Irish local authorities are due to have made all of their decisions on this year’s Residential Zoned Land Tax (RZLT) maps by 1 July. What steps can landowners take now to deal with an unfavourable decision?

RZLT is the tax introduced as part of the Government’s “Housing for All” plan, affecting residential and mixed-use land identified on an annually updated map, prepared by the local authority. Owners of land zoned for residential had the opportunity to make submissions setting out their reasons against inclusion of lands on the local authority RZLT maps. The deadline for these submissions was 1 April 2025. The relevant local authority must make its determination by 1 July 2025. The land owner has until 1 August 2025 to appeal the local authority decision regarding submissions. These appeals must be made to An Coimisiún Pleanála (formerly An Bord Pleanála).

It is important to understand the reasoning for the local authority determination. Often a local authority will issue a decision letter and there may be an underlying planner’s report but that may not be included with the letter. Requesting this planner’s report in the first instance is important.

The deadline for appeal is only one month and runs out over the summer months, when key personnel may be on leave. Early engagement with your development team and external planners and solicitors is key to making a strong appeal.

Once the appeal is lodged there is a notional decision date of 31 October for the appeal decision. Some local authorities issue earlier so keep an eye out for the decision. The only avenue for challenging an appeal decision is by way of judicial review. There is a 3 month deadline for judicial review of this decision.

Please see our webinar linked here for KnowledgePlus subscribers which provides an insight into the lessons learned by ALG’s tax, real estate and environmental & planning lawyers on RZLT. KnowledgePlus is available exclusively to A&L Goodbody LLP clients.

For more information, or to request access for you or your team, please contact Alison Fanagan, Consultant, Paul Fahy, Partner, James Somerville, Partner.or your usual ALG contact.

The Minister for Housing, Local Government and Heritage has announced a significant expansion of the Land Development Agency’s (LDA) mandate, aimed at enhancing the delivery of affordable and social housing across Ireland. This development follows a review by the Cabinet Committee on Housing and is intended to align with national planning priorities for sustainable urban and regional development.

Key Measures

The expansion of the LDA’s role will be advanced through six principal measures:

Active land management and private housing delivery

The LDA will further develop its land bank, adopting active land management policies and delivering private housing in suitable locations, in addition to its existing focus on social and affordable housing.

Geographical expansion

The LDA’s operational remit will be broadened to cover a wider geographical area, enabling the Agency to support housing delivery in more communities nationwide.

Unlocking strategic public lands

A focus will be placed on unlocking key strategic public lands, particularly urban brownfield sites, through targeted infrastructure investment to facilitate housing development.

Amendments to land transfer provisions

Provisions of the LDA Act relating to the transfer of lands from commercial state bodies will be amended to expedite the development of suitable sites for housing.

    Tax treatment of cost rental activity

    The LDA will collaborate with the Department of Finance to address the tax treatment of its cost rental activities, with a view to supporting the viability and expansion of affordable rental housing.

    Support for local authorities and master planning

    The LDA will provide enhanced support to local authorities, the newly established Housing Activation Office, and relevant government departments in master planning and infrastructure provision for new towns and districts.

    Implementation and Next Steps

    The Cabinet Committee on Housing has agreed in principle to these recommendations. Relevant Government departments, the LDA, and the Housing Activation Office will now work together to advance the necessary actions and develop detailed proposals for Cabinet approval and implementation.

    We will provide further information in due course but please feel free to direct any queries in the meantime to Aoife Smyth, Knowledge Consultant, or your usual ALG Real Estate contact.

    The Irish Government has officially launched the Modern Methods of Construction (MMC) Action Plan (the Action Plan) which maps out how the Government intends to adopt and embrace the use of MMC across the construction industry. This marks a key milestone in Government’s strategy to modernise the construction sector, expand housing capacity, and create sustainable, skilled jobs.

    The Action Plan is a cross-government initiative to modernise the construction sector, with a focus on innovation, efficiency, and sustainability. It arose from a report issued by the Expert Group on Future Skills Needs (EGFSN) which had been commissioned to assess the current and future skills requirements for the transition to MMC. Following the publication of the EGFSN report, the Department of Further and Higher Education, Research, Innovation and Science developed the Action Plan to target actions that can be taken to implement its recommendations. Input into the Action Plan spanned stakeholders across the construction industry, to include various Government departments, the Construction Industry Federation, the Royal Institute of Architects Ireland, technological universities and other education providers, and industry partners such as Cairn, Glenveagh and Sisk.

    The Action Plan includes 58 targeted actions, under the following 8 key themes, to accelerate the adoption of offsite manufacturing, modular systems, and digital construction tools:

    1. Senior management training;
    2. Information sharing;
    3. New roles and labour retention;
    4. Use of digital and AI tools;
    5. Certification;
    6. Early learning engagement;
    7. Policy levers; and
    8. Training provision.

    Watch this space for a more detailed review of the Action Plan and the recommendations which it makes. In the meantime, should you have any queries please contact Síomha Connolly, Associate, or your usual ALG Construction and Engineering contact.

    The Irish Government passed emergency legislation last week to extend rent pressure zones across the entire country, with effect from 20 June 2025.

    The Residential Tenancies (Amendment) Act 2025 extends rent pressure zones nationwide, with all residential tenancies now subject to a maximum annual increase in rent of 2% per annum or the rate of inflation (measured by reference to HICP), whichever is the lower. This extension applies until 28 February 2026, at which point the reforms referred to in our previous post will replace the existing rent pressure zone scheme in its entirety.

    Rent reviews are now also permitted nationwide on an annual basis – previously these were permitted only once every 2 years in areas outsides of rent pressure zones.

    We continue to await publication of a draft bill providing for the wider residential tenancy reforms promised by Government and will revert with further updates in this regard. Should you have any queries in the meantime, please feel free to contact Aoife Smyth, Knowledge Consultant, or your usual ALG Real Estate contact.

    The Irish Government has today announced its intention to introduce significant changes in the context of the residential rental market.. These are a combination of proposed reforms of rent controls, which the Government hopes to stimulate investment in PRS, and significantly enhanced tenancy protections.

    Key developments

    Under the proposed changes, different categories of rental properties will be subject to different treatment, with key distinctions emerging between large versus small landlords and between existing rental stock versus newly built properties.  Much detail remains unknown but, based on the Government announcement issued just after 1pm today, we have set out below our high-level summary of what is proposed for large landlords. Owners with three or less units will be subject to different, more relaxed measures.

    Next steps

    As with any new policy proposals, the devil will ultimately be in the detail and we await publication of the draft legislation required to give effect to these reforms, which the Government indicates will be published in the coming weeks. We will continue to monitor these and related developments. 

    In the meantime, should you have any queries please contact Aoife Smyth, Knowledge Consultant, or your usual ALG Real Estate contact.

    Setting of rent on grant of new tenancySetting of rent on reviewTenancy termination (applicable to new tenancies entered into from 1 March 2026)Key items requiring further clarification in legislation
    Existing property in an RPZ and subject to an existing tenancyNew provision.

    Landlords will be permitted to reset rents to prevailing market rates between tenancies. However, this will only be possible where a tenant has either left voluntarily or is in breach.    		No change.

    Current RPZ rules continue to apply, with rent increases for reviews under existing tenancies capped at 2% per annum or in line with inflation, whichever is the lower.    		New provision.

    Enhanced tenant protections meaning landlords will not be able to end a tenancy where the tenant has complied with their obligations except in “very limited circumstances”.  These protections seem to be underpinned by a new statutory concept of six year rolling tenancies.     		Unclear whether new RPZ rules take effect on 1 March 2026 or before.
     
    No clarity provided on what the “very limited circumstances” for termination will be.
     
    The full implication of the concept of statutory six year rolling tenancies is as yet unclear in the context of fixed term arrangements.
    New build property in an RPZ (being new development subject to a commencement notice to planning authorities on or after 10 June 2025)New provision. 

    Landlords will be permitted to reset rents to prevailing market rates between tenancies. However, this will only be possible where a tenant has either left voluntarily or is in breach.    		New provision. 

    Newly constructed rental properties are to be exempt from the existing RPZ regime which caps increases in rent at 2%. Instead, rent increases will be capped at the rate of inflation (CPI).    		New provision. 

    Enhanced tenant protections meaning landlords will not be able to end a tenancy where the tenant has complied with their obligations except in “very limited circumstances”. These protections seem to be underpinned by a new statutory concept of six year rolling tenancies.    		It appears from today’s announcement that the definition of “new build” is limited to apartments.
     
    See issues raised above also.
    Existing property in the balance of the country not currently designated as RPZsNew provision. 

    Landlords will be permitted to reset rents to prevailing market rates between tenancies. However, this will only be possible where a tenant has either left voluntarily or is in breach.    		New provision. 

    Current RPZ rules are to be extended to cover these areas, such that rent increases for existing stock countrywide are to be capped at 2% per annum or in line with inflation, whichever is the lower.    		New provision. 

    Enhanced tenant protections meaning landlords will not be able to end a tenancy where the tenant has complied with their obligations except in “very limited circumstances”. These protections seem to be underpinned by a new statutory concept of six year rolling tenancies.     		Currently rent review frequency in  these areas is limited to every 2 years – query whether this will be brought in line with current RPZs (i.e. permitted annually).
     
    See issues raised above also.

    Ireland’s revised National Planning Framework (NPF) was recently approved by the Government, and (subject to Oireachtas approval) will set the strategic vision for Ireland’s growth and development out to 2040.

    This is the first revision of the National Planning Framework as required under the Planning and Development Act 2000 (as amended). There is substantial overlap between the first and the revised NPF, and indeed the overarching National Strategic Outcomes remain the same. But there have been some key changes to the detail of these strategic outcomes that reflect:

    • how Ireland has changed over the last five years
    • changes to Ireland’s legislative and regulatory frameworks
    • some real imperatives in terms of housing.

    Housing

    The revised NPF targets the delivery of 50,000 new homes a year, doubling the previous goal set by the first NPF. Whilst this is a significant increase in ambition, the overarching NPF strategy in relation to housing largely remains the same. What has changed is that where the first NPF set out ideas or goals for new regulation, policy and legislation to support the strategy, the revised NPF fills in some blanks with the actions of the Government over the past seven years.  In that respect, the revised NPF (and the subsequent guidance the Government intends to provide) provides a more concrete roadmap for how Ireland might achieve this ambitious housing goal.

    National Strategic Outcome 1 – Compact Growth provides a clear example of this shift. In the years since the first NPF, the Government has established the Urban Regeneration and Development Fund and the Rural Regeneration and Development Fund. Outcome 1 has also been expanded to include the Residential Zoned Land Tax, which comes into effect in 2025 and aims to activate suitably zoned and serviced land for development. Similarly, the first NPF set out the Government’s objective to establish a strategic and centrally-managed approach to realising the development potential of state owned/influenced lands – and now, with the Land Development Agency fully operational, the revised NPF provides a specific Objective for the LDA’s role in the future.

    There are some completely new additions to the overall strategy – for example, an increased focus on how to evaluate land for zoning. Local authorities should not zone land for development if it cannot be serviced within the life of the relevant plan. Given the last zoning update was 2022/2023, there may be a question of whether an interim rezoning is now required. As expected, the revised NPF refers to the Planning and Development Act 2024, and expects that it will provide key legislative tools to achieve Ireland’s housing goals.

    For further information in relation to this topic, please contact Brendan Curran, senior associate, Alan Roberts, partner, Alison Fanagan, consultant, Jason Milne, partner or any member of ALG’s Environmental & Planning team.

    The Planning and Development Act 2024 (the 2024 Act), signed into law on 17 October 2024, represents a significant overhaul of Ireland’s planning system.  The 2024 Act aims to enhance clarity, improve consistency, and increase confidence in the planning system.  Key reforms include mandatory decision-making timelines, reorganisation of An Bord Pleanála, alignment of plan-making tiers, and changes to the judicial review process.  On 4 March 2025, the Department of Housing, Local Government and Heritage (the Department) published an implementation plan to set out the phased commencement of the 2024 Act.  

    Phased Commencement

    The 2024 Act will be commenced on a phased basis, with the existing provisions of the Planning and Development Act 2000 (the 2000 Act) remaining in place until the relevant provisions of the 2024 Act are commenced and the corresponding provisions of the 2000 Act are repealed. The 2024 Act includes a number of ‘transitional provisions’ which will be important in navigating this period of transition. The phased commencement is divided into four blocks (A, B, C, and D).

    Block A (early Q2 2025): Aspects of the 2024 Act covered in this first commencement stage are to include the following: concept of Development in section 15, Chapters 1 & 3 of Part 9 relating to judicial review, Part 16 (Events and Funfairs) and Part 17 providing for the establishment of An Coimisiún Pleanála.

    Block B (mid-2025): The second commencement phase will include the following: Part 3 (Plans, Policies and Related Matters), Chapters 1 & 2 of Part 6 (Environmental Assessments), Chapter 1 of Part 7 (Housing Strategy and Supply), Part 18 (Office of the Planning Regulator) and Part 22 (Urban Development Zones).

    The remaining sections of the 2024 Act will be commenced in Blocks C and D with further details as to timing to be provided once Blocks A and B have been commenced.

    The commencement timeline will be updated regularly and confirmation of specific dates will be issued in advance of any provisions coming into effect.

    Revised Planning and Development Regulations

    In September 2023, the Department began examining existing regulations to identify alignment with the new Act, any new regulations required, and the scope of work needed.  This task was substantial, involving over 100 existing regulations amounting to approximately 1,200 pages.  The review identified areas needing major revision or entirely new regulations, while many existing regulations require updates to reflect the structure and language of the new Act. It is envisaged that revised Planning and Development Regulations (the Regulations) will be finalised to align with the commencement of the relevant provisions of the 2024 Act which they support.

    The proposed structure of the Regulations is detailed in a table within the implementation plan.
    Public consultation will be undertaken for certain regulations, including exempted development regulations and EIA screening threshold regulations.  Regulations dealing with the new judicial review legal costs regime under Part 9, Chapter 2 are the responsibility of the Department of Climate, Environment & Energy.

    Conclusion

    The commencement of, and transition to, the 2024 Act is a task of “considerable scale and complexity” and the publication of the phased implementation plan is to be welcomed. The Department recognises the imperative of ensuring a smooth transition to the new planning regime.  It is envisaged that the Department will have a dedicated website for the rollout of the 2024 Act and the associated revised regulations which will include commencement information, general guidance material, updated commencement schedules etc. On 7 March 2025, the Department published a helpful Correlation Table listing each section of the 2000 Act and identifying a section, or sections, of the 2024 Act which corresponds closest to that provision. Our Environment & Planning Team will provide further updates as commencement of the 2024 Act proceeds.

    For further information in relation to this topic, please contact Alison Fanagan, Consultant,  Alan Roberts, Partner, Jason Milne, Partner, Rachel Kemp, Senior Knowledge Lawyer, or your usual ALG Environmental & Planning contact.

    The Irish press has reported this week that Taoiseach and head of the incoming government, Micheál Martin, has indicated that rent pressure zones (RPZs) may be phased out when their current designation expires at the end of 2025.

    Mr Martin said on Sunday that “we have time to see if we can develop an alternative system which protects renters but also a clear, stable environment in which to invest” and that the State needs to “pivot more strongly to getting private sector investment into the market”.

    This aligns with the recent Programme for Government which emphasises the need for private investment in the housing market, calling out the need to:

    • Achieve stable and predictable policy to attract and retain private investment combined with record state levels of funding to finance the €24 billion per annum needed to build 60,000 homes annually by 2030.
    • Develop new financing sources, especially for brownfield sites and small builders, with support from Home Building Finance Ireland (HBFI), the Housing Finance Agency (HFA) and domestic banks as well as state support of equity investment.

    The Irish Times is today reporting that a review of the RPZ system is being carried out by the Housing Agency and is expected to be completed by the end of Q1. It indicates that one of the options being considered is a “reference rent” system, which was a recommendation of the Housing Commission in its report published in May 2024. The proposal is that, under such a system, rent increases would be determined by a reference rent for local homes of a similar quality, as opposed to the 2% cap currently imposed by the RPZ system. It remains to be seen whether this, or alternative options, will be favoured by Government.

    We will follow developments in this area closely over the coming months. In the meantime, should you have any queries please contact Aoife Smyth, Knowledge Consultant, or your usual ALG Real Estate contact.

    The Dáil is expected to elect a new Taoiseach tomorrow, which will mark the formal commencement of the new coalition government. The government parties have agreed a new Programme for Government (the Programme), the “Accelerating Housing Supply” section of which outlines a comprehensive strategy aimed at tackling housing supply issues. This post sets out what you need to know.

    A step-change in housing supply

    The government acknowledges the critical need to increase housing supply to meet both current and future demand. It intends to introduce a successor to the “Housing for All” plan and aims to build over 300,000 new homes by the end of 2030. This ambitious target is underpinned by a multi-annual funding commitment and a stated intention to “ramp up construction capacity”.

    Planning and active land management

    To facilitate the intended increase in housing supply, the Programme emphasises streamlining the planning process by:

    • implementing the Planning and Development Act 2024, which became law in October 2024 but which is to be commenced in stages;
    • strengthening and streamlining compulsory purchase order (CPO) powers with a view to activating under-utilised land;
    • fully resourcing the Ministerial Action Plan on Planning Resources, recruiting additional planning staff and creating a public audit of zoned, serviced and unzoned land;
    • enhancing the resources of the Planning and Environment Court to address litigation efficiency; and
    • local authorities facilitating pre-planning meetings for significant developments.

    The aspiration is that these measures should promote a faster and more predictable planning environment for the benefit of all stakeholders, to include developers and investors.

    Investment in infrastructure

    Recognising the critical link between infrastructure housing development, the government is to support Uisce Éireann in delivering key strategic projects. This includes various proposals to ensure large developments can proceed without delay, for example a new procedure for large developments above 100 units whereby a developer can meet local authority planners and Uisce Éireann on site to iron out issues at pre-planning stage. Additional capital is also to be invested, prioritising water and wastewater infrastructure.

    These changes should address infrastructure bottlenecks that have historically delayed housing delivery.

    Reducing delays and red tape

    A National Housing Procurement Strategy will support housing standardisation with a view to reducing costs and delays, while a Central Housing Construction Supply Unit will also be established to co-ordinate and monitor all major public sector construction projects. It is also intended that a Land Price Register will be established, although there is currently no further detail as to what this will entail.

    Modern methods of construction (MMC)

    The Programme for Government includes several initiatives under its commitment to MMC, aimed at driving innovation and efficiency in housing delivery. Key elements include:

    • The establishment of an MMC Innovation Fund to fund new housing factories and expand existing ones;
    • The introduction of binding MMC targets, whereby at least 25% of all state-backed housing projects must utilise MMC;
    • An overhaul of the National Standards Authority of Ireland, aligning Irish regulations with EU standards; and
    • Promotion of the use of sustainable materials, to include multi-storey timber-frame residential units.

    Land Development Agency (LDA)

    The LDA will be further capitalised and its housing delivery targets increased up to 2030. It will also be granted strengthened CPO powers to activate under-utilised land for home building. Efforts are also to be accelerated to transfer under-utilised State lands appropriate for residential development to the LDA.  

    The rental market

    The Programme outlines a framework designed to support the rental market, with key points including:

    • Expansion of cost rental units through the LDA, local authorities, and Cost Rental Equity Loan funding to Approved Housing Bodies, embedding cost rental as a permanent tenure category;
    • Ongoing review of income criteria for cost rental to ensure broader tenant eligibility;
    • Continued support for affordable rents via the Secure Tenancy Affordable Rental scheme, with criteria under review to encourage greater private developer participation;
    • Establishment of a Rent Price Register;
    • Enhanced enforcement powers for the Residential Tenancies Board, including statutory timelines for complaint resolutions; and
    • Continued review of the effectiveness of Rent Pressure Zones.

    Conclusion

    The Programme sets out an aspirational vision for transforming Ireland’s housing landscape, with numerous ambitious initiatives designed to address the housing crisis. However, it remains to be seen which elements will take priority and how they will be implemented. An updated legislative programme, expected in the coming weeks, should provide clarity on the Government’s immediate priorities and the focus areas for the months ahead.

    For more information, please contact Aoife Smyth, Knowledge Consultant, or any member of ALG’s Real Estate team.

    Our Annual Knowledge Report 2024 is now available for viewing. This is the ninth year that the A&L Goodbody Knowledge team has published its report looking at the year’s key legal developments and those in the pipeline for 2025. For the first time, the report has been produced as a digital publication.

    The report covers legal developments in real estate and across a range of other areas including investment funds, finance and litigation and disputes. It also includes analysis of developments in data protection, employment, financial regulation, corporate and ESG, and EU and competition law. Additionally, we feature in-depth articles on knowledge management and the impact of the dissolution of the Dáil on legislation.

    Each chapter of the report is laid out in three sections:

    • ‘2024 at a glance’ highlights the key themes of the past year.
    • This is followed by a review of the year’s legal developments.
    • We finish with a brief ‘looking ahead’ to developments on the horizon.

    Also published this week was our Annual Knowledge Webinar. Available here is an extract from the webinar where Aoife Smyth, Knowledge Consultant with our real estate team, provides an update on proposed reforms to the Irish conveyancing process which have the potential to have implications for dealings in commercial property.

    For further information on any of the topics raised, please reach out to your usual ALG Real Estate contact.