100% Completion Requirement: Real Safety or an Obstacle for the Housing Market?

More than a year has passed since the amendments to the Construction Law came into force, requiring that apartments can only be notarized and sold once a project reaches 100% completion. Market participants are now seeing the real consequences of this decision. The Lithuanian Real Estate Development Association (LNTPA) surveyed its members to understand how this regulation affects projects, buyers, and the overall market. The results show that what was intended as a safeguard for homebuyers often acts more as a barrier than a solution.

Longer timelines, higher costs

The biggest challenge reported by developers is project timelines. More than half of the respondents said their projects are now delayed by 3–6 months or longer. For buyers, this means moving in later; for developers, it means financing projects longer and at a higher cost.

Financially, the picture is just as clear. Most respondents reported project costs increasing by 5–10%, while some faced even higher overruns. Only a handful said they saw no financial impact.

LNTPA President Mindaugas Statulevičius emphasizes that these changes are hitting the market at the worst possible time:

“In today’s situation, where adequate housing supply is essential for ensuring affordability, time costs are critically important. Our survey shows that the 100% completion requirement before notarization does not always achieve its intended goal of protecting buyers. On the contrary – it makes projects more expensive and delays access to housing.”

Buyer behavior remains the same

Interestingly, homebuyers’ behavior has hardly changed. Most developers note that people still sign preliminary agreements or wait for full completion, but there has been no fundamental shift. This suggests that a rule meant to change market practice has not altered buyer expectations in practice.

Safety – more symbolic than real

Does the 100% completion requirement actually make buyers safer? Opinions are divided. Some respondents see it as necessary, but many argue that real risks have not been eliminated – instead, the rule has created new obstacles.

“Citus” lawyer Silvestras Sušickis highlights the paradox:

“In practice, 80–85% completion means the building is fully functional and buyers can already move in or start interior works. Yet a few centimeters’ deviation or bureaucratic delays can prevent registration at 100% for years. This requirement ‘punishes’ the entire market but does not necessarily protect buyers from real risks.”

The biggest obstacles – infrastructure and bureaucracy

Developers also point to specific technical challenges. To register a project as 100% complete, roads and utility networks must first be transferred to the municipality. Until this happens, the entire process is stalled – meaning buyers get access to their homes 6–12 months later than before.

Another challenge is staged neighborhood development. In such cases, the developer must bear a disproportionately high upfront cost for all infrastructure, while municipalities, despite collecting infrastructure fees, often fail to deliver their part of the works in parallel.

What solutions does the market propose?

Developers stress that instead of rigid formalities, buyers need real safeguards. Suggestions include:

  • Allowing projects to be registered as complete once compliance certificates are issued, with infrastructure transfers finalized afterwards;

  • Making municipalities more accountable for delivering infrastructure projects on time, to avoid blocking housing completion;

  • Introducing genuine buyer protection mechanisms in preliminary agreements – such as insurance schemes, escrow accounts, or deposit models – that would actually enhance security.

A discussion with the ministry – this autumn

LNTPA stresses that while the amendment to the Construction Law aimed for a worthy goal, in practice it has contributed to reduced housing affordability and longer project timelines.

The association plans to initiate discussions with the Ministry of Environment this autumn, in order to evaluate the regulation’s real impact and seek solutions that would balance buyer protection with market efficiency – ensuring safety without freezing the housing market.

Translated by ChatGPT