Real estate investments after 1 January 2026: key changes under the new ZPU
As of 1 January 2026, the new Spatial Planning Act applies, and the previous act has been repealed. Although at first glance it may seem like a technical statute for planners and public administration, the changes are very concrete for investors and landowners: faster and more digital procedures, clearer deadlines, a stricter regime on the coast and in tourism, and mechanisms that can unblock projects that have been stuck for years due to infrastructure.
One of the biggest changes is a full shift towards digital planning. Spatial plans are prepared and adopted in the information system through ePlanove, and the decision on adopting a plan must also be published in ePlanove no later than 15 days after publication in the official gazette. In addition, the implementation provisions, maps and explanatory statement must be published in the official gazette and electronically on the relevant websites and in the information system within 30 days from the date the decision enters into force; the same applies after every amendment or supplement to the plan. In practice, this means plan data will be more accessible and easier to review, but it also means the latest version of the documentation becomes critical in due diligence: when buying land or preparing a project it will no longer be sufficient to rely on an old PDF copy or unofficial excerpts—it’s important to verify the status in the system and the official publications.
A particularly important change relates to existing spatial plans and their period of validity. The new act provides that, for plans adopted under earlier regulations, a decision to prepare amendments and supplements can no longer be made in the traditional way, but as a rule only as “new‑generation” plans. In addition, these plans cease to apply within seven years from the act’s entry into force, which in practice means a broad wave of transformations and new plans is expected by 1 January 2033. This matters to investors because long-term projects (especially those financed by loans or developed in phases) must factor in from the outset that the planning framework may change and that municipalities and cities will initiate new procedures. That does not have to be negative, but it increases the importance of timely preparation and checking the stability of the planning framework before committing significant costs.
The second major set of changes concerns infrastructure and municipal servicing—i.e., who must ensure the basic prerequisites for construction, and when. The act expressly requires local self‑government units to set the dynamics of municipal servicing so that a building area is municipally serviced no later than five years from the date it is designated in the spatial plan, and existing building areas must be serviced within five years from the act’s entry into force. Along with the budget, an annual programme for building municipal infrastructure is adopted with a three‑year projection. This is an important message for projects on the edges of zones and settlement expansions: infrastructure is no longer merely a matter of political will and improvisation, but comes with clearer deadlines and planning responsibility.
At the same time, the act gives investors a tool to kick‑start the resolution of infrastructure where a project is already planned but is realistically unfeasible because basic connections and access are missing. If a building area is not equipped with basic infrastructure, an investor may submit a statement of interest. This has to be a serious document and includes: a commitment to finance the preparation and adoption of an urban development plan if it has not been adopted; resolving property‑law issues in the name and for the account of the JLS; construction of basic infrastructure; evidence of financial capacity; evidence of legal interest; and a traffic and municipal‑infrastructure expert study analysing the contact area and possible connection. Crucially, the act sets triggers on the JLS side: if within three years of the statement of interest the JLS does not adopt an UPU where it is mandatory, it is deemed that the investor has proven it can act as the investor of basic infrastructure; the same applies if the UPU exists but the JLS does not equip the area with basic infrastructure within three years.
In addition, the communal contribution payable for the investor’s building is reduced by the amount invested in documentation and the construction of infrastructure.
This mechanism is especially useful for larger projects where it is economically sensible for an investor to deliver the infrastructure, but it is important to structure contractual relationships, costs and risks properly from the outset (because in practice the investor takes on both the financial and time burden).
The third set of changes is visible in location permit procedures and communication with public-law bodies. The procedure for issuing a location permit is initiated electronically through eDozvolu. Public bodies must respond and provide special conditions or connection conditions within 30 days of the request; if they do not, it is deemed that the special conditions have been issued, i.e. that the building may be connected to the infrastructure. This can significantly speed things up in practice, provided the conceptual design is orderly and complete, because the entire mechanism relies on the quality of the input documentation and on timely monitoring of the procedure.
Related to this, another practical change is how a large number of parties are notified. Where a location permit is issued in a procedure involving more than ten parties, or where the intervention borders more than ten parcels (or is formed from ten or more parcels), parties are invited to inspect the file by a public notice published on the electronic noticeboard. For investors, this means objections, deadlines and procedural rights will increasingly be tied to electronic postings, so it is important to have a clear communication strategy with neighbours and orderly property‑law preparation, especially for larger developments or parcel subdivisions.
The fourth set of changes is particularly important for tourism projects and projects along the coast. The act regulates planning of hospitality‑tourism uses and camps in more detail and introduces very clear restrictions in relation to the coastline. For example, in detached building areas outside settlements designated for hospitality‑tourism use, accommodation buildings must be at least 100 m from the coastline, while in the 25–100 m belt only certain facilities are permitted (such as open pools, sports fields, sunbathing areas, promenades, terraces and sanitary facilities), and in the belt up to 25 m it is possible to arrange beaches,
parks and greenery. For camps, the rules are even more precise: in a camp outside a settlement, within 25 m of the coastline it is not possible to plan construction or place modular/prefabricated cabins and similar interventions, except for arranging beaches and greenery; within 25–100 m, construction and placement of cabins are also prohibited, except for a limited set of facilities and areas for placing camping equipment. In camps within settlements, within 25 m of the coastline it is likewise not possible to plan buildings or place modular cabins, subject to the listed exceptions. It is also important that the act explicitly states that mobile homes are counted in a camp’s built‑up ratio regardless of whether they are firmly attached to the ground, which in practice affects a camp’s capacity
The act goes a step further by introducing transitional rules for existing camps. Camps that on 1.1.2026 have a valid decision confirming they meet the conditions for providing hospitality services may remain in place for up to ten years, but modular/prefabricated cabins and other interventions within the camp in the belt 25 m from the coastline must be removed within five years from the act’s entry into force—i.e. by 1 January 2031. Furthermore, for camps that remain in place, the act requires an improvement of the state of the area (for example, a share of greenery and limits on built-up area) within ten years, and for such an improvement as a complex intervention it is necessary to obtain a location permit determining the siting of all parts of the intervention and the position of mobile homes.
Fifth, the act delivers a very clear message on condominium subdivision of tourist accommodation buildings. Hospitality‑tourism buildings intended for accommodation may not be subdivided into separate units. There is an exception, but it is narrowly limited to top‑category five‑star buildings, provided that at least 70% of accommodation capacity is hotel accommodation and that the remaining 30% may be subdivided into villas and apartments only after an occupancy permit has been issued for the hotels and accompanying facilities. Such facilities must operate as a single whole with centralised management and letting; villas and apartments are not intended for residential use; the contract must limit owner use to no more than 60 days per year, along with a number of additional obligations and sanctions. It is expressly emphasised that subdivision is not permitted on the area of pomorsko dobro.
In conclusion, the new act changes the game most in three typical situations: where a project depends on future amendments to spatial plans, where a project is stuck due to infrastructure, and where it involves tourism and the coast. In all of these cases it is advisable to conduct a legal check before investing in design and acquisition: verify the status of the spatial plan and the expected transformations by 1.1.2033, verify the actual level of infrastructural servicing and whether the statement‑of‑interest mechanism can be used, and for tourism projects precisely analyse distances from the coastline and the applicable transitional rules.
As of 1 January 2026, the new Spatial Planning Act applies and the previous act ceases to be valid. Although it sounds technical, the changes are very tangible for investors and landowners: more digital and faster procedures, clearer deadlines, stricter coastal and tourism rules, and a tool for situations where a project gets stuck due to infrastructure.
The biggest change is a full shift to digital planning. Spatial plans are prepared and adopted through ePlanove, and publications are tied to short deadlines: the decision on adopting a plan must be visible in the system very quickly (no later than 15 days), and all key
attachments (provisions, maps and reasoning) should generally be available within 30 days. In practice this means clearer information, but it also means that for checks (land acquisition, project preparation) what is officially published in the system becomes decisive.
Another important change concerns the lifespan of older plans. Plans adopted under earlier rules are gradually moved into the new generation, and some of them cease to apply within seven years, which in practice pushes a major wave of alignment by 1 January 2033. For investors this means: for long-term projects, it is worth checking early on how stable the planning framework is and whether amendment procedures are likely to start soon.
The third set of changes concerns infrastructure. The act reinforces the responsibility of cities and municipalities: municipal servicing should no longer be “whenever it happens”, but according to a plan and a deadline (generally 5 years). This is particularly important for edge zones and settlement expansions, where projects often break down on access, water, drainage or electricity.
At the same time, an investor gets a de‑blocking mechanism where an area is planned but realistically cannot be delivered without infrastructure. If basic connections and access are missing, the investor can submit a statement of interest and take on certain obligations. If the city/municipality still does not act within 3 years (for example by failing to adopt the required plan or by failing to equip the area with basic infrastructure), the act opens the path for the investor to take on the role of investor of basic infrastructure, with the ability to offset part of the investment against communal obligations. This is most useful for larger projects, but it requires good preparation and solid contractual arrangements because the investor takes on both the cost and the timetable.
The fourth set of changes concerns location permit procedures and communication with public authorities. The process runs electronically and authorities have 30 days to issue conditions. If they do not respond, the procedure should not be dragged out indefinitely—the idea is that administrative silence should not block a project. For larger interventions with many neighbours/parties, notifications are made via electronic postings, so it is important to monitor postings systematically and have a plan for communication with neighbours.
The fifth and most sensitive set of changes concerns the coast and tourism. Clear zones and distances from the coastline are introduced. In detached tourism zones, accommodation is pushed further from the sea (typically 100 m), while the 25–100 m belt and especially the belt up to 25 m are reserved for limited facilities (landscaping, promenades, sports, greenery, etc.). For camps, the rules are even stricter: within 25 m there can be no cabins and similar interventions, and within 25–100 m the possibilities are very limited.
For existing camps, the act introduces transitional rules: camps may remain for a certain period, but cabins and interventions within the 25 m belt must be removed by 1 January
2031; and for continued operation and modernisation, arrangements and demonstrable improvements are generally required, together with the relevant permits.
Finally, the act sends a very clear message on subdivision of tourist accommodation buildings: the general rule is a prohibition. An exception exists but is narrow (top category, predominantly hotel capacity, centralised management and restricted owner use), and it is emphasised that subdivision is not permitted on the area of pomorsko dobro.
Given the above, the new act changes the rules of the game in three situations:
- when a project depends on future plan amendments,
- when it gets stuck on infrastructure,
- when it relates to the coast and tourism.
In practice, before incurring major costs it pays to do a quick legal check: the status of the plan (and how secure it is through 2033), the area’s actual infrastructural servicing and whether the statement‑of‑interest mechanism can be activated, and for coastal projects a precise review of the coastal belts and transitional deadlines.
In conclusion, for higher‑value investment projects it is especially important that planning status, deadlines and infrastructure prerequisites are clearly established and documented, because they directly affect feasibility, phasing and the ability to secure financing. The new ZPU brings more transparency, but it also requires a more disciplined approach to verifying assumptions at the outset.
As of 1 January 2026, the new Spatial Planning Act applies, and the previous act has been repealed. Although at first glance it appears to be a technical regulation for planners and public administration, the changes are very concrete for investors and landowners: more digital procedures, clearer deadlines, a stricter regime on the coast and in tourism, and mechanisms that can unblock projects that have been stalled for years due to infrastructure.
One of the biggest changes is a full shift to digital planning. Spatial plans are prepared and adopted in the information system through ePlanove (čl. 83.), and the decision on adopting a plan must also be published in ePlanove no later than 15 days after publication in the official gazette (čl. 133. st. 2.). The implementation provisions, maps and explanatory statement are published in the official gazette and electronically on websites and in the information system within 30 days from the decision’s entry into force (čl. 134. st. 2.), and the same applies after each amendment or supplement to the plan (čl. 135. st. 3.). In practice, this means more accessible and clearer data, but it also means the “latest version” becomes critical for due diligence: when acquiring land and preparing a project, it is important to check the status in the system and the official publications rather than relying on old copies.
An important change is also the “period of validity” of existing plans. For plans adopted under earlier regulations, as a rule a decision on preparing amendments and supplements can no longer be taken in the traditional way, but as new‑generation plans (čl. 238. st. 1.). Such plans cease to apply within seven years from the act’s entry into force (čl. 238. st. 2.), which in practice means a broad wave of transformations and new plans is expected by 1 January 2033. This matters to investors because long‑term projects (especially those financed by loans or developed in phases) must factor in potential changes to the planning framework from the outset.
The second major set of changes concerns infrastructure and municipal servicing. The act requires local self‑government units to set the dynamics of municipal servicing so that a building area is municipally serviced no later than five years from the date it is designated in the spatial plan, and existing building areas must be serviced within five years from the act’s entry into force (čl. 205. st. 1.). Along with the budget, an annual programme for the construction of municipal infrastructure is adopted with a three‑year projection (čl. 205. st. 1.). For edge‑zone projects, this signals that servicing comes with a deadline and planning responsibility.
At the same time, investors are given a tool for situations where a project is planned but cannot be implemented without connections and access. If a building area is not equipped with basic infrastructure, an investor may submit a statement of interest (čl. 208. st. 1.). The statement must include: a commitment to finance the preparation and adoption of a UPU if it has not been adopted, resolving property‑law relations in the name and for the account of the JLS, construction of basic infrastructure, evidence of financial capacity, evidence of legal interest, and a traffic and municipal‑infrastructure expert study analysing the contact area and possible connection (čl. 208. st. 2.). The act sets triggers on the JLS side: if within three years of the statement of interest the mandatory UPU is not adopted, it is deemed that the investor has proven it can act as the investor of basic infrastructure (čl. 208. st. 3.); the same applies if a UPU exists but the JLS does not equip the area with basic infrastructure within three years (čl. 208. st. 4.). The communal contribution is reduced by the amount invested in documentation and the construction of infrastructure (čl. 208. st. 5.).
The third set of changes is visible in location permit procedures and communication with public-law bodies. The procedure for issuing a location permit is initiated electronically through eDozvolu (čl. 156. st. 1.). Public bodies must provide special conditions or connection conditions within 30 days (čl. 170. st. 1.); if they fail to do so, it is deemed that the conditions have been issued, i.e. that connection to the infrastructure is possible (čl. 170. st. 2.). This can accelerate procedures, but it presupposes an orderly and complete conceptual design.
Related to this, notification rules change where there is a larger number of parties. Where more than ten parties participate in the procedure, or the intervention borders more than ten parcels (or is formed from ten or more parcels), parties are invited to inspect the file by a public notice published on the electronic noticeboard (čl. 176. st. 1.). For investors, this means deadlines and procedural rights are increasingly tied to electronic postings.
The fourth set of changes is particularly important for tourism projects and projects along the coast (ZOP). The act regulates planning of hospitality‑tourism uses and camps in more detail and introduces clear restrictions in relation to the coastline. In detached building areas outside settlements designated for hospitality‑tourism use, accommodation buildings must be at least 100 m from the coastline, while in the 25–100 m belt only certain facilities are permitted (open pools, sports, sunbathing areas, promenades, terraces, sanitary facilities), and in the belt up to 25 m it is possible to arrange beaches, parks and greenery (čl. 65. st. 1. t. 2. i 3.).
For camps, the rules are even more precise. In a camp outside a settlement, within 25 m of the coastline it is not possible to plan construction or place modular/prefabricated cabins (mobile homes) and similar interventions, except for arranging beaches and greenery; within 25–100 m, construction and placement of cabins are also prohibited, except for a limited set of facilities and areas for placing camping equipment (čl. 67. st. 2.). In camps within settlements, within 25 m of the coastline it is likewise not possible to plan buildings or place cabins, subject to the listed exceptions (čl. 67. st. 3.). The act expressly states that mobile homes are counted in a camp’s built‑up ratio regardless of whether they are firmly attached to the ground (čl. 67. st. 1. t. 4.), which directly affects a camp’s capacity and “maths”.
Transitional rules for existing camps are particularly important. Camps that on 1. 1. 2026 have a valid decision confirming the fulfilment of conditions may remain in place for up to ten years (čl. 243. st. 4.), but modular/prefabricated cabins and other interventions within the camp in the 25 m belt from the coastline must be removed within five years—i.e. by 1 January 2031 (čl. 243. st. 5.). For camps that remain in place, the act requires an improvement of the state of the area (e.g. a share of greenery and limits on built-up area) within ten years (čl. 243. st. 6.), and for such an improvement as a complex intervention it is necessary to obtain a location permit that determines the siting of all parts of the intervention and the position of mobile homes (čl. 243. st. 7.).
Fifth, the act delivers a clear message on subdivision of tourist accommodation buildings. Hospitality‑tourism buildings intended for accommodation may not be subdivided (čl. 68. st. 1.). An exception exists, but it is strictly limited to 5★ buildings, provided that at least 70% of capacity is hotel accommodation and that the remaining 30% may be subdivided into villas and apartments only after an occupancy permit has been issued for the hotels and accompanying facilities (čl. 68. st. 2.). The facility must operate as a single whole with centralised management and letting; villas and apartments are not intended for residential use; the contract limits owner use to no more than 60 days per year, with additional obligations and sanctions (čl. 68. st. 3.–9.). It is specifically emphasised that subdivision is not permitted on the maritime domain (čl. 68. st. 9.).
In conclusion, the new act changes the game most in three typical situations: where a project depends on amendments to spatial plans, where a project is stuck due to infrastructure, and where it involves tourism and the coast. In such cases, before major investments it is advisable to check the status of the plan and the expected transformation by 1. 1. 2033, the area’s actual level of servicing and whether the statement‑of‑interest mechanism can be used, and for tourism projects to precisely analyse distances from the coastline and the applicable transitional rules.
