Arbitrary & building ID: new extension, new tasks for owners, engineers

Big Breath to Property Owners with the New Amendment

The new amendment of the Ministry of Environment and Energy gives a big breath to thousands of property owners, extending critical deadlines for the Electronic Building Identity, the settlement of unauthorized buildings and building permits that were cancelled due to the "bonus" of the NOC.

These regulations prevent the "freeze" of transfers and parental transfers that threatened the real estate market, giving time to settle pending issues that had become a bureaucratic deadlock.

However, owners should not rest, but should immediately close the pending issues they have and register their properties correctly in the E9 in the land registry and with the PPC, so that they can transfer them, upgrade them in terms of energy and generally put them to good use.

What should owners do?

♦ Check directly with your engineer if your property has arbitrary actions and falls into the categories that received an extension and find out about the discounts and settlement on the fines given by the state.

♦ Start the process of gathering supporting documents now, as the issuance of an Electronic Building Identification Card takes time.

♦ Utilize the e-Permits system to reissue permits that were cancelled due to NOC before the 2026 expiration date.

What are the new deadlines for properties?

Under the latest amendment by the Ministry of Environment, the following are regulated:

♦ Electronic Building Identification (Cat. 1), by 1 February 2028

♦ Settlement of Vacant Buildings (pre-2011), by 31 March 2028

♦ Suspension of Fines for Fines for Building Fines (until 31.20.2011) NOC permits, until 31 December 2026

♦ Re-issuance of permits via e-Permits, until 31 December 2026

- Until when can I settle an arbitrary building built before 2011?

The deadline to regularize unauthorized structures and changes of use built before July 2011 is officially extended until March 31, 2028.

Attention! The extension applies ONLY to Category 1, 2, 3 and 4 unauthorized structures, which involve violations prior to 2011 and minor or medium deviations from the permit. Note that, for arbitrary buildings built before 1983, the existence of a building permit is not a prerequisite

What should owners do?

They should immediately contact an engineer in order to take the following steps:

1. Check the legality of the property by a civil engineer.

2. Comparison of the approved building permit drawings with the actual situation.

3on Categorisation of the infringement (1-4) and calculation of the fine.

4on Submission of a declaration of unauthorized use via the TEE system.

5on Payment of the fine & penalty (one-off or in instalments).

6on Final affiliation and update of the Building Identity.

Note that in older properties where no file is available, a new topographic survey or structural assessment by a qualified surveyor may be required.

What is the new deadline for the Electronic Building Identity?

For buildings of major importance (Category 1), such as public buildings, schools and hospitals, the new deadline for submitting the Electronic Building Identity has been set for 1 February 2028.

- Is there a risk of a fine if I don't meet the new deadlines?

Yes, failure to comply after the new deadlines will result in fines of up to 10% of the property's assessed value.

The penalties apply to both private and public buildings.

Failure to issue the Identity Card makes any transfer of property, such as sale, donation or parental transfer, impossible.

Where is the Electronic Building Identity Card necessary?

The issuance of an Electronic Building Identity Card is required by law (ed: Law 4495/2017):

1. For buildings or parts of buildings used for petrol stations or car washes as well as for all kinds of garages (ed: car workshops).

2. For tourist accommodation with a surface area of more than 300 m².

3. For private and public pre-school, primary, secondary and higher education establishments.

4. For healthcare buildings (hospitals, medical centres, clinics, rural and regional dispensaries, mental health centres, health service centres). This category also includes nurseries, crèches, day nurseries, boarding schools, retirement homes, institutions for the chronically ill and institutions for the disabled.

5. For public buildings: theatres, cinemas, assembly halls for social, economic, cultural and religious events, conference centres and exhibition buildings. This category also includes: cultural facilities (libraries, museums, museums, exhibition halls), sports facilities (indoor gymnasiums, stadiums with grandstands and indoor ancillary areas, football stadiums, Olympic sports facilities).

6. For buildings belonging to the State, local authorities, legal persons under public law, as well as for those housing public and local authorities' services.

7. For detention centres and specialised detention centres for young people.

-What are the supporting documents for the Electronic Building Identity Card?

♦ The stub of the building permit of the building within which the divided property is located, with its revisions.

♦ The plans accompanying the building permit, and the accessibility study for disabled persons and handicapped persons, if required.

♦ The energy performance certificate of the divided property.

♦ The construction inspection certificate, if issued.

♦ The declarations of compliance with laws suspending the imposition of penalties on unauthorized buildings.

♦ The floor plans, which show the divided property in its actual condition.

♦ The structural vulnerability report or the technical report of structural inspection, accompanying an application for inclusion in the relevant law, or the structural adequacy study if required.

♦ The millimeter table and the cost allocation study, if available.

♦ If the building permit and its accompanying data cannot be found in the records of the planning office, a certificate of loss from the competent Building Department shall be submitted instead.

What applies to building permits cancelled due to the NOC?

Of particular relevance is the provision on the suspension of fines and prohibitions on properties whose building permits have been cancelled. It concerns building permits using NOC incentives, which were legally issued, but are annulled following decisions of the Council of State and the buildings are declared unauthorised and demolished. For these cases, the amendment suspends the sanctions of fines and demolition of the buildings, referring to the possibility given under the decision of the State Council and a relevant Decree passed after the Court's preliminary legislative approval, to implement with environmental equivalent and work commencement regulations.

This suspension is valid until 31 December 2026, giving the necessary leeway for reissuing permits.

Owners are invited to make use of the digital e-Permits system to legalise their constructions without the threat of penalties.