Nine Key Changes To The Administrative Procedure Code

Nine key changes to the Administrative Procedure Code

On December 17, 2025, Law No. 241-VIII was adopted, introducing amendments to the Administrative Procedure Code (APC), the Civil Procedure Code (CPC), and the Code on Administrative Offenses. The amendments came into force on December 29, 2025.

1.Challenging subordinate legislation in the APC

Cases challenging subordinate legal acts (SLAs) have been transferred from the CPC to the APC.

• New type of claim: challenging the legality of SLAs or its individual provisions (Art. 135-1 APC).
• Time limits for filing a lawsuit: within three months from the date when the plaintiff became aware of the violation or possible violation of his rights by the act (part 3-1 of Article 136 of the APC).