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The HOAI reform: current status and expectations

📐 Article7 min read

What you will learn How far the process has advanced, which two expert reports exist and what they propose, why the timetable has repeatedly failed, and what a revision would mean for running contracts.

A process to revise the HOAI has been running for several years. It is well advanced and has repeatedly stalled.

This article gives the position at the date of checking. It is the fastest-ageing article in this subject, and its statements must be verified before use.

The position at 1 August 2026

No draft ordinance exists. The formal rule-making procedure has therefore not begun, and the HOAI in its 2021 version applies unchanged.

The principal milestones can be read chronologically. The interruption of 2025 is the most consequential among them.

Date Event
December 2023 Publication of the report on the planning fields
March 2025 Publication of the fee report, over 600 pages
Spring 2025 Early federal election, process interrupted
2025 Revision not included in the coalition agreement, initially halted
January 2026 Coordination meeting scheduled between ministries and professional bodies
March 2026 Federal economics minister confirms continuation of the process in writing
Mid-2026 Priority legislation completed; the path is clear according to the professional bodies

No binding timetable exists. Professional bodies consider a draft ordinance during 2026 and entry into force in early 2027 possible, while themselves stressing the uncertainty of that assessment.

The largest open point of contention is the level of the fee rates. It is also the point where public and professional interests stand directly opposed.

The two expert reports

The process follows a two-stage structure, mirroring the 2013 revision. One report addresses the services, the other their price.

The report on the planning fields addresses the service profiles: which services now belong to the customary scope, where digitalisation and sustainability requirements generate new services, and where profiles should be supplemented.

The fee report addresses the fee tables. It carries forward the models of the report prepared for the 2013 revision, accounting for the rising costs of design practices and, except in spatial planning, the movement of construction costs since the last revision.

Both are published on the websites of the responsible ministries. They are academic studies, not drafts: the decisions are taken within the rule-making procedure.

What is proposed

The following points come from the published reports and from the professional bodies' accounts. They are proposals, not applicable rules.

Proposal Order of magnitude Reasoning in the report
A substantial increase in the table values object design of buildings and interiors +16 to +67 %, technical installations +26 to +76 % a cost forecast to 2026 together with the legal and technical changes since 2013
A stronger increase at the lower end disproportionate the fees of small projects are generally regarded as not viable
A reduction in one area construction surveying that table is regarded as having been raised disproportionately in 2013
Flat reduction factors 0.55 to 0.75 per service profile to be incorporated into the ordinance as flat values
A new service profile urban design exists with a service description and a fee table
A definition of sustainability addition to the definitions takes account of compliance with statutory requirements

Why the timetable has repeatedly failed

Three factors have delayed the process, and they continue to operate. The third is the only substantive one among them.

Factor Effect on the process
Political discontinuity the early federal election interrupted the process before the reports could be converted into a draft ordinance
Absence of political priority the revision was not included in the coalition agreement; the responsible ministry addressed other legislation first
The open dispute over fee levels an increase on the scale proposed acts directly on public construction budgets, which is why this point is regarded as the hardest

The professional bodies have prepared a communications campaign should the project fail definitively. That is an indicator of how robust the timetable appears to those involved.

What a revision would mean

Four points would matter in practice. The first is reassuring; the three that follow require preparation.

Point What would follow
Nothing changes for running contracts a new version would apply to contracts concluded from its entry into force; for earlier ones the version in force at conclusion would remain decisive, as on the move to 2021
The table values would remain values for orientation binding price law is precluded under European law; raising the tables would improve the negotiating position but create no floor
The base fee rate would rise with them as the lower figure of the table it would be directly affected, acting on the fallback where no agreement in text form exists
Changed service profiles would require new contract templates where services move between basic and additional, existing templates must be adapted

What to do now

Two precautions make sense regardless of the outcome. Both keep their value even if the revision fails.

Record your own calculation traceably. Since the table values date in amount from 2013 and that age is known, a bare reference to the table now carries less weight as an argument. A derivation of actual effort carries further, and retains its value after any revision.

Check contract templates for adaptability. Long-running contracts referring to specific sections or table values should be worded so that a change of version does not lead to disputes over interpretation. Naming the version relied upon is the simplest route.

This article reflects the position of the process at the date of checking and serves professional orientation. It does not constitute legal advice and does not replace assessment of the individual case.

Frequently asked questions

The article describes the position as at 1 August 2026 and the expert reports available. No date is fixed.

The reports contain proposals on structure and fee determination. The article summarises them.

Because of political and legal preliminary questions, which the article names. A forecast would not be serious.

It would mainly affect the system of determination. Existing contracts would still be judged under their own legal position.

HOAI work phases: fees and service profiles for architects