The entry into force of shelter requirements should be postponed by six months
The Estonian Chamber of Commerce and Industry and the Estonian Association of Construction Consulting Companies proposed to the Government that the entry into force of the requirements for shelters and sheltering places be postponed until 1 January 2027. We also asked for the creation of a support measure for designing and building shelters.
Under the leadership of the Ministry of the Interior, a draft regulation titled “Requirements for shelters and sheltering plans, principles for adapting sheltering places, and procedure for preparing sheltering plans” has been prepared and is planned to enter into force on 1 July 2026.
We support the objective of the draft regulation to strengthen civil protection in Estonia and improve sheltering options, but we informed the Government that we are seriously concerned about the rapid entry into force of the draft regulation. Businesses will be given less than two months to adapt to the new requirements.
Businesses are waiting for design guidelines
Design guidelines should be completed before the new requirements enter into force, but according to our information, they will not be completed until the end of the year. The lack of design guidelines turns each project into a separate experiment, the outcome of which depends on interpretations rather than uniform practice. Inevitably, this increases the time required for design, the risk of errors, and the cost of design and construction. If the entry into force is not postponed, there is a real risk that shelters that do not comply with the requirements will be built and will later have to be redesigned or rebuilt.
In the absence of uniform design guidelines, it will also be more difficult for the supervisory authority to assess whether a specific solution meets the requirements.
It must also be taken into account that the private sector currently lacks broader practical experience in designing and building shelters, and the necessary competence is still developing. This makes it all the more important that, before the obligations enter into force, the state, in cooperation with sector experts, creates clear, unambiguous and technically well-considered design guidelines.
The state could create a support measure
We also proposed to the Government that a support measure be created for designing and building the first shelters. At present, there is a support measure for adapting sheltering places, but no such measure exists for shelters.
State support for shelters would help ensure that the first shelters to be built are high-quality and compliant with the requirements, thereby creating a reliable basis for future projects. Support would help reduce uncertainty among market participants and develop a uniform implementation practice.