In The Debrief, our Practice Leaders across CEE share updates on recent and upcoming legislation, consider the impact of recent court decisions, showcase landmark projects, and keep our readers apprised of the latest developments impacting their respective practice areas.
Albota Law Firm Partner Oana Albota reports that, on August 25, “a single law replaced three decades of urban planning regulations.” She explains that “the Code on Land Use, Urban Planning, and Construction – Law No. 169/2026 – has fully repealed Law No. 50/1991 and Law No. 350/2001 and is already in effect, without implementing regulations.” While “public discussion has focused on the shortened deadlines and digitization,” Albota notes that “less attention has been paid to the changes that take immediate effect on ongoing transactions and projects.”
Albota highlights five key changes for developers. First, “an annulled Building Permit no longer automatically means demolition.” She explains that “the risk of litigation has always been the hardest to quantify: an annulled Building Permit opened the way to the demolition of the works, regardless of the quality of their execution. The code offers an alternative.”
Second, “the Urban Planning Certificate becomes a condition of validity.” According to Albota, “demergers carried out in breach of urban planning regulations remained, for a long time, without civil-law consequences: under Law No. 350/2001, the certificate was mandatory only for the division of land within the built-up area into at least three plots for construction purposes, and a breach of this requirement resulted in the annulment of the demerger deed. The code shifts the applicable sanction.”
Third, the Detailed Urban Plan (PUD) moves “from a detailed planning tool to a derogation tool.” Albota notes that “until now, any amendment to the urban planning regulations applicable to a small-scale project had to go through a Zonal Urban Plan (PUZ): under Law No. 350/2001, the PUD could not amend the provisions of the General Urban Plan or of a PUZ. The code redistributes these roles.”
Fourth, “the project is transferred together with the documentation.” Albota explains that “the sale of a project currently in the approval process raised a question that Law No. 50/1991 only partially addressed: what happens to the urban planning certificate and the approvals obtained if the building permit has not yet been issued? The code settles the matter.”
Fifth, there is a “one-year window to regularize existing unauthorized constructions.” Albota notes that “the code introduces a regularization permit for constructions (Art. 301) carried out without a building permit or in breach of an issued permit,” and that “for a transitional period of up to one year from the code’s entry into force, (i.e., until August 25, 2027) this mechanism may also be used for categories of constructions that would not ordinarily qualify for regularization.” She cautions that “regularization is, however, subject to a prior compliance review assessing whether the construction meets the applicable urban planning regulations and fundamental construction quality requirements.”
Wolf Theiss Associate Marta Wasil reports that “the substantive part of the Act on Artificial Intelligence Systems came into force on August 11, establishing a national market surveillance authority for AI.” She notes this is “directly relevant to employment law, since AI systems used for recruitment and workforce management are classified as high-risk under the EU AI Act.”
Wasil adds that “the legislation implementing the Women on Boards Directive has also been in force since August 18,” and “requires listed companies to aim for 33% representation of the underrepresented sex across their management and supervisory boards, to adopt a gender-balance policy and to apply transparent selection criteria when appointing candidates.” She notes that “the President has referred the legislation to the Constitutional Tribunal for ex post review, but this does not suspend its application.”
Finally, Wasil reports that “the rules governing the legal employment of Colombian, Venezuelan, and Georgian nationals have become more restrictive as of August 22.” She explains that “these individuals can no longer work in Poland solely on the basis of a work permit while staying under the visa-free regime and must also hold a visa or another residence permit that authorizes them to work in Poland.”
“Building a nuclear power plant is one of the most complex infrastructure projects,” says Greenberg Traurig Senior Associate Katarzyna Stochnialek. In Poland, she explains, “the process is governed mainly by the Construction Law of July 7, 1994, the Act of June 29, 2011 on the Preparation and Implementation of Investments in Nuclear Power Facilities and Related Investments (Special Nuclear Act), and the Atomic Energy Act of November 29, 2000.”
According to Stochnialek, “an amendment to the Special Nuclear Act entered into force on September 3, 2026,” introducing “measures to streamline the preparation and implementation of nuclear power projects while maintaining high standards of nuclear and construction safety.” She explains that “one of the key changes is the introduction of a specific type of building permit for preliminary construction work at nuclear power facilities,” meaning that “construction may begin before the complete design documentation for the entire project has been prepared.” This matters because “the ability to carry out certain works separately from the main construction permit is particularly important for nuclear power plants,” as “these projects require highly complex and detailed documentation, which takes considerable time to prepare.”
Stochnialek adds that “the new rules are intended to make the investment process more flexible and efficient,” and that “according to the explanatory memorandum to the amendment, the changes could shorten the overall investment and construction process by up to two years without compromising high safety standards.”
Wasil reports that “one of the most notable” developments in Polish employment law in August 2026 “was the publication of an amendment to the Labor Code concerning workplace bullying (mobbing), due to come into force on November 5, 2026.” She explains that “the amendment simplifies the statutory definition of mobbing and obliges employers to actively prevent it,” and “requires employers with at least 10 employees to consult with employee representatives and adopt internal anti-mobbing procedures within six months of the new provisions coming into force.” Wasil adds that “the amendment also introduces statutory minimum compensation for mobbing, set at six times the minimum wage.”
Peterka & Partners Partner Adela Krbcova reports that “the Czech Government submitted two highly anticipated proposals to the Chamber of Deputies: an amendment to the Labor Code to implement the EU Pay Transparency Directive and a proposal for a brand-new Platform Work Act.” She notes that “the package extends well beyond pay transparency and the platform economy.”
According to Krbcova, “for digital labor platforms, the new act would introduce a presumption of employment and detailed rules for algorithmic management,” including “transparency, restrictions on personal data processing, human oversight, and the right to review automated decisions.” She adds that “there would also be new registration, reporting, whistleblowing, and anti-retaliation obligations,” and that “the definition of dependent work and its substantial conditions would be revised, extending beyond platform work,” a change that “has sparked significant controversy among various stakeholders in the labor market.”
“Sanctions for illegal and unreported work are expected to be strengthened, and the proposal even expands liability within supply chains where a customer knew, or should have known with due care, of the infringement,” Krbcova adds, also noting that “the first phase of the Single Collection Point will also be launched by transferring the enforcement of certain social security receivables to the tax authorities from 2028.” Both acts are expected to take effect on January 1, 2027, with various deferred exceptions.
“At the beginning of September 2026, the negotiations between the future shareholders of the joint venture company, which will be established in the near future in Serbia, and will be responsible for the development and construction of a new gas power plant near Nis, with a planned capacity of up to 500 megawatts and which is planned to be built by 2030, were completed,” JPM & Partners Senior Partner Jelena Gazivoda reports. She explains that “the shareholders’ agreement of Elektroprivreda Srbija, Srbijagas and SOCAR of Azerbaijan was negotiated with the representatives of the Ministry of Mining and Energy of the Republic of Serbia,” and “its conclusion and the establishment of the joint venture company is expected in the near future.”
Gazivoda also highlights “the commissioning of the Cibuk 2 Wind Farm, with an installed capacity of 154 megawatts, which was built right next to the Cibuk 1 Wind Farm, with an installed capacity of 158 megawatts.” She notes that “with the commissioning of the Cibuk 2 Wind Farm, the largest wind energy hub in the Western Balkans region was created and became operational, with a total installed power of 312 megawatts, which ensures the supply of electricity for 178,800 households.” According to Gazivoda, “this significant project demonstrated the relevance of the wind potential in Serbia and the readiness of the renewable energy market to meet the challenges of such a complex and demanding project.”
CMS Sofia Managing Partner Kostadin Sirleshtov reports that “Tesla is set to enter the Bulgarian energy sector with three major energy storage projects in Stara Zagora, Tvarditsa, and Veliko Tarnovo, as announced by the former minister of energy Delyan Dobrev.” According to him, “the Veliko Tarnovo BESS facility will be among the largest energy storage projects in Europe.”
Sirleshtov reports that “August 2026 saw the completion of several new BESS projects of VVV Next Gen Storage – a new investor in Bulgaria – namely Dalgopol Storage Park (10 megawatts/40 megawatt-hours), Trastikovo Storage System 1 (10 megawatts/40 megawatt-hours), and Trastikovo Storage System 2 (10 megawatts/40 megawatt-hours).”
Redcliffe Partners Partner Denys Medvediev reports that “the AMCU has returned to a track of fining companies for health-related claims on products that are not medicines,” and that “the recent decisions make the enforcement architecture visible.”
According to Medvediev, “the targets are familiar: a dietary supplement marketed as a ‘cough syrup’ with expectorant and mucolytic action; another supplement positioned as a hepatoprotector; and a mineral water labelled ‘medicinal’ with indications from liver disease to obesity,” with “the highest fine, imposed on the hepatoprotector importer, reaching approximately EUR 20,500,” while “further decisions of comparable scale should be expected.”
Medvediev explains that “each decision rests on three pillars: a Ministry of Health opinion confirming that the language associates the product with therapeutic properties; a review of the seller’s ‘supporting’ studies, discounted because they cover individual ingredients rather than the finished product or fail modern evidence-based standards; and a consumer survey establishing that the claims influence purchasing decisions.” He adds that “the reference point for competitive harm is then chosen with care: not other products in the seller’s own category, but manufacturers of registered medicines with comparable claimed action.”
Medvediev warns that “any business near the medicine boundary, whether in supplements, cosmetics, FMCG, food additives or functional beverages, is exposed the moment its packaging or website borrows the vocabulary of therapy.” He notes that “the remedy is a fine plus an injunction to stop the claims, which forces a re-launch of the product’s positioning,” and that “substantiation must be for the finished product as sold, not for its individual components.” As he puts it, “individual amounts may still look modest, but the AMCU has built a template it can apply repeatedly across any sector that speaks to health-conscious consumers.”
“Following an administrative decision issued by the General Directorate for the Control of Economic Transactions (GD-DEOS) of the Independent Authority for Public Revenue (IAPR), significant controversy has emerged in relation to the Central Register of Beneficial Owners (the UBO Register),” Drakopoulos Senior Associate Eirini Galanou reports. According to her, “this decision has unsettled the compliance landscape for Greek companies.” Galanou explains that “the case involved a family-owned Societe Anonyme in which one shareholder held 96% of the company’s share capital, while a relative held the remaining 4%.” While “the minority shareholder held no special rights and exercised no control over the company’s management,” the “GD-DEOS imposed a EUR 20,000 fine on the company for failing to register the minority shareholder in the UBO Register.”
According to Galanou, the approach has drawn criticism on several grounds: it “effectively equates the UBO Register with a shareholder registry, which was not the legislation’s intended purpose;” it “conflicts with EU Directive 2015/849 and FATF Recommendation 24 standards on the identification of beneficial owners;” and “no other EU Member State requires the registration of shareholders below the 25% threshold in the absence of control by other means.”
Galanou stresses that “the decision has created a compliance dilemma for companies that adhered to the prevailing interpretation,” since “companies that did not register minority shareholders with no actual control risk being found non-compliant,” while “amending existing filings to include these shareholders may trigger penalties for the earlier omission.” She reports that the administration is being urged by stakeholders to take three key steps: to “issue a clear circular that distinguishes between the concepts of ‘beneficial owner’ and ‘mere shareholder’;” to “provide a transitional compliance period during which companies can update their filings without risk of penalty;” and to “review fines already imposed for the non-registration of minority shareholders who have no actual control.”
AECO Law Partner Cagri Cetinkaya reports that, “on September 4, 2026, the Central Bank of the Republic of Turkiye amended the Communique on the Information Systems of Payment and Electronic Money Institutions and the Data Sharing Services of Payment Service Providers in the Field of Payment Services.” He explains that “the amendments update the rules governing remote customer identification, expressly incorporate the verification of customers’ biometric data into the remote identification process, and introduce more detailed requirements for the verification of identity documents.”
Cetinkaya also reports that, “on August 27, 2026, the Turkish Data Protection Authority (Turkish DPA) published a public announcement clarifying its Guideline Decision dated April 29, 2026 on the processing of biometric data for employee attendance monitoring,” following “requests for clarification from data controllers in different sectors after the Guideline Decision was published.” He notes that “the Turkish DPA reiterated that data such as fingerprints and palm scans constitute biometric data when processed through technical means that enable the unique identification or authentication of an individual,” and that “converting such data into mathematical templates or codes does not remove their biometric nature.”
“The details of the reform of the National Labor Inspectorate are beginning to emerge,” Wasil reports, noting that “the Chief Labor Inspector has issued the first individual interpretations regarding the classification of civil-law contracts and B2B arrangements.” According to Wasil, “factors supporting the civil-law nature of the relationship included the contractor’s genuine ability to refuse an assignment, the absence of a guarantee of continuity of cooperation, contractual liability including contractual penalties, the possibility of appointing a substitute, and the contractor’s assumption of economic risk.” Conversely, she notes, “so-called availability windows, working-time records, and the use of company equipment were not deemed to be indicative of an employment relationship.”
Gazivoda reports that “the end of August and the beginning of September 2026 marked the continuation of negotiations regarding the purchase of the shares of the majority owner of NIS, the Russian Gazprom Neft, by the Hungarian MOL.” According to her, “OFAC’s special license to NIS has been extended to September 30, leaving a slightly longer deadline for negotiations to be completed than in previous extensions,” which “was interpreted as a signal that the negotiations would result in success.” However, Gazivoda cautions that “as the deadline draws to a close, there is still no encouraging news that an agreement has been reached,” and that “if an agreement is not reached by September 30, there remains a fear of what the next step will be, but the most likely scenario would be the re-extension of the license for a certain, probably a shorter time.”
“August was a hot, but very successful month for the energy sector in Bulgaria,” Sirleshtov reports, as “the Ministry of Energy managed to administer the last payments under the Recovery and Resilience Plan of the Republic of Bulgaria and many renewable and BESS projects (including Aratiden and Solar Park Trakiya) managed to utilize their grants.” He says that “Bulgaria is surging to the position of the world’s No. 1 market for the share of operating power coming from Battery Energy Storage Systems (BESS) relative to its electricity grid and population size,” adding that “over the past two years, an extraordinary EUR 3 billion investment boom has transformed Bulgaria from a minor energy storage player into the absolute champion of Europe’s fastest-growing battery market.”
Sirleshtov also reports that “the Bulgarian Government also published its plans for the period 2026-2030 in the energy sector,” including the “implementation of the Strategy for Sustainable Energy Development to 2050 with clear roadmaps to 2035 and 2050 that will be updated every five years;” the “preservation of coal capacities as strategic reserve for peak and crisis conditions;” the “establishment of nuclear energy as strategic pillar with long-term operation of Kozloduy Units 5 & 6, construction of Units 7 & 8 with AP1000 technology, and exploration of small modular reactors;” the “enhanced utilization of hydro potential through modernization of existing plants and the construction of new pumped-storage facilities;” the “expansion of Chiren underground gas storage to 1 billion cubic meters capacity;” and the “development of Bulgaria as a regional energy hub in Southeast Europe.”
According to Cetinkaya, “on September 6, 2026, the Ministry of Treasury and Finance and the Directorate of Strategy and Budget published its Medium-Term Program for 2027-2029 (MTP), outlining several regulatory priorities for data protection, artificial intelligence and cybersecurity.” He says that “most notably, the MTP envisages completing the alignment of the Turkish Data Protection Law No. 6698 with the EU framework, particularly the GDPR, by the third quarter of 2027.”
Cetinkaya also reports that, “on August 18, 2026, the Ministry of Industry and Technology published Turkiye’s 2026-2030 AI Action Plan, outlining Turkiye’s roadmap for developing, deploying, and governing artificial intelligence through 16 priority actions.” Among its key measures, he notes, “the action plan envisages establishing a National AI Council as the highest decision-making and inter-institutional coordination body, developing a national legal and ethical framework for AI that considers the EU’s proportionate risk approach, and establishing a National AI Ethics Board.” It also “provides for algorithmic impact assessments and model cards for high-impact AI systems deployed by public institutions, regulatory sandboxes in priority sectors, and further guidance and standards on AI security.” Cetinkaya adds that “in parallel, Turkiye plans to expand its AI infrastructure and investment capacity through data spaces, public-sector AI pilots, and AI Growth Zones.”