What is an unauthorized structure
Under Article 188 of the Civil Code, a structure is unauthorized when it was built without the required permit or with a material deviation from approved urban-planning documents. The mere presence of a structure on land does not create ownership or lawful-use rights.
The registration window open until 31 December 2026
The transitional rules of the law on the legal status of unauthorized structures allow information and documents for certain structures whose earlier deadline was missed to be submitted to the Cadastre Committee until 31 December 2026.
For privately owned land, the structure must appear in 2021 orthophotoplans or photographs from the same period. For state or community land, this condition does not apply in the same way, but the other statutory requirements remain.
- For multi-unit or subdivided buildings, the file should include photographs showing all sides and floors, a qualified professional’s conclusion and the owner’s written declaration about the construction date.
- The file is submitted under the registration procedure set by the Government.
- The deadline for this transitional route is 31 December 2026.
How registration works
The process usually starts with a qualified measurement professional:
- 01the land and structure are measured and the document package is prepared;
- 02between 4 and 6 colour photographs clearly showing every side and floor are attached;
- 03the package is reviewed, agreed and signed;
- 04the professional uploads the data to the online measurement office;
- 05under the 3.1 mechanism, a measurement code is generated; the Cadastre then reviews the package, confirms it or refuses it and sends a notification.
Registration is not legalization
A measurement code or recording information with the Cadastre means that the structure’s data has been submitted and reviewed. It is not registration of ownership and it is not legalization. Legalization requires a separate decision and compliance with all statutory conditions.
Until legalization, construction of an unfinished unauthorized structure may not continue, except within the special route expressly provided by the new law.
A new route for structures built later
The 2026 amendment under Law ՀՕ-331-Ն allows fully unauthorized structures on privately owned land, including structures built after the earlier deadlines, to be registered and submitted to the Ministry of Territorial Administration and Infrastructure for inclusion in a Government list. Materials may be submitted until 30 December 2027.
This route is not automatic legalization. A structure may be legalized only after it is included in the Government’s approved list and the required procedure is completed. The list must be prepared by 20 February 2028.
- a measurement code;
- a positive technical conclusion from a licensed provider covering structural condition, load-bearing reliability and strength, seismic safety and safe use;
- a positive fire-safety conclusion from the competent urban-planning, technical and fire-safety inspection body;
- a preliminary written assessment by the competent legalization body confirming no material urban-planning violation, infringement or danger to third-party, state or community rights, and no ground for refusal.
Demolition risk from 30 August 2026
Under the amendments to Civil Code Article 188 introduced by Law ՀՕ-405-Ն, unlegalized unauthorized buildings and attached structures on private land (except common shared property) may be subject to demolition or dismantling. The owner must restore the land at their own expense when the community head or an authorized official issues a written demand.
The period stated in the demand is generally one month after receipt, unless a longer period is set. For state or community land and common shared property, the competent authority makes the decision.
What to do now
- 01Confirm who owns the land and approximately when the structure was built.
- 02If the structure appears in 2021 materials, prepare and submit the registration package by 31 December 2026.
- 03If it was built later on private land, assess the new special route and monitor the Government’s implementing acts. An e-draft publication is still only a draft, not an effective rule.
- 04If the structure is unfinished, do not continue construction until its legal status is clear.
- 05If you receive a written demolition demand, have its legal grounds reviewed without delay.
FIAK · Support
A professional assessment of your structure’s status
FIAK reviews the land and structure documents, identifies the applicable route and deadline, helps collect measurement and technical materials, prepares the submission package and supports communication with the Cadastre and the community. If a written demolition demand is issued, we review its legal basis and outline next steps.
Get an individual legal assessmentThis article is general information and does not replace advice on a specific case. Requirements should be checked as of the filing date.