Our statements on measures taken by the government and other authorities

Lausunto Helsingin asumisen ja maankäytön ohjelmaluonnoksesta

Asuntotarjonnan kasvattaminen on ainut kestävä tie kohtuullistaa kaikkien Helsingin nykyisten sekä tulevien asukkaiden asumiskustannusten kehitystä. Esitämme, että Helsinki nostaa vuosittain valmistuvien uusien asuntojen tavoitteen 7000 asunnosta vähintään 10 000 asuntoon. Esitämme myös joukon suosituksia ja muutoksia AM-ohjelman luonnokseen, jotka
tukevat kunnianhimoisen tavoitteen saavuttamista.

Government proposal for the Parliament regarding charging capabilities and charging points of electric vehicles and the automation and control systems in buildings

The Finnish Landlord Association wants to emphasize the importance of reaching climate objectives. In our opinion, the requirements set in the EBPD directive are adequate for charging points needs. There are, however, other means to significantly reduce traffic emissions. In addition to electrification, traffic in city centers should be reduced. The current proposal would lead to considerable expenses for property owners with no guarantees of the efficiency of vehicle fleet electrification measures.
In our opinion, the proposal for legislation should be adjusted to comply with the minimum requirements of the EBPD directive. For instance, if the price of electric cars goes down in the near future, market demand will result in the creation of more charging points. In addition, government should continue to provide economic support for projects related to adding charging points to appropriate locations. Also, the proposal suggests that a tenant has the right to demand a charging point if the capability is there. This is problematic for housing companies since there is no statement in the proposal regarding the ownership of the charging points and their procurement. This brings confusion for housing companies and for landlords and tenants.

Statement on the draft report by the working group on sharing economy, March 22nd, 2019

The Finnish Landlord Association shares the working group’s opinion on how sharing economy can create new business and a working culture where availability of services, freedom of choice, social aspects, and efficient utilization of resources are emphasized. However, in a worst-case scenario, the benefits of sharing economy may be left unrealized due to an imperfect regulatory environment.

For short-term accommodation, the most important current issues are the drawing of boundaries between a professional and a non-professional operation and the inconsistency in interpretations by various authorities. Housing needs are changing and there must be room for new services to develop in the market. There is a clear need for short-term leases and home-like accommodation services. Any regulations should not aim to protect traditional businesses. Instead, the need for any new or additional regulations must be thoroughly assessed. Regulatory burden should be reduced rather than increased.

Statement on government proposal to Parliament for the 2019 state budget, October 8th, 2018


The Finnish Landlord Association has issued a statement regarding the state budget proposal for 2019. The Finnish Landlord Association wants to draw the attention of the Environment Committee to four essential housing related budget themes:
1. Housing production subsidies are currently an ineffective proposition
2. Investing in traffic efficiently creates housing supply
3. The housing benefit system must be individually aligned
4. Taxation of rental income is ultimately paid by tenants

Statement on the working group report on assessment of tax treatment of different forms of investment, June 15th, 2018

The Finnish Landlord Association has issued a statement regarding the report by a working group focused on the neutrality of different forms of investment. We are still far from neutral treatment of various forms of investment. The working group mainly focused on creating a Finnish investment account model. Neutrality would require that various forms of investment, not only stock investments, are taken into account in the development of the investment savings account. Neutral taxation allows free investment of capital in the most efficient way. With the obstacles related to electronic exchange systems removed with the upcoming electronic housing company register (ASREK), there is no basis for excluding shares in a housing company as an option for an investment savings account.

Statement on the government proposal draft regarding the Act on the Residential and Commercial Property Information System, May 4th, 2018

The Finnish Landlord Association considers the ASREK project a necessary
and welcome development. The need for a register for shares in a housing company and the digitalization of related
processes has existed for a long time. The ASREK project speeds up the general digitalization of the real estate industry and creates prerequisites for companies to digitalize their processes and services. An electronic register for shares in a housing company would allow shares to be included in the planned investment savings account, making taxation of different forms of investment more neutral.

Statement on the proposal by the police authorities regarding the Personal Data Act, January 21st, 2018

The Finnish Landlord Association, Finnish Tenants, and RAKLI have issued a statement regarding the Personal Data Act of the police. We suggest an amendment which would allow the police to hand data over to landlords and to housing companies for ending a lease agreement or for taking possession of the apartment. The right to the data would apply to situations where a police report has been made because of disturbances or violations of a building’s ordinance. The data should include the following: the number and dates of the police reports, the number and dates of police visits to the apartment, and whether these visits were made due to disturbances or violations of the building’s ordinance.

Expert statement: Audit Committee study ‘Areas for development in housing policy’, November 15th, 2017

In the opinion of the Finnish Landlord Association, the study is well prepared. It includes a number of good suggestions for developing housing policy. The Finnish Landlord Association thinks that Finland is on the right path regarding its housing policies. Traffic initiatives and their significance to housing production is better understood and the supportive measures have now begun to shift from production to demand. This is the correct direction for our housing policy.

Statement on government proposal for amending the housing benefit act, October 9th, 2017

The Finnish Landlord Association has a critical opinion regarding the government proposal to add a norm for shared housing in the housing benefit system. This is a bad decision that steers people away from shared housing that helps decrease housing benefit costs. Students are already beneficiaries of the general housing allowance, which further exacerbates the issue. Most shared housing residents are students, and the current concept of a household unit is already affecting the popularity of shared housing negatively.

Expert statement: government’s 2018 state budget proposal, September 21st, 2017

The Finnish Landlord Association would prefer the government to acknowledge the current housing market more realistically. As the current economic cycle favors construction, it is not smart to increase ARA’s production. The mounting taxation of rental income does not help the market. Taxes should be cut in order to slow down the price hikes and to increase supply.

Statement on changing the real estate tax, September 12th, 2017

It is the opinion of the Finnish Landlord Association that the government proposal to increase real estate tax in addition to prior resolutions is a step in the wrong direction. Increased living costs have eroded purchasing power, and continuously increasing maintenance and renovation costs further affect the cost of living. Raising the real estate tax is directly reflected in maintenance charges and rent prices, undoubtedly burdening residents further.

Statement on the cooperative model for social residency, September 8th, 2017

The Finnish Landlord Association supports this proposal. One of the most important goals of the proposal is to simplify the prerequisites for arranging housing. The current production subsidy system does not meet today’s demands and new development models are needed.  The production subsidy system should become more supportive towards special housing services.  The production of regular rental apartments should be based on market conditions, and the potential of private landlords should be utilized better.

Statement on sharing economy, August 18th, 2017

The Finnish Landlord Association sees the sharing economy as a major global trend which will grow stronger regardless of whether it is actively promoted or obstructed or stalled. Trying to stop the sharing economy from flourishing is not smart or even possible with national legislation. Instead, we feel the primary goal should be to adapt the legislation and/or its interpretation to allow for new business models to develop. The legislative environment should set a solid yet extensive framework for various forms of operation. Operations should not be forced into a grey area and the operators should not be made to feel insecure about the legitimacy of their operation or confused about the rules.

Comment on the guidelines for the development of the interest rate subsidy model for long-term loans, April 7th, 2017

In short: it is the opinion of the Finnish Landlord Association that housing subsidies should gradually be shifted from production subsidies to demand subsidies. Housing subsidies should be directed to those who need them most, in the most efficient and fair manner. At the moment, there are approximately 200 municipalities in Finland where ARA rents are higher than free market rents. The subsidy system does not function well if market rents are lower than cost rents.

Statement on new construction via demolition March 30th, 2017

In brief: the Finnish Landlord Association issued a statement concerning new construction via demolition that housing companies pursue. The association sees plenty of positives in the bill but insists some economic incentives should be added for housing companies. New construction via demolition is an option, for instance, during a major plumbing renovation. However, new construction should always be financially worthwhile. Cities especially aim to implement this type of construction. The association feels this would efficiently help compact the urban structure and provide urban infill. The association’s managing director Mia Koro-Kanerva was a member of the working group that prepared the bill.

Statement on the amendment of the act on real estate tax, September 29th, 2016

In brief: the Finnish Landlord Association is against the planned tax increase. The increase will be directly reflected in living costs and rent prices. As the act on real estate tax is amended, the minimum obligation for real estate taxation should be removed so that municipalities have the authority to decide on it themselves.

Statement on amending the Act on Interest Subsidy for Rental Housing Loans and Right of Occupancy Housing Loans, the Act on State-subsidized Housing Loans and the Act on Subsidies for Improving the Housing Conditions of Special Groups, October 11th, 2016

In brief: the Finnish Landlord Association has a critical opinion on subsidized production of rental apartments and sees that it skews the housing market. Allocating public subsidies to those who most need them is best secured by a demand-based system.

Expert statement on the 2017 state budget for the Parliament’s Housing and Environment Sub-committee, October 17th, 2016

In brief: the statement highlights the positive aspects and targets  for development. The land use, housing and transport (MAL) agreements between major cities and the state have had a positive effect. They should be developed further. The Finnish Landlord Association also thinks that ARA’s role in implementing housing policy should be revised and clarified.

Statement for the Finnish Ministry of Social Affairs and Health regarding the inclusion of student housing allowance in general housing allowance, October 19th, 2016

In brief: the Finnish Landlord Association supports the simplification and equalization of housing subsidy systems. From this point of view, the inclusion of the student housing allowance in the general housing allowance is a smart move encouraged by the association. The association also encourages further development of the support systems.

Statement on amending the act on inheritance and gift tax, August 22nd, 2016

In brief: the Finnish Landlord Association supports the reduction of inheritance and gift taxes. This helps keep capital in the rental market. Taxation should also help keep as many rental apartments in the market as possible following succession. In the long run, the Finnish Landlord Association supports the removal of the inheritance tax and the shift to the model used in Sweden which focuses on the taxation of capital gains.

Statement on the government proposal to amend the Act on Subsidies for Improving the Housing Conditions of Special Groups

Statement to the Housing Finance and Development Centre of Finland (ARA) regarding the new model for subsidized production of rental apartments

Statement to the Financial Supervisory Authority regarding the regulations and instructions on the calculation of Loan to Value Ratio

Statement to the Ministry of the Environment regarding the report on the effect of housing subsidy systems and tax systems

Statement to the Housing and Environment Sub-committee of the Finance Committee regarding the 2015 state budget