{ "metadata": { "language": "en", "generated": "2026-08-12", "open_count": 4, "resolved_count": 2, "count": 6 }, "section": { "kicker": "Editorial register", "title": "Problems in the published text", "intro": "Clear internal defects are separated from ambiguities and points that merely deserve watching. An “open” card does not mean a court would automatically invalidate the rule; it marks where the published text needs correction, interpretation or careful practice.", "legend": [ { "key": "clear", "label": "Clear internal defect", "text": "Cross-references or sentences cannot be reconciled simply by reading the same text." }, { "key": "ambiguity", "label": "Ambiguity", "text": "A plausible harmonising reading exists, but provisions overlap or use different terminology." }, { "key": "watch", "label": "Watch", "text": "No verdict is published; implementing rules, forms, practice or clarification are needed." }, { "key": "resolved", "label": "Resolved on publication", "text": "The problem existed in the parliamentary working text but is absent from the Official Gazette." } ], "open_title": "Open in the published text", "resolved_title": "Closed by the published form", "audit_link_label": "Open the full publication audit" }, "items": [ { "id": "issue-art-314", "target": "#problema-art-314", "status_key": "open", "status_label": "Open", "finding_key": "clear", "finding_label": "Clear internal defect", "article": "Article 314(8)–(9)", "official_gazette_page": 95, "title": "Article 314 conflicts over the last publicity operation and then points to the wrong paragraph", "summary": "Paragraph (8) treats the permit as brought to public knowledge by reference to paragraph (2). Paragraph (9) describes the same “last publicity operation” as established under paragraph (7), then allows access to information “under paragraph (4)” even though paragraph (4) is the exception for special constructions.", "evidence": [ "Paragraph (2) governs publicity by the authority, at its office and on its website/platform.", "Paragraph (7) governs distinct beneficiary formalities: land-book notation, a newspaper notice and the site board.", "Paragraph (8) points to (2), while paragraph (9) points to (7) for what the text calls the same last publicity operation.", "In paragraph (9), the reference to information in paragraph (4) does not match that paragraph’s content; the actual project information is mainly enumerated in paragraph (5)." ], "assessment": "This internal cross-reference defect was verified directly in the text. The register does not decide which paragraph should be substituted and does not invent a litigation deadline from a presumed correction.", "reader_effect": "It matters directly to neighbours because the provision links publicity to when the permit is deemed brought to public knowledge. The neighbour guide therefore treats dates and court deadlines cautiously.", "next_evidence": "Official Gazette rectification, legislative amendment, official implementing guidance or case law fixing the reading.", "source_refs": [ "code", "code-working", "law50" ], "related_targets": [ { "target": "#guide-ce-se-construieste-langa-mine", "label": "“What is being built next to me?” guide" }, { "target": "#audit-publicare", "label": "Publication audit" } ], "aliases": [ "Article 314", "permit publicity", "site board", "public knowledge", "neighbour permit" ], "tags": [ "transparency", "cross-reference", "permits" ], "last_verified": "2026-08-12" }, { "id": "issue-art-584-2", "target": "#problema-art-584-2", "status_key": "open", "status_label": "Open", "finding_key": "clear", "finding_label": "Clear internal defect", "article": "Article 584(2)", "official_gazette_page": 168, "title": "The Bucharest transfer cites Articles 132 and 134 rather than the district provisions in 131 and 133", "summary": "The provision says functions “exercised by district mayors and their specialist structures” are transferred but cites Articles 132 and 134. In the published text, the district mayor is Article 131 and the district structure Article 133; Article 132 concerns the City Hall structure and Article 134 public expertise centres.", "evidence": [ "The sentence itself points to district functions.", "The published numbering places the district mayor in Article 131 and the district structure in Article 133.", "The committee report contains an earlier numbering that probably explains the stale reference." ], "assessment": "The internal reference is defective. The overall centralising purpose is probable, but its legal scope should not be described as doubt-free before correction or authoritative interpretation.", "reader_effect": "It affects the mechanism of the transfer scheduled for 1 November 2028, including which functions and structures move.", "next_evidence": "Rectification, legislative amendment or an official act clarifying the intended provisions.", "source_refs": [ "code", "committee-report" ], "related_targets": [ { "target": "#bucuresti", "label": "Bucharest file" }, { "target": "#tracker-bucharest-transfer", "label": "Transfer tracker" } ], "aliases": [ "Article 584", "Bucharest powers", "districts City Hall", "district mayor" ], "tags": [ "Bucharest", "cross-reference" ], "last_verified": "2026-08-12" }, { "id": "issue-art-309-310", "target": "#problema-art-309-310", "status_key": "open", "status_label": "Open", "finding_key": "ambiguity", "finding_label": "Ambiguity; not a proven contradiction", "article": "Articles 309–310", "official_gazette_page": 93, "title": "Permit extension: “validity” and “execution period” overlap across two articles", "summary": "Article 309(5) prohibits extending the initial three-year validity term, yet paragraph (6) allows an “extension of permit validity” for up to 12 months when works cannot be completed. Article 310(5) separately regulates an “extension of the execution period”, again once and for no more than 12 months.", "evidence": [ "A harmonising reading is possible: Article 309(5) may concern the initial window in which works must start, while paragraph (6)/Article 310 concern completion after commencement.", "But Article 309(6) itself uses “extension of permit validity” while describing failure to complete the works.", "Article 309(6) requires the request at least 15 days beforehand; Article 310(5) says 15 working days.", "Article 310(5) expressly adds a fee equal to 30% of the initial fee; Article 309(6) does not." ], "assessment": "The provisions can be harmonised, but their relationship is not expressed cleanly. This is classified as ambiguity/possible overlap, not a “certain error”.", "reader_effect": "For a delayed project, the difference may affect which application is made, how early it must be filed and what fee applies.", "next_evidence": "Official forms/rules, consistent administrative practice, rectification/amendment or case law.", "source_refs": [ "code", "code-working" ], "related_targets": [ { "target": "#transition", "label": "Transition rules" }, { "target": "#audit-publicare", "label": "Publication audit" } ], "aliases": [ "Article 309", "Article 310", "permit extension", "execution period", "permit validity" ], "tags": [ "permits", "deadlines", "ambiguity" ], "last_verified": "2026-08-12" }, { "id": "issue-art-250-3", "target": "#problema-art-250-3", "status_key": "open", "status_label": "Open", "finding_key": "watch", "finding_label": "Watch; no definitive finding", "article": "Article 250(3)", "official_gazette_page": 70, "title": "Site organisation and utility opinions: a procedural formulation to watch", "summary": "Alongside authorisation of the main works, the text requires authorisation of site organisation and requests for utility opinions/agreements required by the planning certificate. How strict the simultaneity is will depend on implementation.", "evidence": [ "The committee report uses the working number Article 260; after renumbering the published rule is Article 250(3).", "A strict reading requires simultaneous steps; a functional reading treats it as procedural coordination." ], "assessment": "No drafting error is asserted as fact. This is a point to follow in implementing rules, forms and authority practice.", "reader_effect": "It may change the order and documentation expected when the application for the main works is filed.", "next_evidence": "Implementing rules, official forms, instructions or verifiable administrative practice after commencement.", "source_refs": [ "code", "committee-report", "plenary-transcript" ], "related_targets": [], "aliases": [ "Article 250(3)", "Article 260", "site organisation", "utility opinions" ], "tags": [ "site organisation", "utilities", "watch" ], "last_verified": "2026-08-12" }, { "id": "resolved-art-223", "target": "#rezolvat-art-223", "status_key": "resolved", "status_label": "Resolved on publication", "finding_key": "resolved", "finding_label": "Resolved", "article": "Article 223", "official_gazette_page": 64, "title": "Parcel reconfiguration: the bad Article 224 reference became Article 219", "summary": "The parliamentary working text pointed to Article 224, which governed urban regeneration. The Official Gazette points to Article 219, the provision on conditions applicable to subdivisions.", "evidence": [ "The correction is directly visible in the two texts and is one of the differences confirmed through review in the 584-article audit." ], "assessment": "The pre-publication warning is closed; public citation uses Article 219.", "reader_effect": "That logical break is absent from the published form.", "next_evidence": "None unless a later rectification or amendment changes the text.", "source_refs": [ "code", "code-working" ], "related_targets": [ { "target": "#audit-publicare", "label": "Publication audit" } ], "aliases": [ "Article 223", "parcel reconfiguration", "Article 219" ], "tags": [ "resolved", "subdivision" ], "last_verified": "2026-08-12" }, { "id": "resolved-art-577-8", "target": "#rezolvat-art-577-8", "status_key": "resolved", "status_label": "Resolved on publication", "finding_key": "resolved", "finding_label": "Resolved", "article": "Article 577(8)", "official_gazette_page": 167, "title": "Continuity of the HG no. 203/2003 regulation is now express", "summary": "The parliamentary working text listed the regulation without saying it remained in force. The Official Gazette expressly adds that it remains in force until amendment.", "evidence": [ "This is a content change rather than a numbering correction and was checked directly in the published paragraph." ], "assessment": "The continuity warning is closed for this regulation.", "reader_effect": "The regulation’s survival no longer has to be inferred solely from other transitional provisions.", "next_evidence": "None until the regulation or Code is later amended.", "source_refs": [ "code", "code-working" ], "related_targets": [ { "target": "#audit-publicare", "label": "Publication audit" } ], "aliases": [ "Article 577(8)", "HG 203/2003", "construction regulation" ], "tags": [ "resolved", "continuity" ], "last_verified": "2026-08-12" } ] }