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INREV’s response identifies that key issues, notably threshold-driven cliff-edge effects and disproportionate compliance burdens, extend beyond venture capital and require a more flexible, tiered and proportionate AIFMD framework that also reflects the realities of the real estate fund industry. 

The Asset Level Index measures the performance of real estate assets across Europe on an annual basis.

INREV supports practical, internationally applicable guidance that mobilises capital towards credible transition activities without unnecessary complexity or duplication. The response emphasises interoperability with existing frameworks, proportional application across real asset classes, and guidance that enables effective capital allocation to real estate transition activities.

INREV supports the FCA's shift towards a more flexible, outcome-based client categorisation and conflicts framework that reduces rigidity, supports informed choice, and promotes proportionate access to professional investment products.

INREV broadly supports the smart meter rollout policy but argues it fails to address a key structural barrier: landlords' lack of access to tenant energy data. Without mandatory data sharing, the policy risks falling short of its decarbonisation objectives, and INREV calls for supplier licence conditions and a more outcome-focused framework to enable real impact.

INREV’s response sets key concerns around the practical application of DAC, highlighting disproportionate compliance burdens, divergent national implementation and the need for simplification to preserve tax neutrality and legal certainty for cross-border real estate investment funds.

INREV calls for a simpler, more harmonised and proportionate EU tax framework that preserves the tax neutrality of investment funds, reduces administrative burden and legal uncertainty, and better supports cross-border real estate investment.