Polish Building Law Changes 2025–2026: What Architects Need to Know
Digital permit submissions, tighter technical standards, a simplified path for legalising old unauthorised buildings. The regulatory changes you can feel in daily practice, plus the ones still coming.
Polish building law changes less often than architects would like, but when it changes, it changes wholesale. The 2024–2026 period brought several amendments you can feel in everyday office work, from how applications get filed to what a construction log entry must contain. I’ve gathered them in one place, with the emphasis on what each change means in practice.
In short
- e-Budownictwo: since 2024 applications for projects requiring an environmental decision are filed electronically only, since 2025 further types of proceedings too; every signing architect needs a qualified electronic signature or a trusted profile (Profil Zaufany).
- The Technical Conditions tightened three areas: thermal performance and the NZEB standard (since 2021), bicycle parking, accessibility.
- Unauthorised structures older than 20 years: simplified legalisation (2023 amendment, fully in force since 2024) and a new, repeatable category of commissions for offices.
- To watch in 2026: the spatial planning reform (ZPI), transposition of the EPBD directive around 2026/2027, further stages of digital filing from GUNB.
e-Budownictwo: the end of trips to the permitting office
The biggest systemic shift is the expansion of the e-Budownictwo portal (e-budownictwo.gunb.gov.pl). Since 2024, building permit applications for projects requiring an environmental decision must be filed electronically only, and in 2025 the obligation spread to further types of proceedings. The direction is unambiguous, and there will be no going back.
What this changes in the office
What does this change in the office?
- Every architect who signs project documentation needs a qualified electronic signature or a trusted profile (Profil Zaufany). If your office hasn’t sorted this yet, that’s a backlog.
- Application status is tracked online, which retires the old ritual of phoning the architecture department to ask whether “anything is known yet”.
- Supplements and responses to official notices go out without printouts, and with three binders of project documentation that’s a difference you feel physically.
From practice: sort out your office’s PDF versioning rules right away. The authority sees exactly what you uploaded, and withdrawing a wrongly attached file tends to be harder than it ever was on paper.
Technical conditions: what got stricter
The Technical Conditions regulation (WT) is updated in stages, and it’s easy to miss the moment a given change takes effect. Three areas carry the most weight in current projects.
Thermal performance and the NZEB standard
Since 2021, stricter U-values apply to envelope components, and new buildings plus deep renovations must meet the nearly zero-energy standard. In practice that means thicker assemblies, more careful thermal bridge detailing, and thinking about the heat source at concept stage rather than at the end of the permit design.
Bicycles instead of (some) parking
The WT amendment expanded mandatory bicycle parking. Multi-family and public buildings now need covered stands and charging points for electric bikes. Sounds minor? On a tight downtown plot it can rearrange the entire ground floor.
Accessibility
Accessibility requirements were tightened in line with the European Accessibility Act. Formally this concerns mainly public buildings, but the requirements are gradually reaching multi-family housing too. In my view, designing to the bare minimum has stopped making sense, because the minimum will rise again within two years.
Simplified legalisation of old unauthorised buildings
The 2023 amendment, fully in force since 2024, simplified the legalisation of unauthorised structures older than 20 years. For design offices this created a new, repeatable category of commissions: expert surveys and legalisation documentation. Three things are required:
- a technical expert opinion confirming the structure is safe,
- a geodetic as-built survey,
- descriptive documentation.
A single commission of this kind won’t keep an office running. But legalisation applications keep growing in number, and the client whose grandfather’s barn you legalise smoothly comes back later with an extension project. It pays to have a ready price list and procedure instead of quoting every case from scratch.
Author’s supervision: “visited the site” no longer counts
The updated regulations spell out the architect’s duties during author’s supervision. Construction log entries must document the specific technical decisions taken during a visit, not the mere fact of showing up. From a professional liability standpoint this matters a great deal, because in any dispute the log is the first piece of evidence both sides reach for.
A practical tip: prepare an office template for supervision entries with five fields:
- date,
- scope of inspection,
- deviations found,
- decisions taken,
- recommendations with deadlines.
It takes five minutes per visit and protects you when, two years later, someone has to reconstruct who agreed to what.
Transitional provisions, where disputes are born
With every amendment, the most confusion comes not from the new requirements but from the transitional provisions. A project filed before a change takes effect is usually assessed under the old rules, but “filed” gets interpreted in more than one way, and with suspended or supplemented proceedings the line blurs. I’ve seen a dispute over whether an application supplemented after an amendment already falls under the new technical conditions. It cost the investor three months.
The dates from this article in one place:
| Change | When |
|---|---|
| Stricter U-values and the NZEB standard for new buildings | since 2021 |
| Simplified legalisation of unauthorised structures older than 20 years (2023 amendment) | fully since 2024 |
| Applications for projects requiring an environmental decision filed only via e-Budownictwo | since 2024 |
| Electronic filing mandatory for further types of proceedings | since 2025 |
| Transposition of the recast EPBD (2024) into Polish law | around 2026/2027 |
So for projects straddling a change date, do two things.
- Note in the project documentation which legal state it was prepared under, with the exact date. One sentence in the technical description, and it ends arguments before they start.
- For longer proceedings, read the transitional provisions of that specific amendment instead of assuming the general rule. The ISAP legal database publishes consolidated texts with effective dates, so the check takes fifteen minutes.
What to watch in 2026
Three legislative processes are under way, and each will touch design offices.
- The spatial planning reform from the 2023 act changes how zoning decisions (WZ) are issued and introduces integrated investment plans (ZPI). Municipalities are implementing it at very different speeds, so before starting any new project, check the planning status of that specific municipality rather than assuming it works “like everywhere else”.
- The transposition of the recast EPBD directive from 2024 is due in Polish law around 2026/2027 and will raise energy requirements once again.
- GUNB has also announced further stages of mandatory digital filing in e-Budownictwo.
Keeping track of all this doesn’t have to eat your time. The newsletters from IARP (Chamber of Architects) and PIIB (Chamber of Civil Engineers) review regulatory changes on a regular basis. Reading two emails a month is enough to make sure no amendment catches you mid-project.
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