Knowledge base

    Official APN interpretation: Registering a company's registered office at a subsidised property

    Many of our clients with subsidised housing loans ask whether they may register their company or sole trader business at the address of that property. We requested an official interpretation from the Agency for Transactions and Mediation in Immovable Properties (APN).

    Short answer

    Yes, you may register the office of a company or sole trader business at the address of the subsidised property. However, you must not carry out business activities on the premises or rent them out — this restriction applies until two years after the subsidy ends.

    Our enquiry

    We requested an official statement on whether a company (d.o.o. or j.d.o.o.) or sole trader business may register its office at a property financed by a subsidised loan, under the following conditions:

    • The property owner gives consent solely for the purpose of registering the business address
    • The agreed fee is EUR 0.00 (no financial gain)
    • No business activities are physically carried out at the property (a so-called "virtual office" or administrative registered office only)

    Official APN response

    "The beneficiary of a subsidised loan may register the address of the flat or house purchased with a subsidised housing loan, where they have their registered residence, as the business address of a company or sole trader business. However, they must not rent out the flat or house, or any part of it, or carry out business activities there until two years after the loan subsidy period ends. Otherwise, APN must notify the selected credit institution, which must declare the entire loan immediately due and initiate enforced collection.

    The subsidised property may not be sold or rented out during the subsidy period or until two years after the subsidy expires."

    What does this mean in practice?

    ✓

    You may register a d.o.o., j.d.o.o. or sole trader business

    The address of the subsidised property may be the official address of your company or sole trader business.

    ✗

    You must not carry out business activities on the premises

    The property must not be used as an office, workshop or place to receive clients.

    ✗

    You must not rent out the property or any part of it

    Even part of the premises must not be rented to third parties.

    ⏱

    The restriction lasts until 2 years after the subsidy expires

    Only after that period may you freely dispose of the property.

    Consequences of a breach

    If business activities are found to be taking place at the property, or it has been rented out, APN must notify the credit institution, which will declare the entire loan immediately due and initiate enforced collection.

    For further questions, please contact us.