Big changes ahead in Slovenia's administrative procedures: the ZUP-I amendment explained

On 23 October 2025, the Slovenian National Assembly adopted a far-reaching update to the General Administrative Procedure Act (Zakon o splošnem upravnem postopku; "ZUP") – the ninth amendment, known as the ZUP-I amendment. Aimed at increasing efficiency and modernising administrative processes, the reform significantly reshapes how decisions are issued, communicated and challenged. The amendment will enter into force three months after its publication in the Official Gazette of the Republic of Slovenia, allowing parties a transitional period to prepare for the new procedural landscape.

The ZUP-I introduces key changes affecting document service, procedural deadlines, decision-making formats and exercise of legal remedies. While its primary purpose is to simplify interactions between administrative authorities and parties, the amendment also introduces new procedural nuances that parties will need to navigate carefully.

Below, we outline the main novelties and their practical implications for participants in administrative proceedings.

Mandatory electronic service for business entities and other key changes to document service

One of the most impactful changes concerns document service. Under the new regime, electronic service becomes mandatory for business entities, including companies, public institutions, attorneys and other professionals, regardless of prior consent. For natural persons, it remains optional and subject to having a registered electronic address.

While the Slovenian Ministry of Digital Transformation will provide free access to a secure electronic mailbox system for all business entities registered in Slovenia, the new system is complex. Businesses can also use their own electronic mailboxes or update their service addresses through official registers. The mandatory switch to electronic service will only begin once technical conditions are fully ready and announced in advance, but the transition may require procedural and technical adjustments within organisations.

The amendment also shortens the presumption of service period (from 15 to seven days) and slightly extends deadlines for appeals (see below), altering how procedural time limits are calculated.

Rules on physical mail service will also change. Documents that do not require personal delivery will be placed directly in mailboxes. Personal delivery will be rare, used mainly to prevent intentional avoidance; if unsuccessful, the documents will be left in mailboxes along with a notice of service.

Although these changes may seem straightforward, in practice, they affect critical timings and rights within administrative processes.

Greater flexibility in oral hearings

Authorities will now decide case-by-case whether an oral hearing is necessary, even in matters involving opposing interests. Hearings can also be conducted remotely (via videoconference) and recorded, reflecting a broader digitalisation trend.

A completely new concept, the "presentation hearing", has also been introduced. This allows the authority, particularly in complex or multi-party cases, to present the key factual and legal issues before deciding the matter. How – and how often – this tool will be used in practice remains to be seen. It may, however, prove particularly relevant in environmental, construction or competition-related proceedings, for example.

While these measures aim to streamline procedures, they also give authorities greater discretion, making it increasingly important for parties to understand when and how to request a hearing to safeguard procedural rights.

New option: informative decisions

ZUP-I also introduces a new procedural tool called the "informative decision". This allows authorities to issue a preliminary decision when the facts are clear; however, before the decision becomes final, the party must be given an opportunity to respond. If the party does not object within 21 days, the procedure may be concluded without a separate final decision, potentially speeding up the process.

Practically, this means two procedural steps – giving a chance to respond and issuing the decision – are combined, saving time if there is no dispute. But if an objection is filed, the authority must continue, possibly delaying the outcome.

This approach is entirely new in Slovenian administrative law, and its real impact will become clear only in future practice. However, properly recognising an informative decision and reacting within the prescribed deadline will be essential to avoid losing procedural opportunities.

Administrative decisions without reasoning

Authorities may now issue decisions without reasoning in procedures initiated at a party's request, if the request is fully granted and no one objects. A party can, however, request a reasoned version within 15 days; the authority must then provide it within eight days.

This simplification aims to accelerate the decision-making process but also raises complex questions concerning appeal rights and the position of affected third parties who did not take part in the proceeding.

Extended deadlines for issuing decisions

Under the ZUP-I amendment, authorities can now extend the standard two-month deadline for issuing a decision by up to an additional two months, citing complexity or other justified reasons. This applies to both first- and second-instance procedures. The extension requires only notification to the party, meaning that no formal decision is issued, and the extension itself cannot be appealed.

For parties awaiting administrative decisions, this change brings greater uncertainty about timing and fewer ways to challenge delays. Knowing how and when these extensions may occur (and how they affect the case) will be key to managing expectations and protecting parties' interests.

Importantly, the starting point for counting the deadline has also changed: it no longer begins when the party's request is complete, but rather from the day the authority receives the request, even if the request is incomplete.

Updated rules on legal remedies

The ZUP-I amendment also introduces several updates to how legal remedies are exercised. The deadline for filing an appeal is extended from 15 to 21 days, reflecting the shorter period for presumption of service. Another important novelty allows parties to irrevocably waive their right to judicial protection in administrative dispute, allowing decisions to become (judicially) final earlier than before.

While potentially beneficial for quicker finality, such waivers must be approached with caution. A premature waiver could prevent judicial review even in cases where later challenges might have been justified.

In conclusion

The ZUP-I amendment represents one of the most comprehensive overhauls of Slovenia's administrative procedures in years. While the stated goal is greater efficiency, the new framework introduces layers of procedural complexity and discretion that will take time to interpret consistently in practice.

Understanding how these changes interact – and how they affect procedural rights, timing and available remedies – will be critical for anyone engaged in administrative proceedings. As the new rules begin to apply, careful monitoring, timely reactions and well-informed strategy will make the difference between smooth navigation and costly procedural setbacks.