Apartment Guidelines Eliminated

03/08/2025

Photo by Selim Karadayı: https://www.pexels.com/photo/aerial-view-of-coastal-town-and-landscape-31793641/

We are acting in response to a housing crisis. There are blockages to apartment building in the regulations we have, we can see that in the slowdown in our much-needed pipeline of apartments. We are taking decisive action, without compromising on any essential regulations, to ensure apartments are viable to build.

Minister for Housing James Browne, 8th July 2025 [1]

The Minister for Housing recently announced that Apartment sizes are to be reduced. This is not a new development, in 2015, as soon as the property industry showed signs of recovery, the legislative basis was enacted to alter planning controls to ensure industry profitability.

Smaller apartments were to be permitted under new planning guidelines published by the Department of the Environment. Local Authorities were subordinated (for the first time), to direct Department of Housing planning control to implement Ministerial directives. That was in 2015.

New Apartment Planning Guidelines (2025)

On 8th July 2025 last, Minister for Housing James Browne again issued new guidelines on building apartments.

These were to effect changes to minimum sizes, to reduce provision of private open spaces and preventing local authorities from requiring communal., community and cultural facilities as mandatory for individual apartment schemes.

Regulatory Blockages

There are a number of assertations in the Departmental statement announcing the new measures.

Namely, blockages exist to apartment building in existing regulations, we can the slowdown in our much-needed 'pipeline of apartments' (Minister Browne) is due to this. The announced measures "compare favourably with European norms" further, it would "will likely result in some cases in an average of €50k and up to €100k cost reduction per unit". How this figure was arrived at is unstated.

Furthermore, the supply of apartments was critical to meeting housing needed and that these changes would "get apartment building moving ... without compromising on disability, fire regulations, or environmental requirements". [3]

New Planning Guidelines

The measures: 'Planning Design Standards for Apartments, Guidelines for Planning Authorities (2025)' set out revised standards for apartment development in relation to matters including apartment mix, internal space standards for different types of apartments, dual aspect ratios, floor to ceiling heights, stair/lift core ratios, storage spaces and amenity spaces - including balconies/patios. [4]

The Custom House, Dublin, location of the Department of Housing, Local Government and Heritage, Photo by Mark Dalton on Unsplash

Studio Apartments

In particular, the minimum size for a studio apartment is reduced from 37sqm to 32sqm. Developers can now include smaller two-bedroom apartments, which have one double and one single room.

Under previous guidelines, the number of these apartments allowed in any development was limited to 10%, this limit has now been removed. A new category of three-bedroom apartment has also been introduced in these new guidelines, one which has one double and two single rooms.

Minimum Sizes for Apartments

The minimum size for these smaller three-bedroom apartments is 76 square meters, the minimum size for a three-bedroom apartment with two double rooms and one single remains 90sqm.

The Department of Housing states that the minimum sizes for Irish studio one-bed apartments are smaller than those in the UK, but these Irish standards mandate larger two and three-bed apartments. [5]

Sizes and Percentages

These are minimum sizes, and apartments could be sized larger, but the Department has relaxed minimum requirements around this. Previous guidelines had required 51% or more of the apartments to exceed the minimum size by 10%. [6]

In 2025, just 25% of developments need to do that. The minimum number of apartments to have dual aspect windows is also reduced. Under the 2023 guidelines, 33% of apartments in a complex in an urban location needed to be dual aspect, with 50% in suburban locations.

There is a new single lower standard of 25%. Planning authorities will now accept a reduced provision of private open spaces such as balconies in certain circumstances.

Communal Facilities surplus to requirements

These new guidelines mean that "Communal, Community and Cultural Facilities" are not mandatory for individual apartment schemes. The Department asserted that communal open space requirements would remain.

Dublin City Council offices on Wood Quay, Dublin. William Murphy, CC BY-SA 3.0, via Wikimedia Commons

Local Authority Reaction

On 7th July, Dublin City Council passed an emergency motion accusing central Government of "overreach" and "gutting" its provision for community and cultural spaces in large scale apartment complexes.

Under the 2022-2028 Dublin City Development Plan, apartment complexes built in Strategic Development Regeneration Areas and those of 10,000 square meters or more had to give 5% of their space to cultural or community uses.

Housing Crisis

Mr Browne said the Government supported "cultural spaces, but not in this manner". "We want to do both, we encourage both, but this is not the way to do it, because ultimately we're in a housing crisis I'm treating as a housing emergency," Mr Browne said.

Communal, community and cultural facilities are no longer mandatory for new developments.

2015 Apartment Planning Revision

Back in 2015, then Minister for Housing Kelly (Labour) also stated that the "viability of new construction" was delaying provision of housing, particularly apartments. This was followed by legislation in 2016, directly subordinating local authority planners to new guidelines, issued by the Minister in 2015. [9]

These guidelines on design standards set new minimum apartment standards. Prior to 2015, the minimum size for a one-bedroom apartment in Dublin City and Cork was 55 square metres, and for a two bed was 90 square metres. 

Simultaneously, the quantity of "dual aspect" (A dual aspect flat (or double aspect flat), is a flat that has been designed with openable windows on two or more walls, allowing for views in more than just one direction,windows may be opposite one another, or adjacent around a corner), apartments required was reduced.

With north facing single aspect (windows or openings on one façade only. Air flow through windows in single aspect homes tends to be lower as there is no cross-ventilation), apartments allowed if overlooking amenity parks or gardens. [10] [11]  

The guidelines further set the minimum size of one-bedroom units at 45 square metres, two beds at 73 and three beds at 90 square metres. Studio apartments of 40 square metres would also be permitted in certain developments. 

Costs Reduced

One specific policy objective was that purchase and maintenance costs (for the developer) arising from was described by the Department as overly burdensome lift requirements would be cut.

Significantly, these new orders took precedence over policies and objectives of both development and local area plans and were applied to all developments whether public or private. [12]

The legislation passed on December 29th 2015 enforced the new Department of Environment, Community and Local Government planning guidelines. [13]

These were previously advisory and utilised at the discretion of local authorities, were now mandatory guidelines adopted if an environment minister so ordered.

No Practical Sense

In 2015, a lecturer in housing and urban economics at DIT, Dr Lorcan Sirr, argued that the Ministerial mandate allowing smaller studio apartments to be built, made no practical or sustainable sense, adding that there had been no economic analysis. He said that new smaller apartments would have the same sale price as the current size so the only winner would be the developer and that Dublin was the only capital city where planning standards were being reduced instead of increased. He alleged that the Minister was "selective" in the choice of comparisons with European cities and that the guidelines would have no impact on encouraging developers to build, instead taxing vacant land would be a greater incentive. [14]

James Browne, Minister for Housing, Local Government and Heritage. By © European Union, 1998 – 2025, Attribution, https://commons.wikimedia.org/w/index.php?curid=150407584

Design Standards, not Building Regulations

The 2025 policy repeats almost verbatim the 2015 rationale, that these new measures are not a lowering of standards and that they are design standards, not building regulations.

Minister Browne echoes Minister Kelly in stating that the Government was not "compromising on any essential (building) regulations, to ensure apartments are viable to build".

In 2015, Minister Kelly stated that this incentive is aimed at encouraging developers to build apartments in the city. Also, apartments were not being built because they are not viable projects for developers. This reasoning is repeated in the 2025 guidelines. [15]

Less = More

The Department seems to be implying that existing regulations inflates market price by creating a disincentive to build in a time of rising demand.

However, there is no published rationale to support the Department of Housing contention that these revised guidelines will reduce the prices of apartments.

Dr. Sirr's contention that reduced size is a gift to the developer, who will sell a smaller apartment at the same price remains as valid in 2025 as it was in 2015.