Comparison of building permit

procedures in EU countries
J. Branco Pedro OTB & LNEC | Frits Meijer OTB | Henk Visscher OTB

Delft
University of
Technology

Challenge the future

Part I
Introduction

Titel van de presentatie

2 | 28

Building regulatory system

Building regulations
Rules for enforcement

Public actors

central, regional and

Building permit procedure

Application

local authorities,
including their

applicant
designer

Plan approval

departments and
agencies that relate to

Private actors

design auditor
builder

Site Inspections

construction

building surveyor
approved inspector

Completion

Supervision

Titel van de presentatie

3 | 28

Purpose and research questions

Purpose:
Compare the building permit procedures in the
European Union countries
Research questions:
1. What are the main differences and similarities?
2. What are the main types of building permit
procedures?
3. What are the main trends and developments?

Titel van de presentatie

4 | 28

Methodology
The research was conducted as part of a European
comparative research project currently underway at OTB

First phase describe the building regulatory system of

each country, based questionnaires to national experts
and the analysis of major legal documents
Second phase organize information in tables and
compare it in order to identify trends and developments

Titel van de presentatie

6 | 28

Scope
European Union

(27 member states)

Austria, Belgium, Bulgaria, Cyprus, Czech Republic,

Denmark, Estonia, Finland, France, Germany, Greece,
Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg,
Malta, Netherlands, Poland, Portugal, Romania,
Slovakia, Slovenia, Spain, Sweden, United Kingdom
(England and Wales, Northern Ireland and Scotland)

Titel van de presentatie

7 | 28

Part II
Results

Titel van de presentatie

8 | 28

1. Types of procedures
In all EU countries, there is a regular procedure and there are construction works
exempt from permit procedure. Building notice and light procedure also exist in

Regular procedure

Regularization
No information

UK - England & Wales

UK - Scotland

Light procedure

UK- Northern Ireland

Sweden

Spain

Slovenia

Slovakia

Romania

Portugal

Poland

Netherlands

Malta

Germany

Luxembourg

France

Lithuania

Finland

Latvia

Estonia

Italy

Denmark

Ireland

Czech Republic

Greece

Cyprus

Hungary

Building notice

Bulgaria

Exemptions

Belgium

Austria

most countries.

Titel van de presentatie

9 | 28

Obligatory

No information
Bulgaria
Cyprus
Czech Republic
Denmark
Estonia

Germany

Ireland
Italy

Luxembourg
Malta
Netherlands
Poland
Portugal
Romania
Slovakia
Slovenia

Titel van de presentatie

Sweden
UK- Northern Ireland
UK - Scotland
UK - England & Wales

Spain

Lithuania

Latvia

Hungary

Greece

France

Finland

Belgium

Voluntary
Austria

2. Pre-consultation
In almost all EU countries, pre-consultation is voluntarily and takes place frequently.

all situations some situations

10 | 28

3. Planning permit procedure

In approximately half of the EU countries, there is a combined permit procedure for

Combined
No information

Sweden

UK- Northern Ireland

UK - Scotland

UK - England & Wales

Spain

Slovenia

Slovakia

Romania

Portugal

Poland

Netherlands

Luxembourg

Malta

Lithuania

Latvia

Italy

Ireland

Hungary

Greece

Germany

France

Finland

Estonia

Denmark

Czech Republic

Separate

Cyprus

Bulgaria

Belgium

Austria

planning demands and technical requirements.

all situations some situations

Titel van de presentatie

11 | 28

Yes

No

No information

Titel van de presentatie

UK - Scotland
UK - England & Wales

UK- Northern Ireland

Sweden

Spain

Slovenia

Slovakia

Romania

Portugal

Poland

Netherlands

Malta

Luxembourg

Lithuania

Latvia

Italy

Ireland

Hungary

Greece

Germany

France

Finland

Estonia

Denmark

Czech Republic

Cyprus

Bulgaria

Belgium

Austria

4. Phasing
In half of the EU countries, it is not possible to apply for a regular permit in several

phases.

12 | 28

5. Submission demands
In all EU countries, there are statutory submission demands to apply for a building
permit, and general information about building regulations and permit procedures is

UK - England & Wales

UK - Scotland

Slovenia

UK- Northern Ireland

Slovakia

Sweden

Romania

Spain

Portugal

Poland

Netherlands

Germany

Malta

France

Luxembourg

Finland

Lithuania

Estonia

Latvia

Denmark

Italy

Czech Republic

Ireland

Cyprus

Hungary

Bulgaria

Greece

Belgium

Yes

Austria

available through the Internet.

No
No information

Titel van de presentatie

13 | 28

6. Plan approval
In almost
all EU countries,
plan approval
is checked
the compliance
approximately
half of theduring
EU countries
there isit some
involvement
of publicof the
building
with submission, planning and aesthetic demands, as well as with
parties indesign
site inspections

Finland

France

Germany

Italy

Latvia

Lithuania

Luxembourg

Malta

Netherlands

Poland

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

Zoning demands

Aesthetic demands
Technical requirements
No information

UK - Scotland

Estonia

Ireland

Denmark

Hungary

Czech Republic

Greece

Cyprus

Belgium

Submission demands

Austria

Bulgaria

significantly

UK - England & Wales

The degree of involvement of public and private parties in site inspections varies

UK- Northern Ireland

technical
requirements
Private parties
may be involved in site inspections in almost all EU countries

all situations some situations

Titel van de presentatie

14 | 28

7. Beginning of construction works

In almost all EU countries, construction works can start after the building permit

After submission of the

application

No information

UK - England & Wales

UK - Scotland

UK- Northern Ireland

Sweden

Spain

Slovenia

Slovakia

Romania

Portugal

Poland

Netherlands

Malta

Luxembourg

Lithuania

Latvia

Italy

Ireland

Hungary

Greece

Germany

France

After granting of a partial

permit
After granting permit

Finland

Estonia

Denmark

Czech Republic

Cyprus

Bulgaria

Belgium

Austria

has been granted by the building authorities.

all situations some situations

Titel van de presentatie

15 | 28

8. Site inspections
In all EU countries, public building inspectors, from building authorities, have right
of access to building sites and are entitled to carry out inspections.
In all EU countries, if construction works take place without a building permit or do
not comply with the approved design, they can be suspended until the relevant
authority takes a decision regarding demolition or continuation.
In most EU countries, major and minor design changes are possible during
construction work. For major design changes, a formal procedure is required before
proceeding with construction work

Titel van de presentatie

16 | 28

9. Completion
In about half of the EU countries, a final site inspection, conducted by the building
authorities and other authorities, is required. In the other half, the building
authorities rely on declarations by the private bodies that conducted the building

Sweden

Spain

Slovenia

Slovakia

Romania

Portugal

Poland

Netherlands

Malta

Luxembourg

Lithuania

Latvia

Italy

Ireland

Hungary

Greece

Germany

France

UK - England & Wales

Finland

Estonia

Denmark

Czech Republic

UK - Scotland

No information

UK- Northern Ireland

Not required

Cyprus

Required

Bulgaria

Belgium

Austria

work or the site inspections.

all situations some situations

Titel van de presentatie

17 | 28

9. Completion
In almost all EU countries, it is mandatory to obtain a completion certificate or a

For certain types of

construction work

Portugal

Romania

Slovakia

Slovenia

Spain

Sweden

UK- Northern Ireland

UK - Scotland

UK - England & Wales

Poland

Netherlands

Malta

Luxembourg

Latvia

Italy

Only at request of
contractor or owner
No information

Ireland

Lithuania

Hungary

Greece

Germany

Finland

France

Estonia

Denmark

Czech Republic

Cyprus

Bulgaria

Statutory obligatory

Belgium

Austria

use permit after the construction is completed

all situations some situations

Titel van de presentatie

18 | 28

10. Fees
In all EU countries, the applicant has to pay a fee to obtain a building permit.
However, there is a wide range of variety concerning how the value of fee is

Building use

UK - England & Wales

UK - Scotland

UK- Northern Ireland

Spain

Sweden

Slovenia

Slovakia

Romania

Portugal

Poland

Netherlands

Malta

Luxembourg

Ireland

Hungary

Greece

Germany

France

Finland

Estonia

Denmark

Fixed fee
Other criteria

Lithuania

Latvia

Floor area

No information

Czech Republic

Italy

Construction cost

Cyprus

Bulgaria

Belgium

Austria

determined

Titel van de presentatie

19 | 28

11. Procedure times

In the majority of the EU countries there are fixed procedure times in which the

Time is not set

No information

2
or
8

Titel van de presentatie

20 | 28

UK - England & Wales

UK - Scotland

UK- Northern Ireland

Sweden

Spain

25
or
31

Slovenia

Romania

Slovakia

Portugal

Netherlands

Malta

Luxembourg

12
or 12
26

Lithuania

Latvia

Italy

10
12 or
18

Poland

Ireland

Hungary

8
or
12

Greece

Finland

3
or
6

Germany

4
or
8

Estonia

Denmark

Czech Republic

Cyprus

Bulgaria

8
6
to 11 or
24
11

France

Time is set (in weeks)

Belgium

Austria

permit has to be issued

Part III
Conclusions

Titel van de presentatie

21 | 28

1. Main differences and similarities

The general organization of a regular building permit procedure is similar in EU
countries.
There are several differences between EU countries concerning detail aspects
of the building permit procedure:
1. Agreements and information provided during pre-consultation are only
binding to building authorities in some countries.
2. There are different levels of implementation of electronic case handling
of the building permit.

Titel van de presentatie

22 | 28

1. Main differences and similarities

3. Permit procedures for planning demands and technical requirements
may be separated or combined.

4. Phasing the permit procedure is only statutory available in some

countries; different strategies are used to divide the building permit
procedure in phases.
5. Different criteria are used to allow an early start of construction works.

6. The value of the building permit fee is determined by different criteria.

7. When maximum procedure times are not met by the building
authorities different consequences can result.
8. A completion certificate or a use permit may not be required when the
construction is finished.

Titel van de presentatie

23 | 28

2. Main types of building permit

procedures?
1. There is one main type of building permit procedure.

2. No substantial differences were found in continental

Europe countries.
3. The United Kingdom countries, and particularly England
& Wales, are those that present more deviations from
the common pattern.

Titel van de presentatie

24 | 28

2. Main types of building permit

procedures?
4. In the United Kingdom countries, the following distinctive characteristics
were identified:

There is a specific type approval procedure.

Planning permit and building permit are separated, and there is also the
possibility to phase the building permit procedure.

Full electronic case handling of the building permit is already available.

The applicant can choose to have plan approval and site inspections conducted
by either building authorities or approved inspectors.

Construction works may start soon after submission of the application, not
having to wait for plan approval.

Maximum procedure times are shorter than the average.

All these characteristics have in common the aim of reducing the burden of
administrative aspects, while ensuring good levels of compliance
Titel van de presentatie

25 | 28

3. Trends and developments

In the last 10 to 15 years, the dominant trends in the
building permit procedure were:
1. A decrease in the types of construction works
submitted to building authorities control during plan
approval,
2. A reduction of building permit maximum procedure
times.
Altogether, there is a movement towards
simpler and faster building permit procedures

Titel van de presentatie

26 | 28

Utility and continuation

The results can be useful to:
situate the system of each country in the European
panorama
guide strategic choices on possible improvements in
each country

Comparative studies should be carried out focusing on

performance of each type of system in terms of adequacy,
efficiency and effectiveness

Titel van de presentatie

27 | 28

Thank you for your attention

Thanks are extended to the national experts of the EU countries that filled in
the questionnaire on building regulations.

Delft
University of
Technology

Challenge the future