Analysis · Construction
From 25 August 2026 the Romanian as-built file must be electronic and uploaded to the National Construction Register. What it means for a contractor's records.
In short
Updated September 2026 · 13 min
You have read a summary of the new Code, you have works under execution and a handover this autumn, and you want to know what to change in your records, not in urban planning. At the installation contractors we work with, the as-built file is already an export from the construction workflow: dossiers approved along the way are the pieces required at the end, in the format the law now demands. This analysis covers what Law 169/2026 changes about the as-built file (cartea tehnică), what the contractor hands over and when, what gaps cost, and how an electronic file is built without waiting for the register platform.
The as-built file must be compiled in electronic form, updated during execution under the site supervisor's coordination, and registered in the National Construction Register. The Code of territorial planning, urbanism and construction (CATUC) was published in Official Gazette no. 661 of 10 August 2026 as Law no. 169/2026 and entered into force 15 days later, on 25 August 2026 (art. 575). It repeals Law 50/1991, Law 350/2001 and almost all of Law 10/1995, of which only articles 10 and 41 survive (art. 576).
The article that concerns you directly is 529: "the elaboration and compilation of the technical book of the construction in electronic format, uploaded to the National Construction Register, is mandatory" (Law 169/2026, art. 529 para. 2). The file is compiled by the developer and handed to the client, and "the updating of the technical book during execution is carried out under the coordination of the site supervisor" (art. 530 paras. 2 and 3). When the building is sold, the file goes to the new owner "in physical and digital format", and the digital version is registered in the register by the client (art. 530 paras. 8 and 9).
The contents do not change: design, execution, handover and operation, maintenance and in-service monitoring documentation (art. 530 para. 1), the same four groups that Government Decision 273/1994 calls chapters A–D. The handover regulation stays in force until replaced (art. 583 para. 1). What changes is the format, the moment it is assembled and where it ends up.
| Law 10/1995 and Decision 273/1994 | CATUC · from 25 August 2026 | |
|---|---|---|
| Format | Paper or electronic, as the parties choose | Electronic, mandatory (art. 529) |
| When it is assembled | At handover, as a rule | During execution, under the site supervisor (art. 530) |
| Who compiles it | The investor | The developer, handed to the client (art. 530) |
| Where it ends up | With the owner, in the archive | With the owner and in the National Construction Register (art. 530) |
| What the contractor hands over | Their documents, at handover | The file's documents, before requesting handover (art. 452) |
The contractor submits for handover only works for which it has handed over the documents needed for the as-built file, notifies completion and requests the commission, and the client organises handover within 30 days. The wording in the law is precise: the general contractor is responsible for "submitting for handover only constructions that meet the quality requirements and for which it has handed over to the client/developer the documents needed to compile the technical book of the construction" (art. 452 letter i). The contractor also notifies completion of the works and requests that the commission be convened (art. 452 letter n).
On the other side, the developer must organise handover "on the basis of the notification sent by the contractor" and complete it "within 30 days of receiving the notification" (art. 423 para. 7). The Code provides no deemed acceptance if the deadline passes, contrary to some press summaries; it provides an offence for the client who fails to organise handover (art. 570). For you the deadline is useful in another way: after the notification, those 30 days are no longer time for hunting declarations of performance through e-mail.
The commission receives, through the site supervisor, the as-built file, the operation and maintenance manual, the handover reports and the as-built drawings, whose level of detail is set by the contract between client and contractor (art. 528). Nor is handover a single moment any more: at the contractor's request, with the designer's opinion, partial handovers may be carried out per object or section, including for works under execution when the Code entered into force (art. 527 para. 3 and art. 574). Every piece closed comes with its own documents.
The minimum fine for serious breaches rises from 1,000 to 50,000 lei, failing to hand over or maintain the as-built file costs 20,000–50,000 lei, the half-fine paid within 48 hours disappears, and limitation runs from the breach. The Code sets offences on three tiers: 50,000–100,000 lei for breaches under letters a) to m), 20,000–50,000 lei for letters n) to ee) and 10,000–20,000 lei for the rest, with no warning (art. 570 paras. 2 and 3). Law 10/1995 started its top tier at 1,000 lei (Law 10/1995, art. 36).
Documents sit on two tiers. On the top one, "failure to present the documents and records requested by persons with control duties" and handover carried out in breach of the law (art. 570 para. 1 letters e and i). On the second, the developer's failure to hand over the file, the client's failure to complete and keep it, and the lack of professional civil liability insurance for designers, contractors and consultants (art. 570 para. 1 letters r, t and dd). The fine is the developer's or the client's, but the documents they cannot hand over are yours.
Two mechanisms make the fine more likely, not just larger. The general regime for offences under Government Ordinance 2/2001 does not apply (art. 581 para. 3), so the payment of half the fine within 48 hours that Law 10/1995 allowed (art. 38) disappears. And the right to establish the offence is time-barred 5 years "from the date the act was committed" (art. 571 para. 2), not from handover as before (Law 10/1995, art. 39): a document missing from month four of the site has its own clock.
Also from 25 August, contractors must hold insurance for construction and erection works and 10-year civil liability insurance from handover, both presented at the start of works (art. 556). And from 1 June 2027 contracting authorities require, in works tenders, the technical and professional qualification certificate issued by the Romanian Association for the Certification of Construction Operators, with a public digital register (art. 383). The criteria come by Government Decision; a documented track record will count.
| Law 10/1995 · minimum of the top tier | 1,000 lei |
|---|---|
| CATUC · serious breaches, letters a–m | 50,000 lei |
| CATUC · file not handed over, no insurance | 20,000 lei |
| CATUC · the rest, letters ff–oo | 10,000 lei |
Law 10/1995, art. 36; Law 169/2026, art. 570, 2026
The State Inspectorate for Construction suspended 617 handovers and rejected 95 in 2025, and among the highly repetitive deficiencies it names as-built file documents drawn up improperly. The 2025 summary counts 28,692 control activities during execution, 7,284 deficiencies, 2,216 sanctions and fines of 19.2 million lei (ISC, 2026). The figures predate the Code, with the 1,000 lei minimum.
The ISC wording is worth reading in full, because it describes exactly what an ordinary contractor is missing: "improper drawing-up of the documents that make up the technical book of the construction, either through the absence of the quality documents of the products put into the works, or through the failure of all parties involved to sign off the quality documents concluded" (ISC, 2026). That is, missing declarations of performance for installed materials and reports signed by two parties out of three. The same two gaps at every handover, now with a fine tier above them.
ISC, Summary of activities in 2025, published in 2026
On 1 September 2026 the sector had 64 % of PNRR works certified and 33 % collected, and the employers' federation describes sites at 50–60 % physical progress settled at 5 %, for lack of documents. The figures are Daniel Pițurlea's, vice-president of the FPSC federation: of roughly €9.45 billion allocated to the sector, certified works totalled about €6 billion, and contractors had collected €3.1 billion (Agenda Construcțiilor, 2026). Cristian Erbașu, the federation's president, put it more bluntly: works physically executed at 50–60 % were settled at 5 % "because there were no documents behind them to certify them" (Gândul, 2026).
It does not matter whether you have PNRR works or not. The mechanism is general: a progress statement is certified on documents, and missing documents block the invoice, not just the handover. A material approval dossier without the signed version, a critical-phase report with one signature missing, a declaration of performance requested from the supplier three weeks ago: each one holds the money in place. The new Code does not invent the problem; it gives it a mandatory format and a price.
Hence a rule we applied before the Code and which is now also the law's logic: whoever signs a document also files it, in the same place, at the moment of signing. Not in an e-mail thread, not in the site manager's WhatsApp. The electronic file that art. 529 requires is exactly the collection of documents filed that way, with the date and the approvers next to each.
Every document enters the file at the moment of signing, linked to the installed product and to the item in the bill of quantities, and the execution chapter becomes an export, not a reconstruction. The order of things does not change: the item is quoted from the bill of quantities, approved in the material approval dossier, ordered, installed and documented. What changes is only where each piece ends up when it appears.
Concretely, the material approval dossier enters the file in the approved version, with the signatures of the site supervisor, the designer and the client, not the last one sent. The declaration of performance sits attached to the product in the library and is reused on every project where it is installed. The hidden-works report is generated from the execution stage and signed at its moment, by all parties. When a piece of equipment is replaced along the way, the new data sheet replaces the old version in the file, not just in e-mail.
What is missing shows during the works, while the supplier still answers and the crew is still on site. This is what the electronic file of an installation site looks like in week 30, with handover two months away:
The last row is new. Order no. 975/2026 of the Ministry of Development, published in Official Gazette no. 711 of 26 August 2026, replaces the permitting forms with 36 new templates, usable in physical or digital form, among them the notices of start of works to the authority and to the inspectorate (F_A_08 and F_A_09) and the notices of completion (F_A_10 and F_A_11) (MDLPA, 2026). They are site documents, with a date, and they belong in the same record as the rest.
At an installation contractor with over 100 employees and several sites in parallel, the approved version of the material approval dossier enters the execution chapter at the moment of signature, and handover is an export. The workflow runs on the same dossier used for material approval: the technical office generates the dossier from the product library, the site supervisor, the designer and the client approve it with a status per item, and on approval the signed version is linked to the item in the bill and to the installed product.
When the Code entered into force, nothing changed in the way people there work. What changed is that the format they produce anyway, every document with its date, version and approvers, became the format the law requires. At handover, the documentation lead picks the project and exports the execution chapter; whatever shows as missing is that week's work, not a surprise on the day of the commission.
The same item has a continuous trail: quoted in the bill of quantities, approved in the material approval dossier, documented in the as-built file. The new Code requires exactly that continuity, without saying how to get it.
The Code applies immediately and without secondary legislation (art. 575 para. 2), but in three situations this article changes nothing for you.
On the next job, before the first critical phase, decide for each type of document who files it at the moment of signing and where; it is a one-hour decision that produces the electronic file without waiting for the register platform. The chapter structure and what is usually missing at handover are in the as-built file guide.
Before the first handover under the new Code
No. Registering the digital file in the National Construction Register is the client's responsibility (art. 530 para. 9), and compiling the file is the developer's. Your obligation is to hand over the documents needed for the file before handover (art. 452 letter i) and to notify completion of the works. What you hand over, however, has to be in a format that can be uploaded, not in a binder.
The law sets no deadline for it. The only IT-system date in the Code is 1 September 2027, for the reference-index application (art. 418 para. 5), not for the register. The Code applies from 25 August 2026 without waiting for secondary legislation (art. 575 para. 2), so the electronic-file obligation exists now; the platform will receive whatever you have structured in the meantime.
Yes, until replaced. The Code keeps the decisions issued under the repealed laws in force until new ones are adopted (art. 583 para. 1), and only articles 10 and 41 of Law 10/1995 survive. The chapter structure, design, execution, handover and operation, is in any case the same one the Code requires in art. 530.
They finish under the new Code. Handovers from now on follow it, and works in progress may be accepted in parts, by sections or objects, at the contractor's request with the designer's opinion (art. 527 para. 3 and art. 574). For a contractor this means closing and handing over in pieces, each with its own documents, instead of waiting for the end.
The first conversation is about your process: who does what, on which documents, where time is lost.
One email a month, only when we publish. Nothing else.
The four chapters (A–D) of the Romanian as-built file, who is responsible for each, what is usually missing at handover and how to build it as you go.
Read →Material approval (MAF / submittals): what the packet contains, the technical office → supervisor → designer → client circuit and where time is lost.
Read →Where quote calculations live today, what gets reused (product list, prices, norms), what is recalculated each time, and how 5 days become one.
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