Land & leasehold
Building on leased land keeps the most expensive item off the balance sheet — where that is actually financeable, across 30 European countries.
A long ground lease is legal in all 30 countries assessed — but only 14 have a regime mature enough to carry a 60-year housing loan. 12 work with caveats a lender prices in, and 4 are weak.
Holding land on a long lease instead of buying it keeps the most expensive item off a housing project's balance sheet. Whether that is a good idea depends on three things a lender cares about: how long the lease can run, whether the lease itself can be mortgaged, and whether anyone has actually built housing on one here. The instrument exists everywhere — the tier is about maturity and finance, not legality.
How this was researched
Two adversarially-verified research passes per country — a deep-research fan-out followed by a per-country research-and-verify pass — scored on the three axes that decide whether a 60-year debt-financed lease is bankable: duration reach, bank-mortgageability and housing track record.
What the tier is measuring
No single test settles the tier: a long term counts for little if no bank will lend against the lease, and a statute counts for little if nothing has been built under it. The track record is the one that does not bend — all 14 Tier A countries have housing standing on a ground lease today.
A— mature, mortgageable, housing-proven (Germany's Erbbaurecht, Dutch erfpacht, Swedish tomträtt). B — the instrument exists but is housing-thin, in reform, or reliant on public lenders. C — short terms, poor bankability, or absent for private housing.
Leasehold viability by country
| Country | EU | Instrument (local) | Max term | Bank-mortgageable? | Housing-proven? | Tier |
|---|---|---|---|---|---|---|
| Austria | EU | Baurecht | 100 yr | Bank-mortgageable | Housing-proven | A · strong |
| Denmark | EU | Bygning på lejet grund | No cap | Conditional | Housing-proven | A · strong |
| Finland | EU | Maanvuokra | 100 yr | Bank-mortgageable | Housing-proven | A · strong |
| France | EU | Bail Réel Solidaire | 99 yr | Conditional | Housing-proven | A · strong |
| Germany | EU | Erbbaurecht | No cap | Bank-mortgageable | Housing-proven | A · strong |
| Ireland | EU | Long leasehold | No cap | Bank-mortgageable | Housing-proven | A · strong |
| Italy | EU | Diritto di superficie | No cap | Conditional | Housing-proven | A · strong |
| Malta | EU | Ċens perpetwu | Perpetual / term | Conditional | Housing-proven | A · strong |
| Netherlands | EU | Erfpacht | No cap | Bank-mortgageable | Housing-proven | A · strong |
| Norway | — | Tomtefeste | No cap | Bank-mortgageable | Housing-proven | A · strong |
| Spain | EU | Derecho de superficie | 99 yr | Conditional | Housing-proven | A · strong |
| Sweden | EU | Tomträtt | No cap | Bank-mortgageable | Housing-proven | A · strong |
| Switzerland | — | Selbständiges und dauerndes Baurecht | 100 yr | Bank-mortgageable | Housing-proven | A · strong |
| United Kingdom | — | Leasehold / Long lease | No cap | Bank-mortgageable | Housing-proven | A · strong |
| Belgium | EU | Erfpacht / Emphytéose | 99 yr | Conditional | Housing-proven | B · viable, with caveats |
| Bulgaria | EU | Право на строеж | No cap | Conditional | Emerging | B · viable, with caveats |
| Croatia | EU | Pravo građenja | No cap | Conditional | Emerging | B · viable, with caveats |
| Czechia | EU | Právo stavby | 99 yr | Conditional | Emerging | B · viable, with caveats |
| Estonia | EU | Hoonestusõigus | 99 yr | Bank-mortgageable | Emerging | B · viable, with caveats |
| Greece | EU | Δικαίωμα επιφανείας | 99 yr | Conditional | Emerging | B · viable, with caveats |
| Lithuania | EU | Užstatymo teisė | No cap | Conditional | Not yet | B · viable, with caveats |
| Luxembourg | EU | Bail emphytéotique / emphytéose | 99 yr | Conditional | Housing-proven | B · viable, with caveats |
| Portugal | EU | Direito de superfície | No cap | Conditional | Emerging | B · viable, with caveats |
| Romania | EU | Dreptul de superficie | 99 yr | Conditional | Emerging | B · viable, with caveats |
| Slovakia | EU | Nájom pozemku | No cap | Conditional | Emerging | B · viable, with caveats |
| Slovenia | EU | Stavbna pravica | No cap | Conditional | Emerging | B · viable, with caveats |
| Cyprus | EU | Εγγεγραμμένη μίσθωση ακινήτου | 99 yr | Conditional | Emerging | C · weak / problematic |
| Hungary | EU | Építményi jog | 50 yr | Conditional | Not yet | C · weak / problematic |
| Latvia | EU | Apbūves tiesība | No cap | Conditional | Not yet | C · weak / problematic |
| Poland | EU | Użytkowanie wieczyste | 99 yr | Conditional | Emerging | C · weak / problematic |
“Max term” is the statutory ceiling — a debt-financed housing model needs 60–99 years. “Bank-mortgageable” asks whether a lender will take the leasehold itself as collateral; Conditional often means only public or social funds will. Open a country for its instruments, lease-end rules, reforms and sources.
30 countries are assessed — the European markets the research covers. A country that is absent has not been assessed, which is not the same as a finding that leasehold does not work there.