On 19 November 2025, the National Council passed an amendment to the General Administrative Procedure Act (AVG), which is set to come into force on 1 January 2026. The aim of the amendment is to speed up large-scale proceedings and make them more cost-effective. But what does the AVG actually mean by „large-scale proceedings“?

Large-scale proceedings are administrative proceedings initiated upon request in which, as the name suggests, a large number of participants is to be expected. Typical areas of application are found in particular in industrial plant, environmental and water law. The AVG provides for special provisions for these proceedings, which are intended to enable coordinated and more efficient conduct of proceedings.

If more than 100 people are likely to be involved, an authority may announce the application initiating the proceedings by means of an edict (Section 44a AVG). The announcement by edict marks the start of the large-scale proceedings regime. The consequence is significant: anyone who fails to submit written objections within the deadline loses by law its party status. This is intended to counteract the „problem of overlooked parties“ known in administrative procedural law.

Other special features for large-scale proceedings include the possibility of a public hearing (Section 44c AVG) to ensure information and transparency (AB 1167 BlgNR XX. GP, 34) and service by edict: documents – such as notices, expert opinions or procedural orders – can be published by the authority by edict. After two weeks, such a document is deemed to have been served; service is therefore deemed to have taken place (Section 44f(1) AVG, AB 1167 BlgNR XX. GP, 33).

The amendment aims to expand these instruments and clarify key points. Specifically, the amendment introduces the following changes:

• Edictal announcements are already permissible for more than 50 participants;
• The previously applicable „Edictal Barrier“ (temporary „barrier“ for edictal announcements during the holidays) between 15 July and 25 August and between 24 December and 6 January is completely abolished.;
• The authority may also declare the conclusion of the investigation proceedings only for individual parts of the same case (instead of a conclusion). en bloc);

• the decision concluding the proceedings must be served exclusively by edict;
• the authority may require the applicant to pay the cash expenses incurred by him directly; advance financing by the authority is therefore no longer necessary;
• In future, edicts will no longer be published in the „Amtsblatt zur Wiener Zeitung“ (Vienna Gazette), but in the „Rechtsinformationssystem des Bundes“ (Federal Legal Information System, „RIS“);
• When scheduling an oral hearing, the authority may at the same time set a deadline for further submissions.

The amendment contains elements that both speed up proceedings and reduce costs. Positive aspects include (finally!) the reduction in the number of parties involved – in line with the German legal situation, which introduced a threshold of 50 parties as early as 1996 – and the abolition of the edict barrier, which seemed outdated in the digital age with electronic information available at any time.

At the same time, however, there is still a need for further modernisation: the continued requirement to publish in two widely read daily newspapers in the federal state seems anachronistic in view of digitised publication channels. It also remains questionable why the threshold was set at 50 participants and not lower; after all, the decision on whether to apply the large-scale procedure regime remains at the discretion of the authority anyway.

Whether the new instruments will have the desired effect will depend largely on how they are applied by the authorities. Only then will it become clear whether the promised acceleration of large-scale proceedings will be achieved – or whether, for the time being, only the potential scope of application of the large-scale proceedings regime will be expanded. The predicted „turbo“ has therefore not yet fully ignited.