Integrated Permits in the Czech Republic: Process, BAT and IED 2.0 Changes

Mgr. Karel Huneš
Mgr. Karel Huneš
9.4.2026 | ARROWS law firm

An integrated permit under Act No. 76/2002 Coll. is the most comprehensive instrument regulating the operation of major industrial and agricultural installations in the Czech Republic. Underestimating this system can cost millions in fines and lead to a shutdown of operations. The absence of a permit means not only financial penalties, but also a costly obligation to remedy the situation.

The photograph shows experts discussing the topic of integrated permitting.

Quick summary

  • An integrated permit (IPPC) is a mandatory requirement for operating hundreds of key installations in the Czech Republic that are categorised in Annex No. 1 to the Integrated Prevention Act. Without it, you face a fine of up to CZK 50 million and suspension of operations.
  • Emission limits are strict obligations; exceeding them triggers sanction proceedings and an obligation to invest in remedial measures.
  • The system is dynamic, as the link to the revised IED 2.0 Directive creates an environment in which operating conditions change and require regular updates.
What is an integrated permit and why does it exist?

Integrated Pollution Prevention and Control (IPPC) originated in the European Union with the aim of addressing environmental protection comprehensively. The goal was to prevent the practice of merely shifting pollution from one component of the environment to another. IPPC addresses everything at once – air, water, soil, waste, noise, energy and raw materials.

From a legal perspective, an integrated permit is a decision issued by the competent regional authority (krajský úřad) that replaces a number of individual permits, opinions and consents issued under sector-specific legislation. Instead of dealing with many authorities, you handle everything in a single procedure. In practice, however, this means that all risks and conditions are concentrated in one highly complex document. For installations where the integrated permit also addresses links to construction permitting and changes in operations, support in the area of development and construction law is typically applied.

Act No. 76/2002 Coll., on Integrated Prevention, transposes the European Directive 2010/75/EU on industrial emissions (IED) and its amendments into Czech law. In 2024, a revision of this directive was adopted at EU level (the so-called IED 2.0 – Directive (EU) 2024/1785), which the Czech Republic will transpose into its legal system with effectiveness expected in mid-2026.

IPPC processes overlap with dozens of legal regulations and involve a number of procedural pitfalls. The attorneys at ARROWS, a Prague-based law firm, handle IPPC matters on a daily basis and know where mistakes typically arise.

When do you need an integrated permit?

Whether your installation falls under the IPPC regime is determined by Annex No. 1 to Act No. 76/2002 Coll. It defines categories of industrial and agricultural activities. These include, for example, energy, metal production and processing, mineral processing, the chemical industry, or waste management.

The key factor is the design capacity of the installation:

  • For example, a foundry falls under category 2.4 if it has a production capacity of more than 20 tonnes per day.
  • Combustion plants must have a rated thermal input of 50 MW or more.
  • Chemical production often falls under IPPC regardless of the lower capacity threshold if it involves industrial production.

An important note for future legislative developments. A practical impact may also include situations where environmental limits lead to restricting or stopping a project, as we discuss in the text When can air pollution be a reason to stop construction or operations. With the transposition of the IED 2.0 Directive, the scope will be expanded to additional installations, for example the extraction of certain minerals or battery manufacturing.

The decision as to whether you fall under IPPC has fundamental implications, as operating an installation without a permit is an administrative offence subject to a high fine. The attorneys at ARROWS, a Prague-based law firm, can prepare a legal assessment of the categorisation of your installation.

Related questions on the integrated permit

1. How is capacity determined?

Capacity is determined as the maximum design capacity, not by how much you actually produce. If the installation is technically capable of producing above the threshold, you fall under the Act even if you operate at half capacity.

2. We increased capacity—what now?

If, by increasing capacity, you exceed the threshold values in Annex No. 1, you must obtain an integrated permit before putting the expanded part into operation. If you already have a permit, you must apply for its amendment.

3. I am not sure about the classification.

In case of doubts, it is possible to use the mechanism of a preliminary consultation with the authority, but the safest approach is to obtain an independent legal opinion that reflects the current interpretative practice of the Ministry of the Environment (MŽP) and the courts.

Integrated permit issuance process

Obtaining an integrated permit is a demanding administrative process conducted by the locally competent regional authority (krajský úřad). In practice, IPPC often overlaps with spatial planning, which is why it can also help to understand how to properly submit comments on a draft zoning plan. The application is submitted electronically and must include extensive particulars, including a description of the installation, raw materials, energy, and a comparison with BAT.

A CZK 30,000 administrative fee is payable for accepting an application for an integrated permit. For an application for a substantial amendment to the permit, the fee is CZK 10,000, or more in more complex cases requiring an on-site inspection.

The procedure includes several phases:

  • Submission of the application and completeness check by the regional authority.
  • Sending the application to the participants and publication in the Integrated Prevention Information System (ISIP).
  • An oral hearing and subsequent issuance of the decision.

During the procedure, emission limits and operating conditions are effectively negotiated, which requires expert argumentation. In practice, when setting and defending operating conditions, the impacts on the installation’s energy management are also often addressed, where legal support in the area of energy law can help. If you demonstrate that a certain technical solution is economically unsustainable or technically infeasible in your specific case, it is possible, under strict conditions, to apply for an exemption.

Legal representation is crucial at this stage to set sustainable conditions. The attorneys at ARROWS advokátní kancelář will guide you through this process, help you draft an application for a derogation, and ensure that the conditions in the permit are achievable for you and legally clear.

Best Available Techniques (BAT) and their role

The concept of BAT (Best Available Techniques) is key for IPPC and refers to the most advanced stage in the development of technologies suitable for setting emission limits. BAT are described in the BAT Conclusions, which are issued by the European Commission in the form of implementing decisions. If the European Commission publishes new BAT Conclusions for your sector, you have 4 years to bring your installation into compliance with these new requirements.

Czech law allows for different (more lenient) emission limits to be set if achieving BAT levels would lead to disproportionately high costs. An application for such a derogation must be supported by an expert assessment and an economic analysis, and the authorities assess these derogations very strictly.

Expert assistance is essential when applying for a derogation. The attorneys at ARROWS advokátní kancelář have experience defending these derogations and know how to properly structure an application for a derogation procedure.

Emission limits and Operating Rules

The emission limits set out in the integrated permit are binding and often include hourly, daily, or monthly averages. Exceeding even a daily limit may be considered a breach of the law and lead to sanctions.

The Operating Rules are also essential, as they precisely set out the rules for operation, emission measurement, and maintenance. The operator is obliged to comply with these rules, and a common mistake is a mismatch between the written rules and the reality of operations.

Risks and sanctions

How ARROWS helps (office@arws.cz)

Operating without an integrated permit: Fine of up to CZK 10,000,000, suspension of operations.

Assessment and legalisation: We will assess whether you fall under the law and arrange expedited obtaining of the permit.

Exceeding emission limits: Fine of up to 5

CZK 10,000,000 (depending on severity), mandatory remediation.

Defence and set-up: We will represent you in administrative proceedings and help with revising the permit conditions.

Breach of permit conditions (outside the limits): Fine of up to CZK 10,000,000.

Compliance audit: We will check your operation’s compliance with the permit and propose changes to the Operating Rules.

Failure to comply with obligations when BAT changes: Fine of up to CZK 10,000,000.

Deadline monitoring: We will alert you to new BAT and ensure timely updating of the permit within the four-year period.

Failure to report changes in operations: Fine, risk of the permit becoming invalid.

Amendment proceedings: We will administer the process of amending the integrated permit with the regional authority.

Legislative changes and the IED 2.0 Directive (2026)

The currently ongoing transposition of the IED 2.0 Directive (2024/1785) brings significant changes into Czech law. It includes an obligation to have transformation plans prepared to achieve climate neutrality and a circular economy by 2050.

Other changes include:

  • Stricter limits with an emphasis on the lower end of BAT-associated emission ranges.
  • Extension of scope to a broader range of installations, such as extraction of industrial minerals or larger animal farms.
  • EU pressure for effective and dissuasive sanctions, including the possibility of class actions.

These developments need to be prepared for in advance. ARROWS’ Prague-based attorneys monitor these changes and are ready to inform clients in a timely manner about the impacts on their specific operations.

Inspections, sanctions, and steps after a breach is identified

The main inspection authority is the Czech Environmental Inspectorate (ČIŽP), whose inspectors have the right to enter premises and carry out measurements. If an inspection identifies a breach, an inspection report is drawn up, against which objections may be filed.

The process includes the following steps:

  • Inspection report and submission of objections (usually within 15 days).
  • Misdemeanour proceedings if the objections are unsuccessful.
  • Imposition of remedial measures, which may also include restricting operations.

The amount of the fine depends on the severity and consequences of the unlawful conduct. The maximum threshold is CZK 10 million; for less serious administrative shortcomings the limits are lower, but still in the hundreds of thousands to millions.

If you are facing an inspection or a fine is threatened, do not hesitate to contact experts. Timely legal intervention can significantly reduce the fine or prevent it altogether.

Reporting obligations and the Integrated Pollution Register (IRZ)

Operators of IPPC installations are generally required to report emissions and transfers of substances to the Integrated Pollution Register (IRZ) under Act No. 25/2008 Coll. The report is submitted annually by 31 March for the previous calendar year.

Failure to comply with the reporting obligation may result in a fine of up to CZK 500,000. Data in the Integrated Pollution Register (IRZ) are public, which means that incorrect data may damage the company’s reputation in the eyes of the public and the media.

Rules for operation and permit review

In the Czech Republic, an integrated permit is usually issued for an indefinite period, but it is subject to regular review. The regional authority is obliged to review the conditions always within 4 years of the publication of new BAT Conclusions.

The permit is also reviewed in the event of a substantial change in operations or a change in legislation. Throughout the operation, the operator must keep records of data on compliance with binding conditions and submit an annual report to the authority on their fulfilment.

If you are planning modernisation, a fuel change, or a capacity increase, always consult a lawyer on whether a permit amendment is required. ARROWS’ Prague-based attorneys will help you navigate the amendment process smoothly.

FAQ

1. Can I obtain confirmation that I do not fall under IPPC?
Yes, if the situation is borderline, we recommend preparing an expert legal opinion that will serve as supporting documentation in the event of an inspection. Contact us at office@arws.cz.

2. It seems to us that the permit conditions are too strict/unachievable. What should we do?
If the permit has not yet become final, file an appeal. If it is already in force, it is possible to apply for an amendment to the integrated permit if you demonstrate a change in circumstances or the availability of a different technique.

3. We received a fine from ČIŽP—do we have a chance to defend ourselves?
Yes, an appeal against the decision imposing the fine may be filed with the Ministry of the Environment. It is necessary to analyse whether the inspectorate followed the correct procedure and whether the fine is proportionate. ARROWS advokátní kancelář has extensive experience with these appeals.

4. How long does it take to process a change to the permit?
It depends on whether this is a “material change” involving public participation and an oral hearing, or a non-material change. A non-material change may be processed within a matter of weeks, while a material change usually takes 3 to 6 months.

5. Do we need a separate permit for each site?
If the facilities are in one place (within one premises) and are technically interconnected, as a rule a single integrated permit is issued for the entire facility. If you operate in different locations, each one needs its own permit.

Disclaimer: The information contained in this article is for general informational purposes only and serves as a basic guide to the issue as of 2026. Although we strive for maximum accuracy, laws and their interpretation evolve over time. We are ARROWS Law Firm, a member of the Czech Bar Association (our supervisory authority), and for the maximum security of our clients, we are insured for professional liability with a limit of CZK 400,000,000. To verify the current wording of the regulations and their application to your specific situation, it is necessary to contact ARROWS Law Firm directly (office@arws.cz). We are not liable for any damages arising from the independent use of the information in this article without prior individual legal consultation.

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