by HabitaRetail 
1. A new package of urgent housing and urban planning measures
The Generalitat, despite not having approved budgets for 2025, has opted to implement an emergency regulation that combines immediate actions with structural reforms. Decree-Law 2/2025 includes measures in five main blocks:
2. What changes with Decree-Law 2/2025?
a) Compulsory pre-emption and withdrawal for large holders in stressed areas
The obligation to report all transfers of housing in stressed residential market areas is extended if the transferor is a large holder, whether an individual or a legal entity. This measure applies even to sales to private individuals, subject to justified exceptions (for example, if the buyer undertakes to reside in the property for 10 years).
The housing acquired by the Generalitat in exercise of this right will be classified as permanently protected housing, which will have relevant effects on its legal and fiscal regime.
b) Creation of the Registry of Major Holders
A mandatory registry is created in which both individuals and legal entities that meet the legal definition of a large tenant (more than 5 dwellings or 1,500 m² of residential use) must register. Failure to register or omission of data is considered a serious infringement.
c) New rules for the Registry of Applicants for subsidized housing
Applications will expire after two years if they are not updated, and the obligation to ratify the willingness to acquire a VPO before formalizing the award is introduced. This is intended to avoid inactive or fraudulent awards and to improve the efficiency of the system.
d) Simplification of urban planning and streamlining of public housing development.
Several articles of the Consolidated Text of the Urban Planning Law of Catalonia (TRLUC) and its regulations are amended, with the following objectives:
- Equalize the publicity requirements of management instruments to those of planning.
- Abolish consortiums in Strategic Residential Areas (ARE) and replace them with agreements.
- Establish a specific regime for historical urbanizations with urban development deficits (60s-70s).
- Streamline licenses and urban planning processes for subsidized housing projects, including simplified procedures and more flexible public procurement.
e) Use of rental guarantees to finance subsidized housing
The Institut Català del Sòl will be able to use the deposits to finance public housing developments, provided that it maintains a minimum liquidity reserve of 5%. This represents an important source of resources to promote new VPOs.
3. What should developers and large holders be aware of?
From HabitaRetail we recommend reviewing the following issues as a priority:
- If you are a large holder and you sell in stressed areas, you must communicate the operation to the Housing Agency of Catalonia before formalizing the sale. Otherwise, you may incur in an infraction.
- The sale to private individuals does not automatically exempt from the right of first refusal: if the requirement of habitual residence for 10 years is not met or if the property does not qualify as a VPO, the Generalitat may exercise the right of first refusal.
- For developments subject to pre-emptive/withdrawal, prices and rents are linked to the CPI and updated with the new established modules.
- Individuals must prove their status as a large holder (in case of doubt), and legal entities are required to register in the new registry.
