What Spain committed to the EU on social housing in its recovery plan, version by version (2021–2026)

A Council Implementing Decision (CID) fixes what Spain committed to deliver in exchange for EU recovery funds. The Commission proposed 10 versions of Spain's CID between June 2021 and August 2026. We extracted every social- and affordable-housing measure, milestone and target from each version and diffed the literal texts. That covers four housing measures, ten milestones and targets, and the sentence that restates the number of dwellings.

The ICO loan line for social housing. It went from €4,000 million (2023) to €750 million (proposal of 17 December 2025), then to €567,854,983 (proposal of 7 August 2026): −85.8%. Both times the stated reason was "lack of demand".

The dwelling target (target 31). It went from 20,000 to 17,365, then to 15,718: −21.4%, "because of inflation". Its wording changed in three steps:

• "New dwellings built", whose "construction shall be completed", "as attested by a certificate or proof of completion and use of the dwellings by the competent authority";
• "Provision of dwellings";
• "Construction or rehabilitation of dwellings", with no completion requirement stated.

Context. The December 2025 amendment rewrote the whole annex: in 109 of 234 measure descriptions (46.6%), the text lost more than 30% of its words. The Spanish Government described it as about 160 measures modified. Within that rewrite, the housing measures lost wording about as often as the rest: 2 of 4. Two of their deletions:

• the clause "in particular in areas in which social housing is currently insufficient and on publicly owned land";
• the Land Law amendment for social housing, replaced by an update of the statute of the public land agency (SEPES).

In August 2026 few items lost text, and housing items were among them: the dwelling target and the ICO milestone are 2 of the 5, out of 480 milestones and targets, that lost more than 30%. That version also dropped the ICO line's climate requirement ("At least 53%").

Cost estimates. The Commission's estimate of the dwelling programme's cost went from €1,000 million to €1,920 million, then to €1,885 million. No Commission text we read explains the change; inflation is the only reason stated for the measure. The ECA found the same pattern, target down and estimated cost up, for a Lithuanian renovation measure.

Between consecutive versions we count 19 item-level changes, 2 of them spacing only, in four of the nine amendments.

Adoption. The Commission's own recitals give the adoption date of 9 of the 10 versions; the December 2025 version was adopted on 20 January 2026. For the August 2026 proposal:

• the Council's text prepared for adoption is dated 25 August 2026, and its housing text is identical to the Commission's;
• the Spanish Government states (1 October 2026) that the Council adopted it on 27 August 2026;
• the Commission's scoreboard (refreshed 4 October 2026) already shows the August wording, with target 31 "Not Assessed".

We found no EU record of that adoption. Where we could compare them, the Council's texts match the Commission's in 206 of 206 field comparisons.

Dates (no inference drawn from their order):

• 4 June 2025: the Commission "urges Member States to undertake such plan revisions as soon as possible and, in any event, by the end of 2025".
• 29 November 2025: Spain's request.
• 9 December 2025: its Council of Ministers' approval.
• 16 December 2025: the EU's Affordable Housing Plan.
• 17 December 2025: the Commission's proposal.
• 11 July 2026: Spain's request for the last amendment.
• 7 August 2026: the proposal.
• Target 31 was due in Q2 2026; the cut-off for all milestones was 31 August 2026.

The Commission has not yet assessed target 31, which is part of Spain's last payment request (1 October 2026).

What is new. The Spanish press reported the headline figures from 6 September 2026 (El Confidencial), including AIReF's €1,301 million against the €1,000 million initially planned. What we add is narrow:

• the complete literal record of every housing item in all ten versions, classified;
• the stated reasons, recital by recital;
• the adoption trail with the Council's texts;
• a reusable differ.