Two regulations were published together in the Official Gazette of 5 August 2026. Their names resemble each other; their jobs differ. The press covered them as a single measure, and one date stood out: 1 September 2027.
That date is correct, but on its own it misleads. The transitional article of the regulation splits the timetable into four stages. When it begins, and for whom, depends on the population of the municipality where the building sits, on the total construction area, and on how the building is used.
Two regulations, one process
The first regulation — Regulation on the Digital Preparation of Architectural and Engineering Projects — governs how the project is prepared. The format it is drawn in, the way files are named, and the standard the three-dimensional model is built to are all set out here. It takes effect on 1 September 2027.
The second regulation — Regulation on the Electronic Submission and Management of Architectural and Engineering Projects — governs how the prepared project reaches the authorities. Upload, review, notice of deficiencies, revision and approval will all run through the Electronic Project Management System. It takes effect on 1 September 2028.
One defines the language of the project, the other its route of delivery. They share the same scope, and neither works without the other.
Who is in scope, who is not
The regulations cover new buildings in areas that have an implementation development plan. Three groups are expressly left out.
- Detached buildings of at most two storeys excluding the basement, with a total construction area not exceeding 200m²
- Agricultural and livestock buildings and facilities that are not integrated plants
- Buildings in areas without an implementation development plan
The exemption requires both conditions at once. A detached building of no more than two storeys but over 200m² is in scope; so is a three-storey building under 200m². The basement does not count towards the storey number.
The documents covered are the architectural project, the structural project, the electrical and installation projects, and their drawings and calculations.
The timetable does not run the same for everyone
The transitional article stages the two main obligations separately. First, the effective dates of the two regulations themselves:
| Regulation | In force from |
|---|---|
| Digital preparation of projects | 1 September 2027 |
| Electronic submission and management of projects | 1 September 2028 |
Then the staging of the provisions on PDF/A and drawing layout:
| Building | Start |
|---|---|
| Buildings over 5,000m² in municipalities of more than 600,000 people, in provinces of more than 2 million | 1 September 2027 |
| All other buildings | 1 March 2029 |
Then the staging of IFC submission of the three-dimensional model:
| Building | Start |
|---|---|
| Province over 2 million, municipality over 600,000 — buildings over 10,000m² | 1 September 2029 |
| Province over 2 million, municipality over 400,000 — buildings over 10,000m² | 1 September 2030 |
| Province over 1 million, municipality over 300,000 — buildings over 10,000m² | 1 September 2031 |
| Buildings not listed above | 1 September 2032 |
There is also a filter by building type. The regulation does not apply to buildings other than housing and mixed retail-and-housing until 1 September 2033. Offices, industrial buildings, schools and healthcare buildings carry on under the current procedure until then.
There are also the jobs that filed before the transition dates. The regulation leaves out buildings for which a building permit application was made before the start date of their own stage, and works for which public bodies have taken a tender decision or set a tender date. The application date decides which procedure applies.
Read together, the tables single out one group. The developer producing housing over 5,000m² in a major city is the only group whose obligation begins in 2027. The same developer will also be the first into IFC submission in 2029. Everyone else has between two and six years of preparation ahead.
What changes in how the project is prepared
Two-dimensional drawings and reports will be submitted in PDF/A. This is not the familiar PDF export; an archivable, vector-based version is required. The PDF of a document printed on paper and then scanned is not accepted.
The three-dimensional building model will be built on BIM and set up to TS EN ISO 19650-1 and 19650-2. The submission format is IFC. Each discipline prepares its own model separately.
The provision that will create the most work sits elsewhere. The model and the two-dimensional drawings produced from it must agree with each other. Plan and section drifting apart in the last round of revisions is something every architect knows from practice; that drift now becomes visible at submission.
The model is not judged on geometry alone. Mandatory IFC classes, mandatory project attributes and a level of model development are defined; a quality control form documenting the integrity of the model is also completed. A model that looks right is not enough; a model whose data is complete is what is asked for.
File order, project code, sheet
The regulation enters the area where office habits are most entrenched: file names.
- A project code will be created for each project in line with the annex to the regulation
- File naming is not free; it follows the rules defined in the annex
- Spaces will be numbered by storey, function and sequence number
- In CAD drawings, layer names, symbols, line types and text layout are standardised
- Sheets will be A4 or its multiples, and each sheet will be submitted as a separate file
The annexes are gathered under nine headings:
| Annex | Content |
|---|---|
| EK-1 | Rules for creating the project code |
| EK-2 | Discipline and sub-discipline lists, file codes |
| EK-3 | Space numbering and naming |
| EK-4 | CAD drawing rules — layer, symbol, line type, text |
| EK-5 | Space naming, IFC classes and category list |
| EK-6 | Attributes and properties of mandatory IFC classes |
| EK-7 | Mandatory project attributes |
| EK-8 | Level of model development |
| EK-9 | Model quality control forms |
All the annexes were published in the Official Gazette as a single file: Annexes to the Regulation on the Digital Preparation of Architectural and Engineering Projects (PDF). The second regulation, the one governing electronic submission, has no annexes.
Submission through e-PYS
The Electronic Project Management System will be run by the Ministry. Uploading the project, its review by the relevant authority, the notice of deficiencies, the submission of revisions and the granting of approval will all move on the same platform. Deficiency correspondence, which until now travelled on paper and by word of mouth, goes on the record.
Two routes are defined for submission. If the project author holds a secure electronic signature, digital submission of the files is enough and no printed copy is required. Without the signature, a printed copy is handed in alongside the digital files and the two must be identical. The second route means doing the same work twice.
The project author is responsible for the accuracy of the uploaded files. Uploading to the system stands in place of assuming responsibility.
What it means for the investor
The housing investor stands on the first step of the timetable. In a housing project over 5,000m² in a major city, the submission format changes from 2027, and from 2029 the model itself is submitted. The span between those two dates is of the same order as the time a housing project takes from land purchase to permit.
It shows up in practice in three places.
The first is the choice of author. Whether the project team works with BIM has been a matter of preference until now. On jobs within scope it is becoming a question of qualification.
The second is contracts and tender files. The submission format, the level of model development and responsibility for quality control need to be written into the contract. A project contract signed today may describe work that runs until the date the obligation begins.
The third is permit duration. Notifying deficiencies through the system makes the process traceable. In a traceable process, where the delay sits also becomes visible.
The regulation does not bring a new understanding of design. It describes the form in which the project reaches the authorities. But when the form changes, the difference between the party used to producing it and the party that is not becomes visible at the permit desk.
We looked at what this same measure means for architectural practice in an earlier article: From Digital Design to Digital Delivery: A New Era in Submitting Architectural Projects to the Authorities.
Frequently asked questions
Does it start for everyone on 1 September 2027?
No. On that date it starts only for buildings over 5,000m² in municipalities of more than 600,000 people, in provinces of more than 2 million. For other buildings it does not apply until 1 March 2029.
What is e-PYS?
The Electronic Project Management System. A platform run by the Ministry on which project submission, review, revision and approval are carried out. The relevant regulation takes effect on 1 September 2028.
Is an ordinary PDF enough?
No. Two-dimensional drawings and other documents are required in PDF/A. The PDF of a scanned paper document is not accepted.
Is BIM mandatory?
It is mandatory on jobs within scope, but staged. IFC submission begins on 1 September 2029 at the earliest and widens through to 2032.
Is a detached building under 200m² in scope?
Detached buildings of at most two storeys excluding the basement, with a total construction area not exceeding 200m², are out of scope. Both conditions are required together.
What if I do not have an electronic signature?
You need to hand in a printed copy alongside the digital files, and the two must be identical. With a secure electronic signature, no printed copy is required.
Is an office building in scope?
The regulation does not apply to buildings other than housing and mixed retail-and-housing until 1 September 2033.