Poland's planning reform is reshaping the land market as the Housing Special Act, commonly known as lex developer, expired on 31 August 2026. The legislation had for eight years enabled residential projects to be built on sites not always designated for residential use under local zoning plans. According to the Polish Association of Developers, the procedure was applied to projects comprising over 100,000 homes during that period. Plots covered by a local zoning plan, a legally binding planning decision, or an adopted Residential Investment Location Determination are now gaining in value, while sites without a secured development pathway face price pressure as regulatory risk becomes a direct component of land valuations.
The decision-making gap primarily affects municipalities that have not yet adopted a general plan. According to the Ministry of Development and Technology, 946 municipalities, representing around 38 per cent of all municipalities in Poland, had adopted general plans by 3 September 2026, exceeding the minimum 30 per cent threshold agreed with the EU. However, the majority of local governments are still working on their plans. Among major cities, general plans have been adopted in Poznań, Wrocław, Lublin, Bydgoszcz, Szczecin, Toruń, Białystok, Olsztyn, Opole, Zielona Góra and Gorzów Wielkopolski, while Warsaw, Gdańsk, Łódź, Katowice and Kielce have draft plans in place. Kraków and Rzeszów have not yet reached this stage.
For investors, the reform changes the way land is valued. Previously, a plot without a local zoning plan could command a high price based on the prospect of obtaining a planning decision. Under the new framework, the key factor is what the general plan provides for the site. If a plot falls outside a built-up area completion zone or within a zone that does not permit the intended use, its investment value may decline significantly. In practice, investors are increasingly buying predictability regarding a site's future use rather than speculative development potential.
The uncertainty is most acute in Poland's largest markets. Warsaw's general plan is realistically expected to be adopted at the turn of 2026 and 2027. In Kraków, which did not use lex developer at all, the draft general plan has not yet been submitted for review and its adoption is estimated for mid-2027, though approximately 90 per cent of the city is already covered by local zoning plans. In Gdańsk, the draft plan has returned for renewed consultations; seven projects were developed under lex developer there, comprising around 4,100 apartments. The Integrated Investment Plan, intended as one of the main successors to lex developer, has so far been taken to a practically applicable stage only in Lublin, meaning the gap left by the expired act is not being automatically filled.
Land price data from Otodom for August 2026 show prices in Warsaw approaching PLN 900 per sqm, around PLN 600 per sqm in Kraków and approximately PLN 484 per sqm in Gdańsk. Over the past year, land prices rose by around 20 per cent in Kraków and 24 per cent in Gdańsk, while demand for building plots increased by 21 per cent and available supply fell by 11 per cent. In Kraków, the share of land costs in the price of an apartment has risen to 25-30 per cent, compared with 10-15 per cent several years ago. Cities where the new planning system is already operational, such as Poznań and Wrocław, may attract a temporary investment premium as capital favours markets with greater planning certainty.
In the short term, the reform means a change in the way risk is priced into land transactions. In the medium term, it may reduce the number of new projects coming forward, and a prolonged planning gap could result in lower housing supply in 2027 and further upward pressure on land prices. A slowdown in the conversion of older office, retail and post-industrial properties into residential use is also a possible side effect, as some owners may be forced to reconsider their asset strategies while awaiting general plan adoption.
