The Flemish framework agreement for foreign property investigation

Until 2021, every social housing company that wanted to have foreign property investigated had to find an agency itself and launch a public procurement procedure. A few companies, such as Woonhaven in Antwerp and De Zonnige Woonst in Hamme, did so, successfully before the courts. Most companies did not: too much work, too uncertain and too expensive.

That is why the Flemish government, through the then VMSW (Flemish Social Housing Society) and now the agency Wonen in Vlaanderen, concluded a framework agreement with five private investigation agencies in March 2021. The agreement covers investigation in 41 countries; that number relates to the framework agreement, not to the reach of an individual agency. The Flemish Minister for Housing earmarked 5 million euros for it. Every housing company can use it by placing an order; the tendering has already been done.

The framework agreement is open to all Flemish housing companies, the successors of the social housing companies and social rental agencies. A company does not need to register in advance; per case or per series of cases it places an assignment with one of the agencies in the agreement and then applies for reimbursement from Wonen in Vlaanderen.

Public centres for social welfare (OCMWs) do not fall under this framework agreement. An OCMW that wants to have an investigation carried out in connection with the living wage (leefloon) or other support concludes an assignment with an agency itself. How that works is described on the page for OCMWs.

The strongest element of the scheme is the reimbursement. Wonen in Vlaanderen reimburses the costs of an investigation:

• in full if the investigation produces a hit, that is, if real estate is found in the tenant’s name;
• 75 percent if there is no hit.

In the worst case, a housing company therefore pays a quarter of the investigation costs. In the event of a hit it pays nothing, and it can in addition recover the social rent reduction and, depending on the court, the investigation costs from the tenant.

The framework agreement has two types of investigation, with different rates and periods per country.

The wide spread is due to the countries: an investigation in a country with a public online land registry is quick and cheap, an investigation in a country with unregistered property and scattered registers is not. The requests concern countries inside and outside Europe; in spring 2022 Italy produced the most hits, followed by Türkiye (VRT NWS).

From March 2021 to the end of 2022, 35 housing companies had 677 investigations carried out. Real estate was found in 322 cases: a hit rate of 48 percent. In Limburg it was even 53 percent. Woonhaven Antwerp alone recovered 1 million euros. Up to May 2024, 3 million euros had been recovered across Flanders.

In 2025, only 89 reimbursement requests were submitted, with 39 hits (43.8 percent). Use of the scheme is therefore falling sharply, while the hit rate remains high. In other words: many cases involving a suspicion may no longer be investigated. A more extensive analysis can be found in Figures: 677 investigations, 48% hits.

An investigation always begins with a case in which a concrete suspicion exists: a long stay abroad, an address abroad in correspondence or on social media, an inheritance that is being discussed, an income that does not fit the spending pattern. Investigation without suspicion, or on the basis of origin alone, is not permitted.

The practical steps:

1. Gather the identity details of the tenant and the suspected country and region of origin.
2. Have a preliminary investigation or pre-check carried out to find out whether anything is registered in their name.
3. If the outcome is positive, consider a full investigation, with separate arrangements made in advance, including land registry extract, sworn translation and, where necessary, a valuation.
4. Hear the tenant, recover the social rent reduction and, where necessary, terminate the lease.
5. Apply to Wonen in Vlaanderen for reimbursement of the investigation costs.

Outside the framework agreement, you can also commission an investigation directly. At Bureaubuitenland België, every case begins with a pre-check of usually 1 to 2 weeks. Only then do you decide, on the basis of a written estimate, whether an in-depth asset investigation is necessary.

Sources: VRT NWS, 10 December 2020; Knack; N-VA press release on the first results; VRT NWS, 12 April 2022; Wonen in Vlaanderen.