In today's article from the series "Tuesday Mornings for the Construction Industry," we take a closer look at the latest changes to the planning reform. On April 15, 2026, the Council of Ministers submitted to the Sejm a government bill amending the Spatial Planning and Development Act and certain other acts (no. UD316, hereinafter referred to as the "Government Bill").
The Government Bill includes not only changes to the Spatial Planning and Development Act itself, but also to the regulations introducing the 2023 reform. There are many changes, so this article will focus on the changes that, from a practical point of view, may have the greatest impact on the situation of investors.
Extension of deadlines for the adoption of general plans
Perhaps the most important change concerns the postponement of the expiry date of studies on conditions and directions of spatial development, and in practice also the deadline for adopting general plans, until August 31, 2026.
From the investors' point of view, this means, above all, additional time for municipalities to organize their planning documents and a lower risk of paralysis of some investment processes in the coming months.
The bill also extends the deadline for granting consent to change the designation of agricultural and forest land from 60 to 120 days, with the absence of a decision constituting tacit consent. This could significantly improve the efficiency of procedures where, until now, delays in approvals have been a problem.
The validity period of the Act of 5 July 2018 on facilitating the preparation and implementation of housing investments and accompanying investments has also been extended and is to expire on 1 September 2026.
In ZPI it is easier for investors, but also for municipalities
The Government Bill contains provisions according to which the investor will be able to, as part of a supplementary investment, also construct facilities for the municipality that do not directly serve the main investment, e.g. a road, a school or green areas.
At the same time, it was clarified that the Integrated Development Plan (IDP) may cover not only the main investment area and the supplementary investment area, but also other areas. However, if the supplementary investment can be implemented based on the applicable local plan, it will not be necessary to include it in the IDP itself. The government's proposal also introduces the possibility of concluding a separate agreement to cover the costs of preparing the IDP before signing the actual urban planning agreement. In practice, this streamlines the financing of the process at an earlier stage.
The municipal council will be able to decide that the investor should submit an urban and architectural concept with visualizations to the application for ZPI approval, instead of a full draft plan. This could expedite the initial stage of discussions and reduce costs by reducing the required documentation. Furthermore, under the proposed regulations, the municipal council will be given the right to withdraw consent to proceed with ZPI development until the urban planning agreement is signed.
The Government Bill also introduced deadlines to speed up the processing of investment plans: 2 months for the municipal council to adopt the ZPI from the moment of submitting the bill and 2 months for administrative courts to consider complaints: to the provincial administrative court and a cassation appeal to the Supreme Administrative Court.
Development conditions: a significant change for part of the market
The government's proposal assumes that only the entity holding the right to dispose of the property for construction purposes will receive a decision on development conditions. The application will be accompanied by a relevant declaration, submitted under penalty of perjury.
This is a clear departure from the previous model, in which even entities without title to the land could apply for a development permit. For the market, this means limiting the practice of "securing" properties with a development permit before the land titles are fully settled.
As a result, some investors will need to rethink their land acquisition schedule, due diligence, and transaction structuring. This change may have greater practical significance than many purely procedural adjustments.
In summary , the proposed changes don't revolutionize the planning reform, but they do significantly adjust its impact on the investment process. Investors will be most concerned about three issues: the actual "unlocking" of the ZPI, the impact of the postponement of the deadline for general plans on local planning processes, and the effects of the new requirement for property rights when applying for a development consent.
This article is for informational purposes only and does not constitute legal advice.
Legal status as of April 20, 2026.
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