Among the pieces you commission for the file, two are well known and have already had articles of their own: the geotechnical study and the topographic study. On the same list sits a third, far less discussed, because it is new.
Where it sits, exactly
Article 265 covers the complementary documentation needed for the permit. These are pieces requested through the urbanism certificate, and obtaining or preparing them falls to the applicant. They are not things the designer produces at a desk; they are things you order separately.
Letter e) of the list is the report on the minimum requirements for a building with nearly zero energy consumption, which the code names the NZEB conformity report, or NZEB report for short.
Its neighbours on that list will be familiar: the geotechnical study at letter a), which we covered in geotechnical study or expert report, and the topographic study at letter d), covered in the topographic study.
What you will not find in the code
The code names it and places it in the procedure. It does not describe its content, does not say who produces it, sets no form and fixes no preparation period. The minimum requirements its title refers to live in technical regulations, outside the code.
It is the same pattern seen elsewhere: the obligation is in the statute, the measure is somewhere else. We wrote about the general effect in the forms changed, the websites did not, and about a cost case in the local infrastructure levy.
What you can do about it
Three things, in the order that matters.
Read the urbanism certificate as your shopping list. Complementary documentation is requested through it, so that is where an NZEB report will appear if it is required of you. If it appears and you do not recognise it, do not treat it as a drafting error.
Ask who issues it before you ask what it costs. For a new piece, the specialist’s availability is the real constraint, not the price.
And put it in the calendar early. A missing piece of complementary documentation does not delay you by a day; it blocks filing, and the review periods start only from a complete file. What happens to an incomplete file is described in after you file.
Why it is worth watching
Energy performance is the direction construction regulation is moving everywhere, and a file requirement introduced now, with no detailed content in the statute, is exactly the kind of requirement that gets filled in over the following years. The full list of pieces in the file is on the PAC page.
This article is analysis, not legal advice. The provisions cited are from Legea 169/2026, published in Monitorul Oficial no. 661 of 10 August 2026. Check your own situation with the issuing authority.