Dispute over building registration: Is a wave of fines looming by the end of the year?

According to the new Law on the Management and Maintenance of Buildings, which came into effect in 2025, every residential building in Croatia must become a legal entity and obtain its OIB by the end of the year. The deadline for registration in the building co-owners register is December 31, but progress has been very slow so far.

Based on the report from the State Geodetic Administration, 2105 applications for registration in the Register of Co-owners have been submitted and resolved, resulting in the issuance of only 2105 OIBs. The relevant Ministry of Physical Planning, Construction and State Property adds that there are still 1073 applications being processed, meaning a total of 3178 applications have been submitted. For comparison, it is estimated that there are only 15 to 20 thousand entrances to buildings in Zagreb alone, not counting the rest of Croatia’s cities and settlements.

In addition, all building managers in Croatia must also be registered in a special register. More specifically, the application for registration in the co-owners register is submitted by the building manager, who must first be registered in the register of building managers. The registers must be established by June 30, 2025, managed by the State Geodetic Administration, and managers who do not submit their registration application within six months, i.e., by December 31, 2025, may be fined between 700 and 5500 euros.

The Ministry estimates that there are between 150 and 300 managers in Croatia, with about a hundred being market-oriented, while the others manage a smaller number of properties, i.e., less than ten buildings. For the register of building managers, 240 applications have been submitted, meaning that 240 managers are already registered, according to DGU data.

Unrealistic deadline

The state has decided to establish these two registers because there has not been a set of systematized data on the number of multi-apartment buildings and managers in Croatia until now.

– Now it is the turn of the managers because they will benefit the most from these registers. They are given a unique opportunity to organize and consolidate the documentation they have and store it in one place. This will significantly simplify their operations once the registers are filled, and the co-owners receive their OIBs – say the Ministry.

Milivoj Kisić, director of the management company K-Index from Zagreb, emphasizes that it is not a problem that this was decided to be done through the managers and representatives of the building residents, but in relation to the amount of work involved in the registration, the deadline is too short and unrealistic.

Building managers must provide the DGU with sketches of all apartments in the buildings they manage and the exact names of all owners, but many do not have all these detailed information about the buildings, which slows down the entire process. The option is for the representatives of the residents to pay the managers for the creation of the entire scheme (prices range around 11-13 euros per apartment), however, this process is slower and more expensive.

– We calculated that about 27 thousand apartments should be processed every hour to achieve this by the end of the year – says Kisić.

Change of plan?

Therefore, the representatives of the residents themselves have stepped in to help, drawing sketches and listing other owners. Kisić notes that many representatives of the buildings they manage have sent their schemes, so the response is large, and the representatives of the residents are indeed speeding up this process, but still not enough to list everything by the end of the year.

From the Ministry of Physical Planning, Construction and State Property, however, they say that both registers are being filled at a ‘satisfactory pace’. However, they admit that not all buildings will receive their OIBs by the end of the year.

– The Register of Co-owners is also making good progress, and the numbers are growing exponentially as the year comes to a close. Nevertheless, the pace of filling is not such that all co-owners could receive their OIB by the end of the year – the Ministry states, noting that they will have the exact number of registered managers and co-owners by the end of the year.

From this response, it can be inferred that due to the large scope of work and the current pace, some flexibility is expected, as otherwise, most managers could face financial penalties.

As we unofficially learn, the Ministry will likely allow buildings to be assigned an OIB if the manager submits only the inter-ownership agreement to the register. This way, the DGU could immediately assign the OIB because the inter-ownership agreement confirms who is the co-owner of which apartment, how the building will be managed, and who has the authority, without the need to additionally and thoroughly collect all data, sketches, lists of apartments and owners, which is a slow process involving many participants.

– If they allowed this shorter procedure, then the registers could be filled by the New Year – says Kisić.

What does the OIB bring to buildings?

By assigning an OIB, the building becomes a legal entity, which means it can independently act in legal proceedings or when entering into contracts, instead of having to list all co-owners individually. Likewise, individual enforcement proceedings will no longer be conducted against each co-owner, but against one legal entity. The community of co-owners can open a separate bank account for the reserve fund, which means that representatives of the co-owners or building managers will no longer have to use their own OIB for transactions.

The Ministry emphasizes that ‘the obtained OIB will be a prerequisite for participation in all funding competitions announced by the state in the future.’