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June 2026 Amendments to the Law on Technological Industrial Development Zones

KEY TAKEAWAYS

• The amendment published in Official Gazette No. 132/2026 entered into force on 17 June 2026.

• Articles 34-a to 34-s, which regulated confirmation of structures and technical equipment whose legal status had not been determined, were deleted.

• New Article 38-z regulates special cases of registration of ownership in the Real Estate Cadastre for qualifying structures, not a general legalization procedure for technical equipment.

• Only structures built under final building permits and lacking a permit for use fall within Article 38-z.

• The land lessee must submit an initiative to the Directorate within one year after 17 June 2026.

• The Management Board of the Directorate decides within 90 days when the statutory conditions and evidence are satisfied.

 

The Law on Technological Industrial Development Zones regulates investment incentives, establishment and operation of technological industrial development zones, activities within the zones, construction procedures, land leases and other matters concerning zone users and investors.

The amendment adopted on 11 June 2026 and published in the Official Gazette of the Republic of North Macedonia No. 132/2026 on 17 June 2026 substantially changed the subject of the existing webpage. It deleted the former provisions on confirmation of structures and technical equipment and introduced a narrower procedure titled Special cases of registration of ownership in the Real Estate Cadastre of structures built within the zones.

The June 2026 amendment concerns the deletion of the former technical-equipment procedure, special registration of ownership of qualifying structures, construction and production deadlines, land leases and related construction documentation rules.

This page is part of our business and corporate law practice, through which we advise investors and TIDZ users on investment structuring, construction documentation, land rights, regulatory compliance and procedures before the Directorate for Technological Industrial Development Zones.

June 2026 Amendment

The amendment was adopted on 11 June 2026, published in Official Gazette No. 132/2026 on 17 June 2026 and entered into force on the date of publication. Its substantive changes include the new Article 38-z regime, amendments to construction and production deadlines, grounds for unilateral termination of land lease agreements and related construction documentation rules.

The Former Technical Equipment Procedure Was Deleted

 

The 2025 framework referred to a procedure for confirming built structures, technical equipment and transferred, accepted or partially constructed structures whose legal status had not been determined within the zones. That framework appeared in Articles 34-a to 34-s of the Law.

The 2026 amendment deleted Articles 34-a, 34-b, 34-v, 34-g, 34-d, 34-gj, 34-e, 34-zh, 34-z and 34-dz in their entirety. The statement of the Law’s subject in Article 1 was also changed so that it no longer refers to confirmation of technical equipment.

Accordingly, the current Law does not provide the former general confirmation or legalization route for technical equipment. Photovoltaic power plants are not identified as a separate category under the new Article 38-z. Any pending or unresolved matter initiated under the deleted provisions requires individual review, because the 2026 amending law does not contain an express transitional rule preserving those proceedings.

Which Structures Fall within New Article 38-z

Article 38-z applies to structures built within zones by land lessees in zones established by the Government of the Republic of North Macedonia or by legal entities before 17 June 2026, provided that the structures were built on the basis of final building permits issued under the Law on Technological Industrial Development Zones and no permit for use was issued.

The procedure is therefore limited by the status of the applicant, the location and founder of the zone, the date of construction, the existence of a final building permit and the absence of a permit for use. It is not drafted as a route for equipment standing independently from a qualifying structure or for construction undertaken without a final building permit.

Construction Technical and Functional Whole

The Management Board of the Directorate may adopt the decision only if the structure represents a construction-technical and functional whole. This must be confirmed by a final report of a supervising engineer stating that the structure may be used as such.

If changes were made during construction without conducting the procedure for changes during construction, an as-built design certified by a supervising engineer must also be submitted. The supervising engineer must confirm in that document that the structure represents a construction-technical and functional whole and may be used as such.

Initiative and Required Documentation

The land lessee submits an initiative to the Directorate for conducting the procedure for registration of ownership in the Real Estate Cadastre. The initiative must be submitted within one year after the Law entered into force on 17 June 2026.

The initiative must be accompanied by the documents expressly listed in Article 38-z:

  • the final building permit;
  • the final report of a supervising engineer confirming that the structure represents a construction-technical and functional whole and may be used as such;
  • where applicable, an as-built design certified by a supervising engineer for changes during construction for which no procedure for changes during construction was conducted; and
  • a geodetic report from the completed survey of the structure.

Decision and Registration in the Real Estate Cadastre

The Management Board of the Directorate decides on the initiative. If the statutory condition and evidence are satisfied, it adopts a Decision on registration of ownership in the Real Estate Cadastre of structures built within the zones within 90 days from submission of the initiative.

The Decision, the final building permit, the final report of the supervising engineer, the geodetic report and evidence of payment of the registration fee constitute the legal basis for registration. Where there were unprocessed changes during construction, the certified as-built design is also required.

After adopting the Decision, the Directorate submits the application for registration of ownership, together with the supporting evidence, to the Agency for Real Estate Cadastre. The statutory procedure therefore begins with an initiative by the land lessee but the final cadastral application is submitted by the Directorate.

Related Construction and Land Lease Deadlines

The June 2026 amendments also link the 36-month deadline for construction of the structure and commencement of production to the date on which the building permit becomes final, rather than to conclusion of the land lease agreement. The deadline may be extended for no more than 12 months after expiry of the 36-month period by an annex to the land lease agreement, subject to prior consent of the Government and a request filed by the lessee no later than 30 days before expiry.

The land lease agreement is unilaterally terminated in the cases listed in Article 8, including where the lessee does not commence construction within nine months after concluding the land lease agreement, where the Decision for commencement of operation of the user is revoked, where the Agreement for conducting an activity with the user is terminated, or where the structure is not built and production does not commence within the applicable 36-month or extended period.

Article 33-d also confirms that construction by investors begins only after obtaining a final building permit. These deadlines and termination consequences should be reviewed separately from the special cadastral registration procedure.

Practical Checklist for TIDZ Land Lessees

  • confirm that the subject is a structure and not merely technical equipment;
  • verify that the structure was built within the zone before 17 June 2026;
  • confirm that a final building permit was issued under the TIDZ Law and that no permit for use exists;
  • obtain the final report of the supervising engineer using the statutory construction-technical and functional whole terminology;
  • prepare a certified as-built design if changes during construction were not processed;
  • obtain the geodetic report from the completed survey of the structure;
  • submit the initiative within the one-year statutory period; and
  • prepare evidence of payment of the cadastral registration fee for the registration stage.

Frequently Asked Questions

Can technical equipment still be legalized under Articles 34-a to 34-s?

No. Those provisions were deleted by the amendment published in Official Gazette No. 132/2026. The current special procedure in Article 38-z concerns registration of ownership of qualifying structures.

Does Article 38-z expressly cover photovoltaic power plants?

No. Article 38-z does not identify photovoltaic power plants or technical equipment as a separate qualifying category. Qualification depends on whether the subject is a structure satisfying every condition in Article 38-z.

Who may submit the initiative?

The land lessee for the relevant structure submits the initiative to the Directorate.

What is the filing period?

The initiative must be submitted within one year after 17 June 2026, the date on which the amendment entered into force.

Who adopts the decision?

The Management Board of the Directorate adopts the Decision on registration of ownership in the Real Estate Cadastre of structures built within the zones.

How long does the Management Board have to decide?

It must adopt the Decision within 90 days from submission of the initiative, provided the statutory conditions and evidence are satisfied.

Who submits the cadastral application?

After the Decision is adopted, the Directorate submits the application and supporting evidence to the Agency for Real Estate Cadastre.

 

Need Legal Guidance

If your company owns, leases or operates a structure or technical installation in a TIDZ, Lalicic & Partners can review whether Article 38-z applies, assess the effect of the deleted provisions on an earlier file and coordinate the required construction, supervisory and cadastral documents before submission to the Directorate.

ABOUT THE AUTHOR

Vedran Lalicic

Attorney at Law | Lalicic & Partners, Skopje, North Macedonia

Practice areas: Business and corporate law, investments, real estate and regulatory matters

Last updated: September 2026


Note: The above does not constitute legal advice and in no way can be accepted or understood as an instruction to act in a specific case. Each legal situation has its own characteristics that should be reviewed at separately, and for that reason we recommend that you contact a professional – a lawyer – for legal advice.