Planning reform reshapes the land market, driving up the value of low-risk sites

The end of the lex developer act and delays in adopting general plans in most municipalities are creating a new hierarchy of land on the real estate market. Plots covered by a local zoning plan (MPZP), with a legally binding planning decision (WZ), or with an adopted ULIM (Residential Investment Location Determination) are gaining in value, while sites without a secured development pathway and exposed to the risk of waiting months for a decision are losing value. Regulatory risk is becoming a direct component of land prices. The impact of the ongoing reform may also be reflected in the supply of new projects in 2027.

The Lack of General Plans Creates a Decision-Making Gap

On August 31^st, 2026, the Housing Special Act, commonly known as lex developer, expired. For eight years, it enabled residential projects to be developed on sites that were not always designated for residential use under local zoning plans (MPZP). According to Polish Association of Developers (PZFD), during the period in which the act was in force, the procedure was applied to projects comprising over 100 thousand homes — a scale comparable to the annual output of Poland’s residential developers.

The expiry of the act does not mean that projects already underway will be halted. Proceedings initiated before September 1^st, 2026 may continue under transitional provisions. Existing local zoning plans (MPZP), building permits and previously issued planning decisions (WZ) remain in force.

The decision-making deadlock primarily affects new developments on land without a local zoning plan. In municipalities that have not yet adopted a general plan, as of September 1^st, 2026, it is no longer possible to obtain a WZ decision for a new application, adopt a new local zoning plan (MPZP), amend an existing one, or proceed with a new Integrated Investment Plan (ZIP), which replaces lex developer. Applications for WZ decisions submitted before the end of August, however, continue to be processed under the previous rules.

The General Plan Becomes a New Filter for Land Value

According to the Ministry of Development and Technology (MRiT), 877 general plans had been adopted by August 31^st, covering approximately 35 per cent of municipalities. By September 3^rd, the ministry reported that the number had risen to 946 municipalities, representing around 38 per cent of all municipalities in Poland. This means that the minimum 30 per cent threshold agreed with the EU has been reached. However, the majority of local governments are still working on their general plans, following a deadline that has been postponed several times.

Among Poland’s major cities, general plans have already been adopted in Poznan, Wroclaw, Lublin, Bydgoszcz, Szczecin, Torun, Bialystok, Olsztyn, Opole, Zielona Gora and Gorzow Wielkopolski. Warsaw, Gdansk, Lodz, Katowice and Kielce have draft plans in place. Cracow and Rzeszow, for example, have not yet reached this stage.

For investors, this means a change in the way land is valued. Until now, a plot without a local zoning plan (MPZP) could command a high value based on the prospect of obtaining a WZ decision. Following the reform, the key factor will be what the general plan provides for the site, and in particular whether the property is located within a built-up area completion zone.

If a plot falls outside such an area or within a zone that does not permit the intended use, its investment value may decline significantly. In this environment, the market will primarily reward land with secured development potential. In practice, this means that investors are no longer buying just a plot of land — above all, they are buying predictability regarding its future use.

Warsaw, Cracow and Gdansk Are Still Waiting

The greatest uncertainty concerns Poland’s largest real estate markets. Warsaw is currently reviewing submissions on the draft general plan. The plan is realistically expected to be adopted at the turn of 2026 and 2027. The city authorities have also suspended the review of ZPI proposals submitted since mid-May and announced that the process will resume towards the end of the year.

The scale of lex developer use in the capital has been significant. Over 100 applications were submitted, including over 20 applications for a Residential Investment Location Determination (ULIM) that were approved under the scheme. This translates into approximately 7,000–9,000 new homes covered by resolutions adopted by May 2026. The city also secured approximately PLN 420 million in infrastructure contributions from 16 projects. At its 27 August session, the city council approved a further four ULIMs.

The legislative and investment risk is currently even greater in Cracow. The city did not use lex developer at all, and the draft general plan has not yet been submitted for review. Its adoption is currently estimated for mid-2027. New ZIP procedures have been blocked since September 1^st,  until the general plan comes into force. The situation is mitigated by the fact that approximately 90 per cent  of Cracow is already covered by local zoning plans (MPZP).

In Gdansk, the draft general plan has returned for renewed consultations and coordination. Seven projects were developed under lex developer, comprising approximately 4,1 thousand apartments. The value of associated infrastructure investments amounted to PLN 207 million, while road infrastructure agreements totaled PLN 262 million.

ZPI Does Not Fill the Gap

The Integrated Investment Plan (ZPI) was intended to be one of the main successors to lex developer. It allows a municipality and an investor to agree on a change in the way a site is developed in exchange for an urban planning agreement and the delivery of associated infrastructure, such as roads, utility networks, schools, kindergartens or green spaces.

In the future, the mechanism could also facilitate the conversion of office, retail and post-industrial sites into residential developments. Today, however, most major cities are not yet ready to use it efficiently. Over the last three years, only Lublin has taken a ZPI procedure to a stage that allows for its practical application. This means that the gap left by lex developer is not being automatically filled.

“Secured” Land Gains Value

The first signs of the decision-making bottleneck created by municipalities that have failed to complete their general plans are already visible in the land market. According to Otodom data from August 2026, land prices in Warsaw are approaching PLN 900 per sq m, while in Carcow they stand at around PLN 600 and in Gdansk at approximately PLN 484. Over the last year, land prices have increased by around 20 per cent in Cracow and 24 per cent in Gdansk. Demand for building plots has risen by 21 per cent, while available supply has fallen by 11 per cent. In Cracow, the share of land costs in the price of an apartment has already risen to 25–30 per cent, compared with 10–15 per cent several years ago.

The reform is beginning to widen the gap between plots with secured development potential and speculative land. In the upcoming months, in municipalities without general plans, developers may focus primarily on acquiring projects with an MPZP, a legally binding WZ decision, a ULIM, or a lex developer procedure already underway. The value of land therefore now depends not only on location, but also on the likelihood of obtaining a specific permitted use and the time required to complete the procedures necessary to commence a development.

The Impact of the Lack of General Plans

The effects of the planning reform and the decision-making gap affecting more than 60 per cent of municipalities in Poland will first become visible in new investment decisions and land transactions, and later in housing supply. Another significant side effect could be a slowdown in the conversion of older office, retail and post-industrial properties into residential developments, forcing some owners to reconsider their asset utilization strategies.

If Warsaw adopts its general plan only at the turn of 2026 and 2027, and Cracow follows in mid-2027, some new projects may be postponed. The situation in Gdansk and Katowice will likewise depend on the pace of general plan adoption. In this environment, capital will favor cities where the planning system is already functioning. This could, for example, create a temporary investment premium for Poznan and Wroclaw, where the new system is already operational.

The biggest beneficiary, therefore, may currently be not so much a specific market segment as land with low planning risk. At the same time, some plots without a local zoning plan (MPZP) and without a secured WZ decision may lose value if the future general plan restricts their development potential.

In the short term, the reform primarily means a change in the way risk is priced. In the medium term, it may reduce the number of new projects. And if the planning gap persists for many months, it could result in lower housing supply in 2027 and further upward pressure on land prices — and, in high-demand locations, on residential property prices as well.

Katarzyna Tencza, Transaction Director, Walter Herz