Dear Madam, Dear Sir, please find attached FEANTSA's position on the EPBD recast. In this document, we argue that the EPBD recast is a praiseworthy intent but lacks adequate tools to deliver for the needs of the most vulnerable.
FEANTSA
NGO · Belgium · EU Transparency Register 673689748475-53
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1106 non-governmental organisations on this site, they rank #141 by legislative files engaged, a count of participation, not a measure of influence.
Declares membership of
- European Anti-Poverty Network
- www.eapn.org
- Social Services Europe →
- www.socialserviceseurope.eu
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Non-governmental organisations
- Registered as
- Fédération Européenne d'Associations Nationales Travaillant avec les Sans-Abri (FEANTSA)
- Head office
- Brussels, Belgium
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
FEANTSA filed 9 positions between 12 Mar 2020 and 30 Sept 2026, across 9 of the 665 legislative files tracked here, attaching a full position paper 8 times.
What they argued
At FEANTSA, the European Federation of National Organisations working with the Homeless, we first want to point that restrictively defining the context where public intervention is possible could lead to a reactive regulatory approach instead of a preventative one, undermine the regulatory capacity of local authorities and bring up subsidiarity issues, considering housing is a national, regional and local…
FEANTSA Working together to end Homelessness in Europe FEANTSA’s input to the consultation on Housing supply and affordability (regulatory simplification) The housing simplification package. Procedural & Contextual issues The housing simplification initiative, one of the actions proposed by the Commission in its Affordable Housing Plan, follows several steps of the Commission regarding the competitiveness agenda…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FEANTSA welcomes the EU Electrification Action Plan (EAP) but warns it could deepen inequality unless households in energy poverty are prioritised and social safeguards are built in. 1. Energy poverty Policy discussion often overlook structural issues around electrification.
FEANTSA welcomes the opportunity to contribute to the EU Heating and Cooling Strategy and urges the inclusion of a strong social and equity focus. The heat transition will only succeed if it reflects the housing conditions and financial realities of low-income households. Without clear social targeting, the strategy risks deepening inequality and missing major climate and health benefits.
In the context of the review of the Energy Efficiency Framework, FEANTSA, the European Federation of Homeless Service Providers, highlights the need to enable social service providers to benefit from renovations, given the prevalence of low-performing service buildings and strained budgets.
FEANTSA welcomes the revision of the Governance Regulation and calls for a stronger integration of social considerationsespecially energy poverty and affordabilityacross all provisions. 1. Making Energy Poverty a Priority FEANTSA recommends turning the current indicative objective on energy poverty into a mandatory national target to improve accountability and ensure effective action.
RECOMMENDATIONS FOR THE IMPACT ASSESSMENT ON POST-2030 NATIONAL TARGETS FEANTSA calls on the Commission to ensure that the Impact Assessment for the revision of national targets and flexibilities after 2030 fully integrates social fairness, distributional impacts, and investment constraints faced by vulnerable households.
Consultation on the Commission’s Proposal to Establish a Just Transition Fund Response from FEANTSA (Federation of National Associations Working with the Homeless) FEANTSA believes a climate plan with an aim to leave no one behind should recognise and address the social implications of climate measures in the housing sector, both as risks to low-income households, and as opportunities to further support those living…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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