This paper provides a legal analysis of the law, in particular Article 12 from the lens of housing, land and property (HLP) and accountability. It draws on a legal review, and consultations with a range of policy, government and civil society representatives. It identifies gaps and proposes recommendations to guide future implementation.
The law constitutes a timely and necessary first step, establishing an overarching legal framework early in the recovery phase and clarifying eligibility for rebuilding in five property categories (including construction on private land, public land, and encroached or prohibited areas). However, it remains high level and heavily dependent on implementing decrees that are either pending or limited in scope. As currently structured, the law primarily benefits owners with clear documentation and financial means to rebuild, leaving complex HLP cases insufficiently addressed.
This paper finds key gaps not addressed in the law which relate to co-ownership, encroachment, tenant protection, gender, and heavily damaged areas. It also does not take into consideration the structural issues with respect to poor land governance in Lebanon, which is particularly pronounced in the South of Lebanon.
In addition, governance and valuation remain central concerns. Past reconstruction processes demonstrated that fragmented valuation systems and politicized compensation bodies undermine trust. Law 22/2025 does not yet establish a unified, transparent damage assessment and compensation methodology, nor does it define appeals mechanisms. Given high community expectations and limited administrative capacity, standardised and transparent valuation—prioritizing speed, equity, and structural safety—will be critical.
Overall, while Law 22/2025 provides a necessary legal entry point, its effectiveness will depend on rights-based implementing decrees, strengthened land governance, inclusive eligibility criteria, tenant protections, gender-sensitive measures, and robust transparency and accountability mechanisms. Without these, reconstruction risks reinforcing pre-existing inequalities and delaying durable solutions for affected communities.
