New Rules in Administrative Procedures: Key Changes Introduced by the ZUP-I Amendment from February 2026

The amendments to the General Administrative Procedure Act (ZUP) introduced by the ZUP-I amendment, which will enter into force in February 2026, constitute a significant reform of administrative procedural law. The amendment introduces a comprehensive package of changes which, inter alia, regulates key aspects of the service of documents, introduces new procedural mechanisms, seeks to streamline the conduct of proceedings, and updates the rules governing time limits for issuing decisions and lodging appeals. This article provides a concise overview of the most significant changes.

The most far-reaching amendments concern the service of documents, with the amendment distinguishing between different categories of documents, in particular depending on whether service triggers the commencement of a time limit for the exercise of a legal remedy or another procedural right.

For documents from which a time limit begins to run (e.g. decisions, rulings, requests for completion), personal service is retained. Where the addressee cannot be reached, the server leaves the document in the letterbox or on the door, and service is deemed to have been affected on the seventh day following the day on which the notice or document was left. This reduces the statutory fiction of service from the previous 15 days to 7 days. In cases of unsuccessful personal service on private individuals, the document is therefore no longer deposited at the post office; instead, service is completed at the addressee’s address.

Different rules apply to the service of documents from which no time limit begins to run (e.g. various notices, invitations, informational communications). Such documents may be served other than by personal service, by simply leaving them in the addressee’s letterbox. In such cases, service is deemed to have been effected on the day the document is actually left, without the application of a statutory fiction of service.

For legal entities and sole traders, the amendment further strengthens the obligation to accept electronic service via a secure electronic mailbox, while electronic service remains voluntary for private individuals.

The amendment also introduces the concept of an informational decision, which partially replaces the existing procedure whereby a party is, prior to the issuance of a decision, acquainted with the facts and circumstances relevant to the case. An informational decision comprises an operative part, a statement of reasons, and instructions on legal remedies, and enables the party to lodge an objection within a specified time limit. If no objection is lodged, the informational decision becomes final. Where an objection is lodged, the authority continues the proceedings and resolves the matter either by issuing a new informational decision or adopting a final decision.

The ZUP-I amendment further introduces the possibility of issuing a decision without a statement of reasons. This marks a departure from the previous fundamental rule under which every administrative decision was required to contain a statement of reasons, irrespective of whether the party’s request had been granted in full. Under the new regime, an authority may issue a decision without reasons where the party’s request is granted in full and the decision does not affect the rights or legal interests of other persons.

At the same time, the ZUP-I amendment introduces a safeguard for the party’s position: where the party requests a statement of reasons, the authority is required to issue it within the statutory time limit. The statement of reasons so issued is deemed to form an integral part of the decision, and the time limit for lodging an appeal begins to run from the date of its service.

As regards time limits for issuing decisions, the ZUP-I amendment retains the general two-month period for issuing a decision, or one month in cases involving a simplified fact-finding procedure, while expressly permitting the deadline to be extended by up to two additional months in more complex cases. The authority is required to notify the party of any such extension.

An important change also concerns the time limit for lodging an appeal, which is extended from 15 to 21 days. The longer appeal period applies to the majority of administrative decisions and is aligned with the shortened statutory fiction of service.

As the changes introduced by the amendment will inevitably intersect in practice and raise new questions about their application, a comprehensive understanding of the broader context and the interrelationship between the amendments will be essential to the proper handling of specific administrative matters. For this reason, close monitoring of the application of the new framework, together with the timely clarification of procedural issues emerging in practice, will be particularly important in the period ahead.