Introduction : Perspectives on housing informality in the “North”

Informal Housing in the Global North Exploring Practices, Actors and Processes in a Transforming Housing System Edited by Jakub Galuszka First published 2026 ISBN: 9781032645254 (hbk) ISBN: 9781032645261 (pbk) ISBN: 9781032645292 (ebk) 1 Introduction Perspectives on housing informality in the “North” Jakub Galuszka CCBYNCND DOI: 10.4324/ 97810326452921 The funder for this chapter is HafenCity Universität Hamburg. DOI: 10.4324/9781032645292-1 This chapter has been made available under a CC-BY-NC-ND license. 1 Introduction Perspectives on housing informality in the “North” Jakub Galuszka Introduction Over the last decade, housing informalities in the socalled Global North have gradually gained recognition as an important research topic and urban phenomenon. Their increased visibility, in particular, has sparked public debates in mainstream media, announcing the return of shanty towns to affluent parts of Europe – often framed as a migrantrelated or “historic” phenomenon. A prominent example cited in this context is the “Calais Jungle,” a makeshift settlement established by migrants and refugees attempting to cross the border between France and the United Kingdom in 2015, which housed as many as 10,000 inhabitants at its peak. The settlement’s stark visual characteristics, associated with poverty, and in sharp contrast to relatively affluent local neighbourhoods, can be considered to have had a twofold effect. On one hand, the issue of basic shelter entered public discourse in a more obvious way than through the more longterm processes of housing expulsion in major European cities. On the other hand, popular understandings of informal housing processes were further obscured by discourses reinforcing longcriticised associations between informality, specific built form such as shantytowns (McFarlane & Waibel, 2012), and migration. In this reading, informality is once again framed as exceptional, transitory and “external” (Haid & Hilbrandt, 2019), effectively opposed to formality and therefore opposed to imagined visions of an orderly “Northern” city. However, at odds with these simplifications, more rigorous investigations into housing informality in the North have followed. While drawing on the theoretically advanced debates from Africa, Asia and Latin America (Bayat, 2000; Roy & AlSayyad, 2004), as well as studies acknowledging the prevalence of various informal urban phenomena in Northern cities (Mukhija & LoukaitouSideris, 2014), recent research on housing informality contributes to the discourse through a significant number of empirical studies. These studies have continued to grapple with the limitations and inherent binary of formalinformal terminology (see, for instance, McFarlane & Waibel, 2012; Marx & Kelling, 2019; Acuto et al., 2019), revealing the significant diversity of informal housing phenomena, which are shaped differently across various local cultural, legal and economic contexts 2 Informal Housing in the Global North (Chiodelli, 2021). A brief review of these cases illustrates the diverse ways in which housing informalities can unfold. The examples encompass phenomena marked by distinct visual qualities associated with selfbuild processes, as well as those that develop more or less undisturbed within the built environment typically associated with formal housing systems. A selection of such cases includes tent encampments, selfbuilt settlements (Finnigan, 2021), and peripheral land subdivisions (Reyes et al., 2024) in the USA, squatting in public housing in Italy (Esposito, 2022), housing in allotment gardens in Germany (Hilbrandt, 2021), various forms of backyard extensions and space conversions (Ferm et al., 2021; Mendez & Quastel, 2015; Kelling, 2024), boat housing (Galuszka, 2024), coliving experiences in UK (Heath, 2021), informal rental practices in Australia (Gurran et al., 2021; Nasreen & Ruming, 2021) as well as informal housing access strategies in New York and Bergamo (Usman et al., 2024; Dotsey & Ambrosini, 2025). Similarly, various forms of shortterm rentals (Colomb & de Souza, 2024), temporary and microliving arrangements, to some extent sanctioned by deregulatory planning systems, are increasingly regarded as representing the informalisation of the housing market from above (Ferreri & Sanyal, 2024). Given the diverse focus of these studies, efforts have been made to systematise and generalise the debate. These efforts capture the main theoretical orientations in discussions of informality (Chiodelli et al., 2024), typify housing phenomena according to their spatial characteristics (Herbert et al., 2024) and examine their relative frequency, mode of production and visibility in the public sphere (Harris, 2018). They also explore the relationality between public sector approaches and the development of informal housing (Chiodelli et al., 2021; Durst & Wegmann, 2017). The debates mentioned above vary not only in terms of typology or analytical category but also in their focus on issues of power, legality, roles of the state and the market, housing precarity, exclusion and marginalisation. While, from one perspective, this multilayered approach highlights the challenges of clearly delimiting the boundaries of the debate, the diversity of approaches to informality also underscores its potential as a heuristic device for investigating broader urban phenomena. Here, informality emerges as a crosscutting concept that serves as a site for critical analysis (Banks et al., 2020), viable across geographic boundaries (Tuvikene et al., 2017; Grashoff, 2020; Galuszka, 2022). In other words, the study of informality, even if focusing on a particular issue such as housing, also provides an opportunity to examine broader societal mechanisms that shape contemporary urban life and unfold across structural factors and everyday agency (Lombard, 2019). This volume takes a similar approach, presenting studies from four continents, characterised by a variety of social, spatial and legal contexts. This broad perspective and focus on dissimilar cases (Robinson, 2011) seeks to provide insights not only from different geographical locations but also from different intellectual traditions, encompassing Anglophone, Francophone and nonEuropean contexts and various methodological approaches, including insights across academia and practice. This includes cases from Berlin, Paris, Oxford and Naples as well as insights from Sydney, Hong Kong and Johannesburg. The two latter cities do not Introduction 3 represent the geographically perceived “North” (a term that is itself an epistemic construct rather than a fixed category). The Hong Kong case (see Chapter 3), however, offers a glimpse of one of the world’s richest and highly developed cities, which suffers from housing shortages and socioeconomic disparities reminiscent of those of major European or North American metropolises. The Johannesburg case (see Chapter 8) provides insights into a once relatively affluent and formally planned neighbourhood that has undergone a trajectory of informalisation and subsequent efforts to reformalise it, representing another common trajectory in large cities around the world. Though contextually distinct in many ways, particularly in terms of the scale and visibility of informal phenomena, it serves as a mirror case study, shedding light on informal practices that resonate across geographical boundaries, in terms of relationships between the power of ontheground local actors and atthetop formal structures. While all these cases may differ in many aspects, several commonalities emerge in terms of the issues, processes and theoretical considerations they reveal. These components are framed around four key principles, which resonate with previous discussions in the field and the contributions of the authors in this volume. In particular, the debate laid out in the volume confirms the interpretation of informality as both local (Haid & Hilbrandt, 2019) and widespread, heavily shaped by state and market operations (Chiodelli et al., 2024; Ferreri & Sanyal, 2024) and intensifying alongside the housing crisis (Potts, 2020). Finally, it focuses on the question of agency embedded in everyday and decentralised informal housing practices (Shrestha et al., 2021; Lombard, 2019; Chiodelli et al., 2024). This focus, oftentimes overlooked in contemporary studies of housing informality beyond the South, at once acknowledges the importance of structural factors in influencing the spread of informal solutions and completes the picture of how contemporary housing systems in the North are constantly reinterpreted and coproduced by their users. Guided by these four key principles, this volume examines various manifestations of housing informality. Through this seemingly niche focus, it aims to shed light on the broader processes of transformation affecting contemporary cities in the Global North and beyond. Housing informalities as a local, permanent and widespread feature of housing systems Firstly, this volume recognises that various forms of housing informality in the North are locally embedded, permanent and ubiquitous features of the housing system rather than external, imported or transitional phenomena. When discussing the localised nature of informalities, a historical perspective is often adopted to illustrate the now largely invisible origins of specific urban areas. In most cases, these phenomena reflect a compelling rationale – whether in the Global North or South (Adegun, 2020) – that rapid urbanisation is a key factor behind largescale and uncontrolled urban expansion. For instance, suburban shantytowns of the nineteenth and twentieth centuries emerged both in major cities 4 Informal Housing in the Global North across Europe and North America, including Rome, Paris, London, Vienna and Montreal (Harris, 1999; Chiodelli et al., 2024), as well as in less known but rapidly urbanising cities such as Łódź in Poland (Zysiak, 2014). While these scholarly examples illustrate that informality was prevalent in Europe and North America in the past, they could also be easily misinterpreted as proof that housing informality is confined to a specific developmental phase and is, therefore, merely transitional. Although this assumption reflects the process of gradually eliminating shantytowns from the urban landscapes of many Northern cities, it offers limited insight into the broader trajectories of informality. As Harris (2018) argues, informal housing tends to spread latently until it becomes overt, prompting authorities to act. In the wealthiest states of the North, where shanty towns proliferated, various forms of public social housing programmes were indeed implemented. However, the pathways of these processes differed across contexts. For example, in Paris, persistent efforts to eradicate selfbuilt settlements (Aguilera, 2016) and develop large housing estates for lowincome population (now forming the banlieues) dominated the housing agenda. Conversely, in Vienna, many suburban selfbuilt settlements underwent gradual consolidation through a blend of approaches that also allowed individuals to formalise their dwellings (Hauer & Kramer, 2023). While such examples may suggest the “end” of informal housing in these cities, they do not rule out the possibility that informal practices have gone from widespread and visible to latent and invisible. This shift complicates our understanding of the scale of informal housing phenomena, including contemporary manifestations, regularisation modalities and potential rebirth as market driven but rebranded housing formats like various microhousing and shortterm rental models. Addressing these issues has emerged as one of the major research gaps in contemporary housing studies, translating into a growing interest in investigating and challenging precarity as the new norm (Harris & Nowicki, 2018). Recent work has also examined this issue from the perspective of informality, documenting the existence of large, hidden housing markets thriving in contemporary cities (Gurran et al., 2021). These markets often flourish within built environments perceived as entirely formal. They manifest through transformations such as backyard extensions, basement adaptations or flat subdivisions, the characteristics of which make reliable quantitative estimates of their scale difficult. Some data, such as that documenting the proliferation of backyard dwellings in California, reveal that while the annual growth of formal housing stock between 1990 and 2010 was estimated at 1.3%, informal units accounted for an additional 0.4% (Wegmann & Mawhorter, 2017). Many formats that exist in a grey area between legality and illegality, shifting across the formalinformal spectrum – depending on the legal and policy environment at any given time – are excluded from such estimates. Formal rules and laws, in this context, are susceptible to interpretation, idiosyncratic and openended (Roy, 2009). In this sense, legality represents an inherently unstable feature of urban development (Caldeira, 2017) (changes in law, rather than static legal definitions, provide a more fruitful analytical lens to examine the dynamic interplay between legality, formality and informality). Visible or semivisible informal Introduction 5 phenomena that attract the most public attention (Lombard, 2019) appear to be on the rise. However, these phenomena may be quantitatively smaller compared to hidden housing practices, which draw far less public attention. Such practices are either tacitly ignored in the policy environment, gradually recognised as legally acceptable or, less commonly, subjected to effective regulation and oversight. Several chapters in this collection explore this issue, illustrating that what surfaces in public discourses as informal often thrives within housing formats historically perceived as entirely formal. Indeed, the archetypes of what is considered formal housing, including private ownership, frequently perpetuate different forms of informal practices, regardless of public sector approaches to that problematic. For example, as discussed by Kingsley and Lam in a chapter focused on Hong Kong (see Chapter 3), private landlords facilitate the subdivision of properties to create substandard microflats, supported by, until recently, the laissezfaire approach of the public sector. Similarly, as Elsner and colleagues document in the Berlin case study (see Chapter 9), head tenants benefit from rent caps and legal protections. However, systemic loopholes enable them to engage in semiformal subletting practices to supplement their incomes. As Kelling (2024) argues, these oftenhidden phenomena epitomise the inseparability of formality and informality. Formal rules, in this interpretation, serve as prescriptions for what individuals should do. However, in practice, these prescriptions are not always known or adhered to. While formal rules may shape behaviour in certain contexts, they can become irrelevant in the face of dominant social practices. Informality, therefore, represents precisely such practices that complement, contest or renegotiate formal rules, functioning as a “structuring feature of everyday life” (Kelling, 2024: 425). What is more, as McFarlane and Vasudevan (2014) note, the belowtheradar practices of everyday life do not merely facilitate the functioning of formal realms; they may, in fact, be more significant than formal structures themselves. With this focus, the interpretation of informal housing practices emerges in a transversal manner through various processes, including realestate operations, changing patterns of labour, mobility and migration, rising digital economies and land shortages, amidst the evolving spatial configurations of cities. Thus, in line with the interpretation of informality adopted in this volume, what is conventionally regarded as marginal informal practices may, in fact, exist within a majority of housing formats across all strata of society, manifesting in diverse ways and serving heterogeneous interests. In practical terms, as the cases in this volume illustrate, such housing practices rarely align entirely with formal or informal categories. They remain wellrecognised social facts, include widespread phenomena but are difficult to quantify and, for that matter, fully regulate or, in some cases, even be intended for regulation by the public sector. Informal housing on the rise amidst an intensifying housing crisis The second principle reflected in this collection is that in the wake of an intensifying housing crisis, informal housing practices are on the rise. However, while 6 Informal Housing in the Global North encompassing a vast array of precarious housing formats, informality is traceable across all income levels. The implications of the housing crisis are straightforward – the decline in affordable options within the formal market pushes individuals to rely on informal solutions that are often precarious, substandard and volatile (Potts, 2020). For instance, as discussed in Espositio’s and Véniat’s chapters (see Chapters 6 and 7) on squatting practices in housing estates in Naples and informal settlements around Paris, respectively, financial or legal marginalisation mobilises insurgent housing practices (Holston, 2009). However, it is important to note that while informality in these cases results from imposed structural conditions, it may also represent a part of longerterm housing strategies, whereby access to formally sanctioned housing is achieved through acts of struggle and spatial appropriation such as squatting of vacant buildings. Such struggles may, in specific instances, be formative in how we interpret questions of rights and obligations in the contemporary city (Vasudevan, 2015). While the sharp increase in the visibility of the most precarious forms of informality, including rough sleeping, tent settlements or shanty towns, may be attributed to new patterns of forced migration (Chiodelli et al., 2024), and, as ElKayed’s chapter shows (see Chapter 5), access to housing is generally more difficult for refugees, the broader issue of housing informality is certainly not limited to new arrivals in Northern cities. On the one hand, the experience of housing struggles in the most “affluent” cities has become so commonplace that it transcends solely marginalised groups and is shared, albeit with varying intensity, by those who previously could expect to secure a permanent and comfortable home with relative ease. This issue inevitably permeates everyday life, becoming a form of shared generational experience. For instance, as discussed in the Berlin case study by Elsner et al. (see Chapter 9), the likelihood of securing an individual rental contract in attractive parts of the city has become so low that formal channels for finding accommodation are increasingly being replaced by informal social networks. Similarly, the expectation of finding a decent home is increasingly being replaced by the acceptance of substandard options in spatial, social and financial terms, as long as these options offer more or less permanent housing in a desired location. On the other hand, these types of informal practices do not exist in a vacuum, nor are they adapted solely by those seeking housing. Property owners and head tenants are equally implicated in these processes – most typically when those with power, knowledge and resources exploit financial opportunities arising from their assets (ownership, permanent contract) by informally converting and renting spaces at prices that do not align with the standards offered. In addition to owners, intermediaries such as middleor streetlevel bureaucrats, immigration officers, housing administrators, informal brokers but also profitseeking private companies appear to play an important role in mediating access to housing opportunities. This is documented, for instance, in a mirror chapter by Mkhize (see Chapter 8), which presents the daily practices of property caretakers within an improvement district in Hillbrow, Johannesburg; ElKayed’s account of refugee housing pathways in Germany (see Chapter 5); and Kingsley and Lam’s inquiry into the role of Introduction 7 architects and building professionals in Hong Kong (see Chapter 3). However, as highlighted by the two former cases, exploitative practices are also accompanied by acts of solidarity that enable access to housing markets that are otherwise sealed off by state regulatory mechanisms and border regimes. In this sense, informality is intensified in the face of the housing crisis, but in some cases, it helps to overcome the shortcomings created by the formal housing system. In others, it is abused by those who have access to assets, power and knowledge. Finally, some scholarship suggests that informality among the affluent is not limited to accepting or facilitating informal uses of their property. It also includes improving their living conditions through notyetcodified solutions, such as luxurious basement developments (Burrows et al., 2022) or leveraging deregulated provisions, for instance, backyard extensions in London (Galuszka & WilkPham, 2022). In other cases, informality involves facilitating access to land and construction processes that circumvent legal procedures (Chiodelli, 2019; Vieda Martinez, 2024) or exploiting legal grey areas, aiming at the extraction of assets (Kusiak, 2019). When additionally considering the role of digital economies and shortterm rentals as a new form of landlordism, the focus of the study of informality, as suggested by Ferreri and Sanyal (2024), shifts beyond the realm of poverty. These issues are also highlighted in the discussion on informal housing practices in Sydney, Berlin and Hong Kong in this volume (see Chapter 2, 9 and 3), including an example of informal subdivision and renting businesses facilitated by formally operating, largescale commercial organisations in the latter. However, further investigation into these issues remains necessary, and the informality of the rich remains an important research gap in current debates on housing in the Global North. Informal housing in a conjuncture between state and market action The third principle applied in this collection is that informality does not operate independently of the state; rather, the state is implicated in the production of informality (Roy & AlSayyad, 2004; Chiodelli et al., 2021), working in conjunction with marketdriven logics of housing delivery. These dynamics are manifest in the rise of new forms of landlordism and rent exploitation. The roles of the state are highly diverse and can be categorised into three main policy approaches: tighter regulation, toleration/ nonenforcement and deregulation (Chiodelli et al., 2021; Durst & Wegmann, 2017). Importantly, even though these approaches may represent dominant trends in specific contexts, they can also coexist, as public sector actors embody diverse agendas within a single institutional setting (Galuszka, 2024; Hilbrandt, 2019). If a commonality can be identified across different Northern contexts, it lies in the stronger connections between the state and the market. This is particularly evident in contexts where deregulation remains the dominant approach. Authorities in such contexts may lower construction standards to stimulate housing delivery by the market. This may involve allowing specific constructions to proceed without planning permissions. Such is the case with the conversion 8 Informal Housing in the Global North of building uses in the UK, which often results in precarious conditions (Ferm et al., 2021). Even though conversions are technically legal, their monitoring is often inadequate, and ontheground implementation blurs the boundary between formal routines and informal practices (Galuszka & WilkPham, 2022; Kelling, 2024). This phenomenon, referred to as informalisation from above, may also occur without physical intervention in space (Ferreri & Senyal, 2024). Instead, it operates through flexible housing logics, in which regulatory grey areas – such as those found in platformbased rental practices – enable opportunities for rent extraction. The toleration or nonenforcement approach positions state action and inaction (Chiodelli et al., 2024) as strong determinants in how housing processes unfold. This is well illustrated by recurring “amnesties” in Italy and Greece, which account for millions of housing units (Chiodelli et al., 2021; Burgel & Darques, 2024). In these cases, the state retroactively legitimises forms of housing that it had previously ignored, but which were built in an informal way, often in violation of official regulations. On the one hand, this legitimisation reflects culturally accepted practices, such as selfmade extensions that create additional floors for household or rental purposes. On the other hand, it conveniently shifts the responsibility for housing provision onto individuals while maintaining the state’s role as regulator of the housing system. Thus, even the passivity by state actors regarding specific informal practices significantly influences the evolution of housing practices in local contexts. This dynamic is evident in the Hong Kong case from this volume (see Chapter 3), which documents past permissiveness towards the creation of substandard subdivided units, coinciding with the public sector’s prerogative to enable housing access for all. Yet, it also points to the fact that on the ground level, there always exist intermediary actors who, for better or worse – and in conjuncture with various interests – take on this broker/ negotiator role in regulating informal relationships. The Hong Kong case illustrates that such roles may be taken by professionals such as architects or building contractors entitled to evaluate the quality of adaptations of specific flats. Meanwhile, the Johannesburg case (see Chapter 8) challenges us to see property caretakers as some of the nonstate actors who behave like state actors – streetlevel bureaucrats – and reinterpret broader market and state agendas to address complex contextual challenges and achieve property management goals. In more regulated contexts, such as Germany or Austria, various solutions (like rent caps) or oversight of shortterm rentals (including Airbnb) are being proactively implemented to control disruptors to affordable housing systems. Furthermore, in regulatory contexts that have traditionally been progressive in facilitating access to affordable housing, widespread civil society campaigns remain visible and relatively influential in the face of a growing housing crisis. These campaigns focus, for example, on housing rights and support the creation of new housing opportunities, as exemplified by initiatives like “Registration for All” and “Right to the City” in Berlin. However, even within these contexts, and in line with the second principle of the volume outlined earlier, the general decline in the provision of social housing has created a situation of scarcity, allowing market Introduction 15 Heath, S. (2021). 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