The Current Framework: As widely reported in the press, on 18 August 2025 the Hungarian Official Gazette published Government Decree No. 274/2025 (VIII.18.) amending Government Decree No. 143/2018 (VIII.13.) on the detailed rules governing the modification of building use. The amendments will enter into force on 17 September 2025.
As anticipated from earlier communications and the draft legislation released for public consultation (link to the draft), the amending decree extends the scope of the so-called Plaza Stop rules.
The Plaza Stop regime—introduced in 2011 and since amended multiple times—refers to a set of provisions spread across various legal sources, the essence of which is to subject the opening of large retail units to regulatory control through the building permit or change-of-use permit procedures.
Currently, the Plaza Stop applies to retail units with a gross floor area exceeding 400 m². The establishment of such units (whether through new construction or by converting an existing non-retail premises, such as an office, into a shop), as well as the alteration of existing retail units of this size, requires the prior approval of the Hajdú-Bihar County Government Office. This approval is granted within the framework of the building permit procedure in the case of new construction, and within the change-of-use permit procedure in the case of existing buildings. The latest amendment concerns this latter procedure.
Key Changes
The amending decree broadens the scope of situations requiring a change-of-use permit. In addition to the existing cases, a new permit must now be obtained by the new owner or occupier of a retail unit exceeding 400 m² gross floor area if:
a) the holder of an existing change-of-use permit transfers ownership or grants use of the unit, in whole or in part, for the purpose of establishment of a retail store selling daily consumer goods as defined in the Trade Act; or
b) the use of a unit exceeding 400 m² having an occupancy permit issued by the building authority is transferred by the holder of the occupancy permit in any form for the purpose of establishment of a retail store selling daily consumer goods.
The decree also clarifies that any subdivision, partition, or separation of a sales area within such a retail unit that results in a new, contiguous area intended for the operation of a store selling daily consumer goods must be regarded as a conversion requiring a change-of-use permit.
The Tightening Applies Only to Daily Consumer Goods Stores
Following the publication of the amendment, several press articles suggested that the new rules would impose a general permit requirement on all sales and lease transactions involving retail units over 400 m². However, such an interpretation is not supported by the official text of the decree.
The amendment applies exclusively to the establishment of stores selling daily consumer goods. Moreover, it is not the transaction itself (sale or lease) that is subject to authorization, but rather the change in use.
For example, if the owner of a 400 m²+ retail clothing store sells the unit and the new owner continues to operate it as a clothing store—or as another outlet for durable consumer goods—no new change-of-use permit is required. By contrast, if the former clothing store is, in whole or in part, converted into a supermarket, drugstore, or other daily consumer goods store, a permit must be obtained. Importantly, the requirement applies even if the newly created daily consumer goods retail area is itself smaller than 400 m².
Reports of a more drastic tightening most likely stem from the fact that the draft decree initially proposed during public consultation did indeed require a new change-of-use permit in case of any sale or lease of affected retail units, irrespective of the type of goods sold. While the final version adopted by the Government is more lenient, it cannot be excluded that the legislator may in the future further expand the scope of transactions subject to the plaza stop regime.