Service charges due by the 10th: recording advances and votes after bill UD312
On 18 August 2026 Infor described bill UD312: utility advances and waste fees by the 10th of the month, meters as common property, electronic voting, and the management report due by the end of April. Version 2.0 sat in the government’s work list on 17 August. A managing agent needs a register that can hold those fields before the text reaches the Journal of Laws.
On 18 August 2026 Paweł Huczko in Infor set out the draft amendment to the Act on Ownership of Premises: New rules for housing communities in 2026, or only in 2027?. The day before, 17 August 2026 at 11:59, version 2.0 of bill UD312 appeared in the government’s list of work. Edyta Kurkiewicz published it. The responsible body is the Minister of Finance and the Economy; the official named on the file is under-secretary of state Tomasz Lewandowski.
It is still a bill. Infor states plainly that adoption by the Council of Ministers in the second quarter of 2026 did not happen, and on 18 August the text was before the Standing Committee of the Council of Ministers. The card on the Chancellery of the Prime Minister’s site gives the planned adoption date as the third quarter of 2026: Draft Act amending the Act on Ownership of Premises. The number in the Government Legislation Centre is UD312. Entry into force — 30 days after promulgation, with a few exceptions described in the draft. That is not a date in your bookkeeper’s calendar until there is a Journal of Laws number.
In an agency that runs twenty communities or a hundred, waiting for promulgation does not fix the spreadsheet that already fails to tie the heating advance to the reserve-fund resolution and the water-meter verification date. The bill adds a duty to pay, by the 10th day of each month, advances on utilities settled through the community and the charge for municipal waste. It provides that heat meters, water meters and radiator heat cost allocators form part of the common property. It introduces electronic circulation of notices and votes. It extends the deadline for the management report to the end of April. A register of community charges and resolutions has to keep those items against the unit, the share and the date, not in an e-mail thread from three years ago.
GESOFT — Paweł Matusiak, Laravel, Vue, Android — does not replace KSeF, the e-Delivery mailbox, your accounts package or the PINB register. We build a panel beside what you already use: units, shares, advances, meters, resolutions, requests to enter a flat, the meeting minutes. If an off-the-shelf SaaS product for managing agents will do, we will say so. If you have your own tables, a few communities still bound by a notarial management agreement, and a portal residents do not open, we send a quote in 24 hours via contact. To start we need: how many communities, how many units, which invoicing package, and whether you still collect votes on paper. We do not switch off a working programme for the sake of a new system. We add what the package does not have, and we leave the accounts software where it already counts.
Bill UD312 on the government’s work list on 17 August 2026
The card was first published on 19 September 2025. The title then spoke of amending the Act on Ownership of Premises and the Construction Law. Version 2.0 of 17 August 2026 has a wider title: amendment of the Act on Ownership of Premises and certain other acts. The aim on the card is specific. It is to bring community practice into line with thirty years of case law, managing agents’ work, multi-family building technology and other statutes that communities already apply, while the Act of 24 June 1994 does not keep up.
The ministry lists a dozen gaps on the card. The Act does not say which parts of a balcony are common. The definition of a community as a “statutory person” under Article 331 of the Civil Code leaves a dispute in the literature. The community has no standing of its own today to claim warranty for defects in the common parts, so it collects assignments of claims and almost never collects a hundred per cent of them. You cannot raise the housing advance when the way a unit is used generates extra cost. There is no duty to admit a team for an installation inspection under the Construction Law. It is unclear who owns the water meter. The utility advance has no statutory due date. There is no definition of ordinary management and no notion of a reserve fund.
Infor repeats those points and adds a timetable. The rules are to enter into force 30 days after promulgation. Management agreements under Article 18(1) remain in force for the period for which they were concluded; changes to them are to follow the new rules. The rules on separating premises in collective-residence buildings do not cover buildings completed before 1 January 2027 or those with a final building permit before that date. The community’s warranty standing and owners’ subsidiary liability are also to apply to situations that arose before entry into force. We do not load that into the register as “in force today”. We record the status: bill, committee, Sejm, Journal of Laws.
For your firm with a book of communities in three cities, that card is a list of fields, not an essay on deregulation. If the panel has no verification date for a full set of water meters, you will not count how many replacements will land in the first season after promulgation. If the reserve-fund resolution sits in a PDF scan with no amount and no account number, you will not separate operating money from reserve money when the Act requires that split. The existing software for property managers covers faults and walk-rounds. Here you need a layer a spreadsheet will not hold: the 10th, the meter as a common thing, a vote sent by e-mail, and a report that must be in writing by the end of April.
Utility and waste advances due by the 10th of the month
Today the statutory due date of the 10th applies to advances for the costs of managing the common property. Advances for heat, water, sewage and waste are usually written into the community’s settlement rules. Those rules can be challenged in court. The bill would move the due date into the Act: by the 10th day of each month the owner pays advances on utilities settled through the community and the charge for collection of municipal waste. Infor quotes the ministry: the community is the party to the supplier contract, so the money has to arrive before the issuer sends the invoice for the building.
In practice, on the morning of the 11th the bookkeeper opens a list of 64 units. Twelve have not paid the heating advance. Three have a credit from last season’s correction that nobody allocated to the new month. One unit is being sold and the notary asks for a certificate of no arrears. If the register holds a single amount called “rent”, you cannot separate a statutory utility arrears from a voluntary contribution to CCTV. The reminder goes out too vague. The owner replies that they “did pay 800 zloty”. They did. Into the reserve fund. Heating still stands.
A panel that can carry this keeps, against each unit at least: the share, the operating advance rate, the heating, water and sewage advances, the waste charge, balances, the date money arrived, the transfer reference and the resolution number from which the rate is taken. Separately — an individual contract with the water company, if the unit has one; then the meter does not go into the community pool. The bill leaves that exception. Without a flag on the unit card someone in the office will drop that unit into a bulk meter replacement and take a complaint that cannot be closed by e-mail.
We do not invent penalties for paying on the 11th. The bill is silent on a new fine for that. The effect is operational: the community has no money for the supplier’s invoice, and under subsidiary liability — more on that below — the community’s debt, after unsuccessful enforcement against it, falls on owners according to their shares. Your register has to show who failed to pay by the 10th, how much and under which heading, before the chair of the community rings to complain that “the system did not watch”. The system watches the date. The call to the debtor still belongs to the agency or to a board member.
Meters, water meters and allocators as common property
The bill provides that heat meters, water meters and radiator heat cost allocators form part of the common property. Upkeep — installation, replacement, official verification, servicing, repairs and cost — rests on the community. The owner may not interfere with those devices. The exception: an individual contract with the water and sewerage undertaking that itself names the owner of the meters. The ministry explains that the devices serve to settle the cost of the whole building under a contract to which the community is party, not only consumption in one flat.
Today most communities treat the water meter as belonging to the unit. The owner buys it, replaces it, has it verified. The community has no hard basis for imposing the same type of device throughout a riser. Verification dates drift by a year. One unit has an old mechanical meter, the neighbour a radio clip-on, and the water bill for the building still comes as one invoice. Disputes over the cost of verification end up in court. Infor repeats the ministry’s view: the system works when the devices are of the same class, fitted at the same time, in line with the manufacturer’s instructions and under the manager’s supervision, and verification runs in parallel.
In the panel the device card needs fields you will not keep in “notes on the unit”. Type (cold water, hot water, heat meter, allocator), serial number, installation date, verification date, next due date, contractor, report, cost against the reserve or operating fund, a flag for “individual water contract”. Plus — refusal of access. If the owner will not let the team in, you record the date of the request, the basis (installation inspection or replacement) and whether it went by e-mail, ADE or letter. After the Act, when the duty to admit people to the unit arrives, that entry is evidence of persistence, not of the administrator’s temper.
The community is not a metrology laboratory. We do not replace official verification or the Central Office of Measures. The register has to say in which week the stamp expires on 40 water meters in stair B, what the quoted cost in the resolution is, and whether units with individual water contracts dropped out of the tender. If those dates live in the plumber’s notebook today, the first settlement season after promulgation will come apart around the units nobody could enter. That is not a “digital transformation” problem. It is the lack of one list.
When you replace a whole riser you also record the resolution number that opens the spend, and whether it is the reserve fund or operating money. Fitting 40 devices is usually the reserve or a special-purpose fund, not “day-to-day keeping of the thing in an unimpaired condition”. If after the amendment someone on the stair challenges the board for exceeding ordinary management, the panel must show the resolution and the quoted amount. The fitting report — date, serial numbers before and after, the team’s signature — sits against the stair, not in the plumber’s mailbox, who will have changed firms in a year. When winter consumption comes out crooked, the first question will be whether all stamps were valid in the same period. The answer has to come from the device card, not from memory.
The reserve fund and a higher advance for the way a unit is used
The Act is silent today on a reserve fund. Communities run one anyway, each under a different label. The bill introduces the notion of a reserve fund or another special-purpose fund created by resolution. It is to be community property, not the owners’ individually, separate from operating money from which day-to-day bills are paid. In the register you need two balances per unit and two for the community: operating and reserve. A transfer marked “rent” with no heading stays in a queue for clarification; you do not guess which account it fell into.
The second change is about raising the advance. Today you cannot raise the housing advance when the way a unit is used generates extra cost for the community. The bill would extend that to every unit in the community. The test: extra costs arising from the way the unit is used. The burden of proof sits on the community — a calculation and a resolution that raises the monthly advance for a named owner. You do not write “because of Airbnb”. You write line items: waste above the standard rate, more frequent cleaning of the stair, water used in common parts with short-stay turnover, if you can prove that from invoices.
In an agency that has a building with three short-stay units on the book, that resolution will fail at the first challenge if the panel has no calculation attached. Fields: basis for the increase, amount, period, resolution number, date of service on the owner. Separately — whether the unit has a registered business. GIS and the municipality do not keep that for you. You keep the resolution and the figures. If you cannot prove the cost, you do not raise the rate “just in case”. The bill does not reward that. It rewards a document.
A special-purpose fund for a lift replacement or for thermal modernisation also needs its own resolution and its own account, or at least an analysis code in the accounts package. GESOFT does not keep the books. From the panel a file should go to the bookkeeper: payments into the fund, spending under resolutions, units in arrears. The existing software for a housing community describes advances and a residents’ portal. After UD312 you need a split that owners will watch at the April meeting, because the report must be in writing and must have a financial part.
Access to a unit for installation inspections and for emergencies
The bill places on the owner a duty to give access for periodic and ad hoc inspections of installations under the Construction Law, and a duty to carry out post-inspection recommendations. If the owner persistently refuses, the board or the managing agent may apply to the building inspectorate for a fine. The Construction Law is to gain a basis for that fine. Separately: a duty to admit people in the event of a breakdown causing damage or threatening damage, or where the way the unit is used threatens the sanitary or fire safety of the building. On refusal — entry with police or fire-service assistance.
Today the administrator stands at the door with an Article 62 Construction Law report and comes back with a note “not found in”. After three failed attempts the gas inspection on the riser stalls. The neighbour downstairs has a hob nobody has looked at for years. The bill does not tell you to force the door. It tells you to have a request, a date, a legal basis and — once the Act is in force — a path to PINB. The register will not do the inspectorate’s job. It has to show that the request went out, to which address, how many times, and whether the owner replied.
In the panel an “access to unit” case is not a fault ticket. It is a separate type: periodic inspection, ad hoc inspection, emergency, sanitary risk, fire risk. Fields: unit, installation (gas, flues, electrics, ventilation), planned date, contractor, result of the request, post-inspection recommendation, deadline, whether the recommendation was done. In an emergency — time of report, whether the fire service was called, whether the door was opened with assistance. You do not drop that into the crew’s chat. After the heating season the owner will say nobody told them. An e-mail from the panel with a date and the text of the request ends that conversation faster than the caretaker’s recollection.
We are not painting eviction-film scenes. Police assistance is a last resort described in the bill, not a daily process. Your job is to stay short of it: two requests with notice, a choice of hours, a note of a contact person. If the unit is empty because the owner lives abroad, the card should hold an electronic delivery address or an e-mail, which the bill will treat as equal to writing. Without that you still send a recorded letter. An e-mail with no read receipt does not replace ADE, but in a dispute about “I did not know the date” it is better than nothing.
A post-inspection recommendation — leaking flue pipes, for example, or no chimney inspection — gets its own deadline and status in the panel: open, done, overdue, referred to PINB. An owner who let the team in and then did nothing about the recommendation is a different state from the one who bolted the door. The bill speaks of a duty to carry out recommendations. A register that only has “access: no” will not handle the second half of the duty. An agency with a single checkbox “problem with the unit” will mix gas, noise and an unpaid advance. The building inspector will take a case about an installation. They will not take a bag of three topics.
Resolutions, collecting votes and electronic circulation
Today a resolution is passed by an absolute majority of shares, counting every share in the property, not only those that voted. The bill leaves that threshold for resolutions taken solely at a meeting. For individual collection of votes — including a mixed mode, part in the room, part by circulation — an ordinary majority of the shares of owners who took part is to suffice. The community sets the voting deadline itself, with a statutory minimum of two weeks and a maximum that Infor does not quote as a number of days, other than that a maximum is also to sit in the Act. After the deadline you count who voted.
That changes the sheet where you currently keep “for / against / abstain” and wait until you have more than 50 per cent of all shares. On circulation under the new rule you may close a resolution when a majority of those who voted (by share) is “for”, even if half the stair never sent the card back. At a meeting in the room you still need an absolute majority of the whole. The register must distinguish the mode: meeting, circulation, mixed. Otherwise someone on the board will announce a resolution that, in “room only” mode, never existed.
Electronic circulation is to be equal to writing: notice of the meeting, the text of resolutions passed, votes in circulation. Notice of the meeting — also to ADE or e-mail. The notice period lengthens to two weeks; the present week, the ministry writes, often makes attendance impossible because a recorded letter does not arrive in time. Owners with at least one-tenth of the shares may convene a meeting themselves if the board fails to do so on their request. The agenda of a meeting convened on request is to include draft resolutions tabled by the owners.
In the panel a vote is a record: person, share, channel (room, paper, e-mail, portal), the text of the resolution in the version voted on, a timestamp, whether the vote arrived in time. After two weeks the system totals the voting shares and — on circulation — checks whether an ordinary majority of those who voted is enough. It does not count heads. It counts shares. A 120 m² unit is not the same vote as a studio. If you currently collect scans on WhatsApp, after the Act the first challenged circulation will show that you do not have the version of the text someone clicked “for”. A residents’ portal with the text locked once voting starts is cheaper than a court case.
The management report by the end of April and owners’ access to documents
The bill requires the board’s or manager’s report to be in writing, to describe the year’s work and to include a financial part. The deadline moves from the end of March to the end of April. The reason on the card: suppliers’ invoices arrive at the beginning of the year, and finding a room and a full set of people for the meeting also eats time. For an agency with forty meetings in March that extra month is real. It does not mean you can “somehow file” in May. It means you have four more weeks for the figures, not for putting it off.
Owners are to have a right to inspect the community’s documents, and the board a duty to give the information requested. Today that scope is blurry and lands in court. After the amendment you refuse inspection only where GDPR or correspondence privilege actually covers a third party’s data, not where “we do not have a scan”. A document register: resolution, invoice (KSeF number if the invoice arrived that way), supplier contract, meeting minutes, request, tender offer. Disclosure — a log: who asked, when, what they received, in which file. You do not publish other people’s proof of payment on a shared drive.
The financial part of the report will not appear in Word from memory. It will come from the same balances you use for reminders on the 11th. If operating money and the reserve sit in one column, the April meeting will end in a row about whether the roof ate the heating advance. The article on software for a housing co-operative shows the same problem with resolutions and utilities in a co-operative. In a community after UD312 there is a statutory duty of written form. A scan of the meeting slides is not a report.
In practice you set a recurring task in the panel: by 15 April a draft with the bookkeeper, by 22 April with the board, by 30 April with the owners together with the meeting notice if the meeting is in May. You count the two weeks’ notice back from the date of the room. If notice goes by e-mail, the server timestamp stays against the unit. If someone has no e-mail, a letter remains. A mixed channel is fine, so long as the register shows which channel went to whom.
Two forms of management and the definition of ordinary management
The bill is to leave two routes: a resolution appoints a managing agent within the meaning of the Real Estate Management Act, or it appoints a board of natural persons. The management agreement concluded unanimously by all owners, and the notarial form for every change, are to go. The ministry writes that a notary blocks circulation and is an unnecessary cost. Agreements already concluded under Article 18(1) are to remain for the period for which they were made. Changing them — under the new rules.
In an agency’s book some communities have such an agreement from the developer. In the register a flag Article 18 agreement with a date and a scan of the deed. While it lives, a vote on changing the manager follows its procedure. After notice or the end of the term — a resolution under the new Act, without a notary at the table. You do not burn that agreement in the panel “because deregulation is coming”. You watch the date. The first community whose agreement you end a year too soon will come back with the developer’s lawyer.
Ordinary management is defined in the bill as day-to-day matters of ordinary use and keeping the thing in an unimpaired condition within its current purpose. That the board or the manager does alone, without a resolution. The rest — a resolution. The lack of that definition, the ministry writes, pushes communities into competence disputes. In the panel, against a payment, a flag: ordinary management or requires a resolution. A value threshold, if the community has resolved one, too. Otherwise a plumber’s bill of 900 zloty will pass, and 12,000 for a riser will draw a claim from the stair that the chair exceeded their powers. The validity of an obligation, the ministry recalls, depends on proper representation.
On a multi-member board, external representation is to go by a majority of members, not as today by two. The point is to stop two people in conflict from binding the community without the rest of the board. Decisions — in any form, including telephone and e-mail, without a sitting. For evidence in more important matters a note or an e-mail confirmation will do. Keeping those e-mails against the supplier contract is cheaper than testimony two years later. A court-appointed compulsory manager is to carry out ordinary management alone; the rest — an owners’ resolution or the court’s leave. A compulsory manager flag on the community card changes which buttons in the panel are live.
Balconies, warranty claims and community assets in the register
The structural parts of a balcony, loggia and terrace — girders, the slab with its insulation, the railing, fragments of the façade — are to be common property. The inner space of the balcony — part of the unit. The ministry notes that whether the whole or only part is common will turn on layout: a balcony used as a walkway is a different story from a loggia attached to one flat. Today you go to a Supreme Court judgment for the particular building. After the amendment the unit card has a flag: private balcony / common walkway / façade ornament. The cost of waterproofing the slab cannot fall “on the owner of 12/5” if the slab is common.
The community is to gain standing to pursue warranty claims for defects in the common property, by bringing an action for the owners. Rights the owners acquired in the purchase deed remain. Today the community collects assignments and almost never collects them all. The bill is meant to ease that. In the register a court case: the defect, the expert report, whether the community, the owner or both are suing, the resolution number for the cost of lawyers. GESOFT is not a litigation firm. The panel must not lose who signed an assignment under the old law when the new Act allows you to proceed without a hundred per cent of signatures.
The definition of a community: an organisational unit without legal personality, with capacity to perform legal acts and with its own assets tied to management of the common property. That is the Supreme Court’s position in the resolution of 21 December 2007, III CZP 65/07, written into the Act. The assets comprise money from advances, income from the common parts and rights under contracts; in theory also real estate bought with the owners’ consent. In the panel the community’s bank accounts cannot be the agency’s accounts. Once subsidiary liability arrives — enforcement first against the community’s assets, then against owners according to shares — mixing accounts is a gift to the bailiff.
Subsidiary liability is also to apply to obligations from before entry into force if the community cannot satisfy the creditor. We do not invent percentages or amounts here. In the register, against a supplier contract, you see the party (the community), the balances and — when enforcement appears — a note that it went against the community, not straight to the woman on the third floor. A certificate of no arrears for a notary counts the unit’s debt to the community, not the community’s debt to the heat supplier. Those are two different balances. Anyone who keeps them in one row will issue the notary a paper that will not survive the buyer’s question.
What the administrator enters in the panel two weeks before the meeting
Take a community of 36 units, 1,000/1,000 shares, an ordinary meeting in the third week of April 2027, if the Act makes it into force in autumn 2026. Two weeks earlier the notice must be with the owners. In the panel you create the meeting: date, time, room or link, agenda, draft resolutions in files that do not change once voting starts. The system sends the notice by the channel on the unit card: ADE, e-mail, letter. A log remains. If one-tenth of the shares tabled their own drafts, they go on the agenda. Not “we will add them in the room”.
The bookkeeper closes the financial part. From the accounts package comes a statement: operating advances paid and overdue, the reserve, utilities to the 10th for March and April, suppliers’ invoices — preferably with a KSeF number, because from 2026 the community receives them that way anyway. We do not replace KSeF. We store the number and the date so the financial part of the report is not “heating invoice, sometime in April”. The administrator attaches the meter table: how many stamps expire this year, how many units refused the team, how many individual water contracts. The board reads the draft. Someone adds a sentence about the car-park warranty if that case is live.
Three days before the room you make an attendance list with shares. Quorum to open the meeting is a separate thing from the majority on a resolution; we do not quote the bill here beyond what Infor and the card give. In the room you vote those resolutions that are to go by meeting mode — the ones for which you need an absolute majority of all shares. The rest, especially housekeeping, you may put into circulation with a two-week deadline. After the meeting: minutes, the list of votes, scans of powers of attorney. The portal receives the text of resolutions passed. An owner who was not there does not ring to ask “what did you pass”. They see the file.
If the meeting is about dismissing the manager, and the board does not convene despite a request from one-tenth, the owners convene it themselves. In the register that request has a date of receipt, the sum of the requesters’ shares and a note that the board did not convene in time. Otherwise a dispute about who had the right to open the room will eat half a year. Off-the-shelf SaaS with a “annual meeting” template will not fix that. A 1/10 request field and a block that will not let you ignore it without a note will. When your package does not have that, you add your own or you change programme. We do not burn a working system as a matter of principle. We add the missing case type.
Monday the 11th in a managing agent’s office
The 11th, 8:40. The bookkeeper opens community “Klonowa 4”, 42 units, 1,000 shares. The register shows that by midnight on the 10th, 37 transfers arrived for operating costs, 34 for heating, 40 for waste. Water is a mess, because three units have individual water contracts and should not be in the bulk advance. The system should flag them. If it does not, the bookkeeper strikes them off the reminder by hand and loses an hour. The reminder to five units goes out with the heading split: operating 210 zloty, heating 180, waste 42. Not “please pay 432 zloty rent”. The owner of 12/3 paid 432 zloty with the reference “rent” — the panel leaves that in a clarification queue; it does not guess the reserve fund.
At 9:15 the plumber from the quote under resolution 6/2026 asks which units on stair B let the team in on Friday. On the device cards: 18 water meters with a stamp until November, 4 refusals of access with a request dated 2 September, 2 units with individual contracts excluded from the tender. The administrator rings 12/8. The owner is at work until 17:00. They enter a new slot for Wednesday 7:30 and send confirmation to the e-mail on the card. Not to a board colleague’s private Gmail. If after UD312 the duty to give access arrives, that log is the start of documenting persistence, not spite. For now it is simply the only way to stop the team driving a third time to an empty door.
At 11:00 a notary asks for a certificate of no arrears for 8/2. The register shows zero arrears of the unit to the community and, at the same time, the community’s arrears to the heat supplier for August, because two large units did not pay heating. Those are two balances. The certificate for the buyer concerns the first. The second stays in the “supplier” file. If they sat in one row, you would issue a paper the notary will undermine after a call to the board. An agency that also runs communities with advances and a portal knows that call. The difference after UD312 is that the 10th for utilities will stop being “our rules” and become statute. A reminder dated the 11th will carry a different weight in a dispute, even without a new fine in the bill.
In the afternoon the chair of the community sends a scan of a resolution from the last meeting, because “the system has different wording”. You check the hash of the file locked on the day voting started and the list of votes with shares. The wording matches. The chair’s scan has a ballpoint note in the margin that nobody voted on. You leave the panel version as the operative text, the chair’s scan as a “non-binding” attachment. It is a small thing that, on a challenge to a reserve-fund resolution, is the difference between “we have the text that was voted on” and “we have a sheet from the meeting”. The register of community charges and resolutions closes that day with a list: 5 reminders, 1 new meter appointment, 1 certificate, 0 changes to resolution text after the fact.
A late vote, a refused meter and notice to the wrong address
A vote that arrived on day 15, with a 14-day deadline from dispatch, does not enter the total. The panel accepts it as late and shows it in the report, but does not add the share. The owner will write that “the e-mail arrived late”. You check the notice-dispatch log and the voting-start log. If notice went two weeks earlier and they opened the portal on the last night and sent the vote after midnight, they stay outside the majority. You do not interpret the “spirit of the Act”. You count the date. The bill requires communities to set the deadline themselves, with a two-week minimum. Your register holds that deadline in the resolution, not in the agency’s habit.
Refusal to replace a water meter: a second request, a third slot, the owner writes that “it is their meter and they will have it verified themselves”. Today, under the old law, the dispute about who owns the device is genuinely open. Once UD312 is in force the answer is in the Act: a common device, interference forbidden, exception only for an individual water contract. On the unit card you check that flag. If there is no contract, you follow the access path — requests first, then, when the Act gives a basis, PINB. You do not throw police assistance at it at once. Assistance in the bill is for emergencies and danger, not for a metrology stamp. Mixing those modes in the panel (one field “problem with the unit”) will produce a request the inspectorate will not take.
Notice of the meeting went to an e-mail the owner changed a year ago and never reported. A letter to the land-register address arrived. In the register two channels: electronic — failed delivery, paper — effective. The bill will equate e-mail with writing, but it does not tell you to trust a dead address. After two failed electronic deliveries the unit card should fall back to letter, before someone challenges the meeting with “nobody notified me”. ADE, if the owner has one and has given it, is more reliable than an inbox from 2019. We do not run the BAE for the Minister of Digital Affairs. We record what the owner indicated, and the date they indicated it.
A proxy at the meeting with a document from three years ago and no end date: on the powers-of-attorney card a flag “until revoked” or a date. A proxy’s vote without a valid document does not count. That is not new in UD312, but with electronic circulation someone will click “for” from a daughter’s account who has no power on file. You bind the portal account to a person and a unit, not to “the Kowalski family”. GDPR in such a panel is not a poster. It is that the daughter does not see the neighbour’s arrears, and a board member has their own account, not the password “admin123” on a card in the caretaker’s room. On inspection of documents — a log of who downloaded an invoice with a KSeF number. You do not dump invoices onto the community WhatsApp group.
A field checklist in the register and questions for a vendor
Before you sign an addendum with a software vendor or commission a custom build, walk the unit card, the community card and the resolution card. The list below is a list of fields from the bill and from an agency’s daily work, not a slide. If a line cannot be stored, it cannot be shown in a dispute about an advance, a meter or a vote.
- Unit: share, floor area, balcony (private / common walkway / façade), individual water contract yes/no, ADE, e-mail, postal address, proxy.
- Advances: operating, heating, water and sewage, waste, reserve fund, special-purpose fund; date received; transfer reference; balance on the 10th of the month.
- Measuring device: type, number, verification, next stamp, contractor, cost, refusal of access with request date.
- Resolution: mode (meeting / circulation / mixed), text locked at the start of voting, deadline of at least 2 weeks, votes in shares, result under the proper majority.
- Meeting: 2 weeks’ notice, delivery channel, 1/10 request, owners’ drafts on the agenda, minutes, written report with a financial part.
- Access to the unit: type (inspection / emergency / sanitary / fire), requests, post-inspection recommendation, assistance, referral to PINB.
- Board: members, majority representation, Article 18 agreement if still live, compulsory-manager flag.
- Assets: community accounts separate from the agency, warranty cases, enforcement against the community versus unit arrears.
Put the questions to the vendor in writing. Does it distinguish an absolute majority of all shares from an ordinary majority of those voting on circulation. Can the resolution text be locked after voting starts. Does the 10th run per advance heading, not per “rent”. Will a meter card survive 200 devices on one stair. Can the access-request log be exported for PINB. Is KSeF only a number against an invoice, or does someone promise “issuing for the community” without credentials. Does the portal meet GDPR on document inspection — the owner sees their balances and resolutions, not other people’s proof of payment.
If the vendor answers “we will do that in the next release” to three of those questions, and you have meetings in April, you do not wait for a roadmap. Either you add your own fields in Laravel and Vue, or you stay on the package and keep meters in a sheet beside it — deliberately, with a date and a name of who owns the sheet. GESOFT (Paweł Matusiak) does the first when the model does not fit the box. It does not promise that Android will replace waterproofing on a balcony slab.
On the choice between SaaS and a custom programme, Off-the-shelf or bespoke software is useful. Briefly: 30 identical communities with no Article 18 agreements and no circulation voting will often run on a package. A book with a TBS, post-developer communities, individual water contracts and a public owner who wants a court change of shares usually will not. We do not guess a price in this article. After the number of communities, units and the accounts integration we quote via contact.
KSeF, e-Delivery and a portal the panel does not replace
From 2026 invoices from the heat supplier, the waste contractor and the cleaning firm arrive in KSeF if the community is a taxpayer required to receive that way. The Taxpayer Application and ZAW-FA credentials stay with the tax office. In the community register you enter the KSeF number, the issuer’s NIP and the amount, so the financial part of the report has an anchor. We do not issue a structured invoice for you. We are not the Ministry of Finance. If you re-invoice utilities, that is a separate tax decision and a separate credential, not a button on the residents’ portal.
A managing agent as a CEIDG or KRS trader has or will have an e-Delivery address under the timetable in the Electronic Deliveries Act. A community as such is in neither KRS nor CEIDG, so we do not derive a duty of ADE “for the community” from that Act. Notices to owners, under the bill, may go to ADE or e-mail, on a par with paper. On the unit card you keep the channel the owner gave. You do not mix the agency’s mailbox with the community’s. When a letter from the municipality about waste arrives, it should land in the community’s file, not in the chair’s private post.
A residents’ portal is a convenience and — after UD312 — a natural place for circulation voting. It is not an office of state. It does not replace the land register, e-Delivery, KSeF or PINB. Login, sessions and 2FA in such a panel we describe separately under authentication in Laravel. Here one rule is enough: the owner sees their unit, their balances, resolutions and their votes. The administrator sees everything, with a log of who opened a document. An agency with twenty staff does not share one login “wspolnota1”.
Collective-residence buildings are, in the bill, taken out of easy separation into premises, save where they meet technical requirements and a municipal council resolution, and save buildings from before 1 January 2027 or with a building permit before that date. That is more a developer’s topic than an evening community meeting. If you have such a building on the book, a flag on the property card and a word with a lawyer. CRM for a developer is for reserving flats, not for working around the local plan. UD312 is meant to make that workaround harder.
A public owner — a municipality, the State Treasury — is given in the bill a court route when the community does not pass a resolution on changing the size of shares. The court is to decide in non-contentious proceedings, having regard to the purpose of the act and the interests of all owners. In the register such a case is not a “complaint”. It is an application, a date, whether the board put a resolution to the vote, the result and — if there is silence — a note that the owner is going to court. You do not block their inspection of documents on the way. The bill requires that inspection anyway. An agency that hides the share table because “we are still counting” picks a fight for itself. The share table is in the notarial deed and in the land register. The panel has to match what is in the KW, not what someone typed by hand in 2018 after the last extra storey.
Frequently asked questions
- Is UD312 already in force?
- No. On 17 August 2026 version 2.0 of the bill was published in the government’s work list. On 18 August Infor reported that the text was before the Standing Committee of the Council of Ministers. The planned RM adoption date on the card is the third quarter of 2026. Entry into force — 30 days after promulgation, with exceptions. It has not reached the Journal of Laws.
- From when must utility advances arrive by the 10th of the month?
- Under the bill — from the day the amendment enters into force, that is 30 days after promulgation. Today that due date for utilities comes from the community’s rules, not from the Act. Advances for management costs already have a statutory due date of the 10th. It is worth splitting the headings in the register before the provision arrives.
- Will the water meter in the flat stop belonging to the owner?
- The bill provides that heat meters, water meters and radiator heat cost allocators form part of the common property, except where an individual water contract itself names the owner of the meters. Upkeep and official verification fall on the community. The owner may not interfere with the device.
- How do you count a majority on a circulation resolution?
- For individual collection of votes and mixed mode the bill provides for an ordinary majority of the shares of owners who took part, after the deadline (minimum two weeks). Resolutions solely at a meeting still require an absolute majority of all shares. The register must know the mode.
- Will e-mail replace a recorded letter for meeting notice?
- The bill equates electronic form with writing: notice, the text of resolutions, circulation votes. It allows ADE or e-mail. It does not scrap paper for people without an electronic address. You keep the channel on the unit card. An e-mail with no date log is weak evidence.
- When does the management report have to be ready?
- The bill moves the deadline from the end of March to the end of April and requires written form with a description of the work and a financial part. It is still the annual meeting, only with an extra month for suppliers’ invoices and the logistics of a room.
- Does GESOFT replace KSeF or PINB?
- No. We do not replace KSeF, e-Delivery, the accounts package, the building inspectorate or meter verification. We build a register of units, advances, devices, resolutions and requests beside those systems. We store a KSeF number against an invoice we do not issue for the authority.
- What about notarial management agreements?
- The bill would remove them for the future. Agreements under Article 18(1) already made remain in force for the period for which they were concluded. Changing them is to follow the new rules, without a notary at every resolution. In the register a flag and an end or notice date.
- Must the owner let the team in for a gas inspection?
- The bill introduces such a duty for installation inspections under the Construction Law and for an emergency or a sanitary or fire risk. On persistent refusal — a path to a fine through the building inspectorate. In an emergency — possible entry with police or fire-service assistance. Today that sanction is not in the Act on Ownership of Premises.
- SaaS or custom, if we run 15 communities?
- If units, advances and resolutions are standard, an off-the-shelf product for managing agents will often do. If you have Article 18 agreements, individual water meters, circulation voting and several TBS buildings in one panel, list the fields and ask through the contact form. We reply in 24 hours, including when we advise you to stay on SaaS.
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