An environmental protection elaborate is a document submitted before you begin an activity — or for an existing activity — demonstrating that the environmental impact is known, assessed and covered by specific measures. The legal basis is Article 24 of the Environment Act (Official Gazette of RM no. 53/2005, as subsequently amended; the latest are in Official Gazette of RNM nos. 3/2025 and 124/2025). It is not the same document as an EIA study, nor as an integrated environmental permit — and the difference determines who you go to and what it costs.
Who needs an elaborate
The obligation arises from Article 24 of the Environment Act, but the specific activities are not listed in the Act itself. They are in two separate government decrees, and that is the first thing to check:
- Decree on the activities for which an elaborate is mandatory and whose approval rests with the mayor of the municipality, of a municipality in the City of Skopje and of the City of Skopje (Official Gazette of RM nos. 80/2009 and 32/2012) — adopted under Article 24(5).
- Decree on the activities for which an elaborate is mandatory and whose approval rests with the body performing specialist environmental activities (Official Gazette of RM nos. 80/2009 and 36/2012, amended in Official Gazette of RNM no. 233/2022) — adopted under Article 24(4). That body is the Environment Administration, a body within the Ministry.
If your activity is in the first decree, the elaborate is approved by the municipality. If it is in the second — by the Environment Administration. It is not the size of the company that decides, but the type of activity.
Activities approved by the municipality
Annex 1 to the municipal decree covers, among others: the food industry (bakery products, meat and dairy products, soft and alcoholic drinks), textile, leather and timber industries, furniture manufacture, plastics products, metal products and machinery, local roads and streets, buildings for primary and secondary healthcare and social care, hotels with fewer than 100 beds outside urban areas, transfer and temporary storage stations for municipal waste, and vehicle paint shops.
Annex 2 covers small-scale activities — restaurants, cafeterias, bars, cafés, nightclubs, fast-food outlets and catering; storage of construction materials; grain silos and waste material stores; car washes; and sheet-metal and mechanical workshops.
Activities approved by the Environment Administration
The second decree holds the larger and riskier activities: mining and extraction of stone, crude oil and natural gas; energy (refineries, industrial installations for generating electricity and hot water below 10 MW, hydropower plants up to 10 MW, renewable energy plants up to 200 MW — but not rooftop photovoltaic plants, which were removed by the 2022 amendment); the chemical industry (pesticides, pharmaceuticals, paints and varnishes, detergents, explosives, and storage facilities for oil and petroleum products); the rubber industry; non-metallic mineral raw materials (cement, lime, concrete, ceramics, glass); production and processing of metals, casting, metal coating, batteries and accumulators.
Also included are: installations for waste treatment and disposal, storage of metal scrap including end-of-life vehicles, collection centres for temporary storage of hazardous waste; industrial complexes, shopping centres with car parks, transformer stations above 10 kW; filling stations and other dispensing points for gas, oil and petroleum products; hotels with more than 100 beds outside urbanised areas; and laundering and dry cleaning of textiles and fur.
This is where mistakes are most often made: a hospitality venue goes to the municipality, but a filling station on the same street goes to the Administration. An elaborate sent to the wrong address means weeks lost.
An elaborate is prepared for both new and existing activities. An existing activity operating without an approved elaborate is not exempt; on the contrary, that is the most common reason for an inspection decision.
What the elaborate contains and in what form
The form is prescribed by the Rulebook on the form and content of the environmental protection elaborate, the procedure for its approval and the manner of keeping the Register of approved elaborates (Official Gazette of RM no. 44/2013, amended by no. 111/2014). It repealed the earlier rulebook from Official Gazette no. 50/09 — if you are still being offered a template under the old regulation, that is a warning sign.
The rulebook prescribes two templates: Annex 1 for larger-scale activities and Annex 2 for small-scale activities — agricultural and craft activities and trade carried on by a sole trader. The elaborate is prepared in A4 format, in printed and electronic form.
The content follows a fixed order:
- General details — name, legal status, address, company and VAT numbers, activity code, category under Article 24(4) and (5), headcount, design capacity
- Type of elaborate — new or existing activity
- Authority competent for approval
- Description of the project — location, technical and technological description, raw materials, annual electricity and water consumption
- Description of the environment around the location — neighbouring buildings, hydrology, planning status
- Environmental impact — emissions to air, wastewater, waste by code, noise, effect on soil
- Protection programme — measures with a timeframe and owners
- Conclusion, list of annexes and a statement on the accuracy of the data
The annexes are what most often blocks approval: the title deed or lease agreement, confirmation of the status of the location, an extract from the spatial plan, contracts with authorised waste operators, electricity and water bills, and photographs of the premises.
How long the procedure takes
The application for approval, together with the elaborate, is submitted in three printed copies and one electronic. It is not submitted directly to the authority that approves the elaborate, but to the authority that approves the implementation of the project — which must forward it within five days (Article 24(2)).
| Step | Statutory deadline |
|---|---|
| Forwarding the elaborate to the competent authority | 5 days from receipt |
| Decision approving or refusing | 15 days from receipt of the elaborate (Art. 24(11)) |
| Supplementation where the elaborate lacks required data | 15 days |
| Application to the registry if the authority is silent | 3 working days |
| Decision on that application | 5 working days |
| Appeal against the decision | 15 days, to the minister |
Once approved, the three printed copies are stamped: one is returned to the developer, one goes into the authority's archive, and one to the State Environmental Inspectorate or the authorised municipal inspector. Approved elaborates are entered into a Register of approved elaborates, kept in both electronic and written form.
The deadlines look short, but they run from a complete application. Realistic planning: start at least two to three months before the date by which you need the approved elaborate.
What happens if you operate without an elaborate
Carrying on an activity without an approved elaborate is a category I offence under Article 212-ѓ of the Environment Act. The same article also penalises the situation where an elaborate exists but the prescribed measures are not implemented. Following the amendments published in Official Gazette of RNM no. 89/2022, fines are graded by the size of the trader:
| Offender | Fine (in denar equivalent) |
|---|---|
| Legal entity — micro trader | EUR 9,000 to 10,000 |
| Legal entity — small trader | EUR 18,000 to 20,000 |
| Legal entity — medium trader | EUR 53,000 to 59,000 |
| Legal entity — large trader | EUR 88,000 to 98,000 |
| Sole trader | EUR 3,000 |
| Responsible person within the legal entity | EUR 500 / 1,000 / 3,000 / 5,000 by size |
| Natural person | EUR 500 |
These offences are decided by the competent court, not by an offence commission. Inspection oversight is carried out by the State Environmental Inspectorate, or the authorised inspector of the municipality or the City of Skopje — depending on which authority is competent for approval.
The consequences are not only financial. The absence of an approved elaborate regularly surfaces as a problem when applying for minimum technical conditions, extending permits, changing ownership, obtaining bank financing and taking part in public procurement.
Elaborate, EIA study or integrated permit
The three documents are often confused. The difference lies in which regulation catches you:
| Document | When it applies | Competent authority |
|---|---|---|
| Environmental protection elaborate | Activities in the decrees, Official Gazette of RM nos. 80/2009, 32/2012 and 36/2012 | Municipality/City of Skopje or the Environment Administration |
| EIA study | Projects in the Decree determining projects subject to impact assessment, Official Gazette of RM no. 74/05 | Ministry of Environment |
| B integrated environmental permit | Installations in Annex 2 of the Decree on integrated environmental permits | The mayor; where the installation is in a protected area — the Ministry |
| A integrated environmental permit | Installations with the greatest impact — larger industrial capacities | Ministry, under the Rulebook on the procedure for obtaining an A integrated environmental permit (Official Gazette of RM nos. 4/06, 116/2014 and 31/2016) |
The B permit procedure is governed by the Rulebook on the procedure for obtaining a B integrated environmental permit (Official Gazette of RM no. 112/2014). The application is submitted in three original copies and electronically, the competent authority carries out a site visit, and the decision issuing the permit must be adopted within 60 days of receiving the application (Article 126(1) of the Environment Act). We cover the detail of both permit types in the separate article on A and B integrated environmental permits.
Important for forward planning: in September 2025 the new Industrial Emissions Control Act was adopted (Official Gazette of RNM no. 193/2025), applying from September 2027. When it takes effect, Articles 95 to 129 and 134 to 144 of the Environment Act cease to apply — that is, the entire chapter on A and B integrated environmental permits. The elaborate obligation under Article 24 remains unchanged.
A simple self-check rule: if your installation is in the decree on integrated permits, you need an integrated environmental permit and an elaborate does not replace it. If it is not, but you fall under one of the two elaborate decrees — you need an elaborate. If the project is in the 2005 EIA decree — the procedure begins with a notification to the Ministry.
How we can help
RI-Opusproekt has been preparing environmental protection elaborates for over two decades — for hospitality, service, storage and industrial sites, including combined elaborates where several activities are carried on at one location. We first establish which decree the activity falls under and which authority is competent, then compile the list of annexes, so that no incomplete application is submitted. See the environmental elaborate service or request a quote with your activity code and the address of the site.
This article is informational and does not replace professional advice. Regulations change — last updated: August 2026.
This article is informational and does not replace professional advice.
