Report from Berlin

Regulatory Update 2026: What Matters for Demolition and Dismantling Companies

When business owners in Berlin hear the word “new regulations,” many have the same reflex. They reach for the calendar, look at the coming year, and ask themselves: when does what apply – and does it affect me at all?

For 2026, this question can be answered quite soberly:
There will be less that’s new than many people think. But what does change needs to be done properly.

This is not a year of major political breakthroughs, but a year of clarification, refinement, and closer scrutiny. Or, less legalistically put: in 2026, Berlin wants less gut feeling and more traceability.

And that is exactly where demolition and dismantling companies have a structural advantage – not because they are less affected, but because they have been working within precisely this logic for years.

2026 Is Not a Disruption, but a Housekeeping Step

Before we dive into individual regulations, it is worth a brief shift in perspective. Hazardous substances, unclear existing building stock, complex material flows, high responsibility – these have always been part of everyday reality.

What changes in 2026 is not the technical expectation, but the formal translation of that expectation into law. Many things that previously counted as “state of the art” are now receiving a clearer legal contour.

This mainly concerns one topic – and it should neither be downplayed nor dramatized.

Asbestos, Hazardous Substances, and the Question of Permits

Let’s get to the core of the amended Hazardous Substances Ordinance.

The new version has been in force since 20 December 2025, and 2026 is the year it will truly arrive in day-to-day operations. It is important to clear up a common misconception right away:

What’s new is not that asbestos is dangerous.
What’s new is not that you cannot simply get started.
What’s also not new is that demolition and dismantling companies must be specially qualified for it.

What is new is the system by which the state now makes this reality binding.

What does that mean in concrete terms?

For certain demolition, remediation, and maintenance work involving asbestos, an official permit is now required – and not only for high-risk activities, but also in the low and medium risk range, provided the work is not merely occasional. At first, that may sound like a classic case of “more bureaucracy.” In practice, however, it is about something else:

The legislator wants to know in advance

• who carries out such work,
• how it is carried out, and
• whether the necessary qualification is permanently in place within the company.

So it is less about the individual site and more about the reliability of the company.

Why this is less new for many businesses than it sounds

The permit can be applied for at company level. It is valid for up to six years and even takes effect automatically if the authority does not respond within four weeks. In addition, there is a transitional period until 19 December 2026.

This transitional period is not a loophole, but a deliberately set timeframe for adjustment. This is where the difference between theory and demolition practice becomes clear:

Many companies already have

• qualified personnel,
• regulated work procedures,
• occupational medical provisions, and
• years of experience handling asbestos-containing materials.

All of this has existed for a long time – it just has not yet been formally bundled under the heading “permit pursuant to Section 11a of the Hazardous Substances Ordinance.”

That is why 2026 is less about learning something new, and more about putting what already exists in proper order, documenting it, and making it robust in the eyes of the authorities.

You could also put it like this:
The reality of dismantling is finally being regulated in the way it has always been.

Why the New Rules Do Not Affect All Trades Equally

A brief classification is helpful here. The new regulations around hazardous substances do not affect the construction industry uniformly – they impact it very differently, depending on the trade and previous practice.

For demolition and dismantling companies, dealing with unclear existing materials, hazardous substances, and the corresponding documentation has always been part of daily business. Risk assessments, proof of competence, occupational medical provisions, and documented work procedures are not exceptions here – they are operational routine.

The situation is different in parts of the construction finishing trades, especially in refurbishment, modernization, and interior fit-out. Trades such as tilers, drywall installers, and others have often had only occasional contact with systematic hazardous-substance requirements. Asbestos was often perceived as a special case, not as a structural issue to be addressed before work begins.

The new system changes exactly that. In future, these trades will also have to check, assess, and document before starting work whether hazardous substances may be involved – and how they must be handled.

What has been lived practice in dismantling for years is now being required across the industry.

This different starting point explains why the new rules are seen as far-reaching in parts of the construction sector, while in dismantling they are more likely to be perceived as a formal clarification. The substances were always there—what is new is the binding, systematic focus on them.

A Quick Look at the Construction Site Ordinance

In connection with the amended Hazardous Substances Ordinance, the Construction Site Ordinance is often mentioned as well.

In fact, the Construction Site Ordinance does not introduce any new substantive obligations. The adjustments are limited to terminological clarification, aligning the rules cleanly with European hazardous-substance law. Only a wording in the annex was changed to match the terminology of European hazardous-substance law (CLP).

No new duties, no new role for the safety and health coordinator (SiGeKo), no additional documentation requirements. For demolition companies – as for other construction trades – this means: if you have organized your sites safely up to now, you do not have to reinvent anything here.

Waste Law

No new law – but a sharper focus.

In waste law as well, there is a persistent feeling that “something might come again” in 2026. In reality, the legal foundations remain unchanged.

What is changing is enforcement. Authorities will take a closer look at whether

• separation concepts are plausible,
• documentation and evidence align, and
• planning, dismantling, and disposal are logically integrated.

For demolition companies, this is not a paradigm shift, but rather a reminder that clean material-flow documentation is not an end in itself. It saves time when questions arise and prevents debates in the wrong place.

And Then There’s “Everything Else”

Beyond the Hazardous Substances Ordinance, there are a number of other regulations that will take effect in 2026 or continue to apply and are often grouped politically under the umbrella term “new regulations.” They affect the construction industry overall, but not specifically demolition and dismantling.

This includes, for example, the new European Construction Products Regulation, which applies from January 2026. Its aim is to harmonize product information, make it more transparent, and increasingly keep it digitally available. For demolition and dismantling companies, this does not mean new product obligations, additional testing, or new technical requirements.

The regulation becomes relevant more indirectly – for example through project documentation, specifications, or handover documentation. Those who keep their documentation structured and know what information needs to be passed on and when will not experience disruptions.

A similar situation applies to labour and employment-law changes that take effect at the beginning of 2026.

The statutory minimum wage has been €13.90 per hour since 1 January 2026, and the earnings limit for mini-jobs is being increased to €603 per month.

These changes are binding, but neither surprising nor short-notice. They mainly affect payroll, bid calculations, and the assessment of subcontractor services. For demolition and dismantling companies, they do not change the technical execution of work, but they do affect business planning. The key is to incorporate the new values early into costing models and contract structures in order to avoid later corrections.

The modernized training regulations in the construction industry, which take effect from August 2026, should also be viewed more in the long term. They aim to update content, adjust examination formats, and make training occupations more attractive. For demolition companies, this is less a short-term obligation and more a strategic opportunity to introduce qualified young talent early to safe working practices, documentation, and responsibility.

All of these topics have one thing in common: they are systemically relevant but operationally manageable. They require attention, planning, and clean implementation – but no fundamental overhaul of the business model.

Or put differently: they do not decide how dismantling is done, but how well organized a company is overall.

2026 at a Glance for Demolition and Dismantling Companies

Truly new and relevant

• Permit requirement for certain asbestos-related work under the Hazardous Substances Ordinance (GefStoffV)
• Stronger formal requirements for documentation and transparency
• Transitional period until 19 December 2026, then binding

Not new

• No new asbestos ban
• No new construction site organization
• No new waste law
• No new product obligations for demolition and dismantling companies

In Conclusion

If you want to be well positioned in 2026, you do not really need to study legal texts – you need to ask a simple question:

Are our processes so clear that we can explain them?

A clear approach to suspected asbestos, complete documentation, and clean responsibilities are not new requirements, but the logical consequence of professional dismantling.

Success will no longer be determined by more rules, but by structure, preparation, and reliability.

All things that have always been part of demolition and dismantling – and that will simply become a bit more visible in 2026, for everyone.

Contact
Dipl.-Ing. (FH) Katrin Mees
Head of Berlin Office
German Demolition Association (Deutscher Abbruchverband e. V.)
Kronenstraße 55–58
10117 Berlin, Germany
Tel.: +49 30 20314 524
mees@deutscher-abbruchverband.de
www.deutscher-abbruchverband.de

Report from Berlin 01/2026 (in German)

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