Poland Planning reform redraws the land market

Investors are no longer buying just a plot of land. Above all, they are buying certainty about how it can be used in the future.
Katarzyna Tencza, transaction director at Walter Herz

The special housing act, known as lex deweloper, expired on August 31, 2026. For eight years, it enabled residential projects to be developed on sites that were not always designated for housing under local zoning plans. According to the Polish Association of Developer Companies (PZFD), the procedure was used for projects comprising more than 100,000 apartments – a volume close to the annual output of Poland’s developers.

The expiry of the act does not affect projects that have already entered the procedure. Proceedings initiated before September 1 can continue under transitional provisions, while existing local zoning plans, building permits and previously issued WZ decisions remain valid.

The biggest change concerns new projects on land without a local zoning plan. In municipalities that have not yet adopted a general plan, new WZ decisions can no longer be issued after September 1, nor can new local zoning plans be adopted or existing ones amended. New Integrated Investment Plans (ZPI), one of the intended successors to lex deweloper, are also currently blocked.

General plans become a new filter for land value

By August 31, 2026, 877 general plans had been adopted, covering around 35 pct of municipalities. By September 3, the number had risen to 946, covering around 38 pct of all municipalities, according to the Ministry of Development and Technology. Most local authorities, however, are still working on their plans.

Among Poland’s major cities, general plans have already been adopted by Poznań, Wrocław, Lublin, Bydgoszcz, Szczecin, Toruń, Białystok, Olsztyn, Opole, Zielona Góra and Gorzów Wielkopolski. Draft plans are being prepared in Warsaw, Gdańsk, Łódź, Katowice and Kielce, while Kraków and Rzeszów are at an earlier stage.

For investors, this is changing how land is valued. Previously, a plot without a local zoning plan could still command a high price because of the prospect of obtaining a WZ decision. Under the new system, the general plan will become more important – particularly whether a property falls within an area designated for infill development and whether the desired use will be permitted.

The reform is widening the gap between plots with secured development potential and speculative land.
Katarzyna Tencza

In practice, developers may increasingly focus on land covered by local zoning plans, with legally binding WZ decisions, ULIM decisions or an ongoing lex deweloper procedure. Location remains crucial, but the time required and the likelihood of securing development rights are becoming increasingly important.

Warsaw, Kraków and Gdańsk under pressure

The greatest uncertainty concerns some of Poland’s largest markets. In Warsaw, comments on the draft general plan are being reviewed, with adoption potentially coming at the turn of 2026 and 2027. The city has also suspended its assessment of ZPI concepts submitted since mid-May and plans to return to them towards the end of the year.

Lex deweloper was used extensively in the capital. More than 100 applications were submitted, of which more than 20 resulted in positive decisions on the location of residential projects. Resolutions adopted by May 2026 cover around 7,000–9,000 apartments. The city also secured around PLN 420 mln in infrastructure contributions from 16 projects. At its August 27 session, the city adopted four more ULIM decisions.

The uncertainty is even greater in Kraków. The city did not use lex deweloper, and its draft general plan has not yet been submitted for consultation. Its adoption is expected in mid-2027. New ZPI procedures remain blocked until the plan comes into force. The situation is partly mitigated by the fact that around 90 pct of Kraków is already covered by local zoning plans.

In Gdańsk, the draft general plan has returned for further consultation. Seven projects comprising around 4,100 apartments were developed under lex deweloper. The value of accompanying investments amounted to PLN 207 mln, while road agreements were worth PLN 262 mln.

The differences between these markets show how important the state of the local planning system is becoming for investors. Where planning is more advanced, it is easier to assess a plot’s development potential and plan the timing of a future project.

ZPI does not yet fill the gap

The Integrated Investment Plan was intended to become one of the main successors to lex deweloper. It allows a municipality and an investor to agree on a change in land use in return for an urban planning agreement and the delivery of complementary infrastructure such as roads, utility networks, schools, nurseries and green spaces.

In the future, ZPI could also facilitate the conversion of office, retail and former industrial sites into residential projects. For now, however, most major cities are not ready to use the instrument effectively. Over the past three years, only Lublin has taken a ZPI procedure to a stage where it could be used in practice.

ZPI could eventually make it easier to convert office, retail and former industrial sites into residential projects, but for now it does not fill the gap left by lex deweloper.
Katarzyna Tencza

This leaves investors in some municipalities with limited options for launching new projects on sites without a secured planning route.

Low-risk land commands a premium

The first signs of change are already visible in the land market. According to Otodom data from August 2026, land prices in Warsaw were approaching PLN 900 per sqm, compared with around PLN 600 in Kraków and PLN 484 in Gdańsk. Over the year, prices rose by around 20 pct in Kraków and 24 pct in Gdańsk. At the same time, demand for building plots increased by 21 pct, while supply fell by 11 pct.

In Kraków, land now accounts for 25–30 pct of the price of an apartment, compared with 10–15 pct several years ago.

These figures do not mean that rising land prices are solely the result of the planning reform. They do, however, show that with supply constrained and demand remaining strong, the difference between land with confirmed development potential and sites whose future use remains uncertain is becoming increasingly important.

Investors may therefore favour projects covered by local zoning plans, with legally binding WZ decisions, ULIM decisions or an ongoing lex deweloper procedure. Land value will depend not only on location, but also on the likelihood of securing a specific use and the time required to launch a project.

Reform could constrain future supply

The effects of the reform will initially be felt mainly in land transactions and investment decisions, but over time they could affect the supply of new housing. Another potential consequence is a slowdown in the conversion of older office, retail and former industrial properties into residential projects, prompting some owners to reconsider their asset strategies.

If Warsaw does not adopt its general plan until the turn of 2026 and 2027, and Kraków not until mid-2027, some new projects could be delayed. A similar situation could emerge in Gdańsk and Katowice, where the pace of investment will depend on progress with planning work.

Capital will favour cities where the planning system is already working. This could create a temporary investment premium for markets such as Poznań and Wrocław, where the new system is already operational.
Katarzyna Tencza

In the short term, the reform primarily means a change in how planning risk is priced. In the medium term, it could reduce the number of new projects. If the planning gap persists for many months, one consequence could be lower housing supply in 2027.

The biggest beneficiary of the reform may therefore be not a particular market segment, but land with low planning risk. Plots with a clearly defined development path could command a premium, while sites without local zoning plans or secured WZ decisions will face greater uncertainty. The reform is thus creating an increasingly clear divide between land whose development potential can be priced in today and land whose value depends on what spatial planning ultimately permits.