What does this law provide?
Law No. 86/2025, **“On the write-off, extinguishment and payment of tax liabilities owed to the central and local tax administration and liabilities payable at customs”** (commonly referred to as the **Fiscal Amnesty 2025**), is an extraordinary initiative of the Albanian government aimed at **writing off or forgiving a range of tax debts accumulated over the years**. The main objective is to “clean” the tax system of old liabilities that, in practice, have become impossible to collect, mainly due to very high late-payment interest and fines that have multiplied these debts. This provides a second chance for businesses and individuals with outstanding tax liabilities.
This law should not be confused with “Fiscal Peace” – another fiscal measure approved in parallel, which relates to voluntary agreements for declaring profits in future years. Unlike “Fiscal Peace” (which aims to encourage an expansion of the tax base for future periods through agreements with businesses), the Fiscal Amnesty 2025 deals only with past unpaid obligations and does not impose conditions on taxpayers’ future activity.
This law enters into force on 1 January 2026 and will apply until 31 December 2026, meaning that the benefits of forgiveness can be realised only within 2026. Within 15 days from entry into force, a special instruction is expected from the Minister of Finance detailing implementation procedures, but the main principles of the law are already known and are summarised below in simplified form.
Who benefits from the forgiveness?
The law is drafted in a highly inclusive way: all taxpayers, businesses or individuals, who have unpaid tax liabilities to the central tax administration or unpaid liabilities at customs benefit. The taxpayer’s current status is not important: both active taxpayers and passive (suspended) taxpayers benefit, as well as those who have been deregistered (closed) or have any other status in the “e-Tax” system. Even if a business closed years ago but still has unpaid liabilities in the system, it falls among the beneficiaries of this law. Likewise, debtors to customs (e.g., importers with outstanding customs liabilities) enjoy the same possibility of forgiveness under this law.
In short, any taxpayer with tax or customs debts registered up to 31 December 2024 may qualify for the benefits of forgiveness, except for certain excluded cases listed below. This makes the Fiscal Amnesty 2025 one of the broadest fiscal forgiveness campaigns ever undertaken in Albania.
Who is excluded from the forgiveness?
Ligji ka vendosur disa përjashtime të rëndësishme, kryesisht me qëllim për të mos “shpërblyer” shkelësit e rëndë fiskalë apo ata që janë në proces hetimi/gjyqësor. Konkretisht, nuk përfitojnë nga falja:
(1) Tatimpaguesit (individë ose biznese) ndaj të cilëve ekziston një vendim gjyqësor i formës së prerë për vepra penale tatimore apo doganore. Nëse subjekti është dënuar për evazion fiskal, kontrabandë apo vepra të ngjashme, borxhet e tij nuk do të falen. Ky ligj nuk synon të falë ata që me dashje kanë kryer krime financiare.
The law establishes several important exclusions, mainly to avoid “rewarding” serious fiscal offenders or those under investigation/court proceedings. Specifically, the following do not benefit from the forgiveness: (1) Taxpayers (individuals or businesses) for whom there is a final court decision for tax or customs criminal offences. If the entity has been convicted of tax evasion, smuggling, or similar offences, its debts will not be forgiven. This law does not aim to forgive those who have deliberately committed financial crimes. (2) Taxpayers who are currently under criminal investigation for tax/customs matters, until the investigation is concluded. (3) Taxpayers who have tax matters in court or in administrative appeal proceedings for the liabilities under dispute, unless they withdraw from the process. If you are in litigation with the tax/customs authorities regarding a liability, you must either win the case through the normal route or voluntarily withdraw the lawsuit/appeal in order to enter the forgiveness scheme. The law allows that, once the taxpayer withdraws the appeal or lawsuit, the liability is closed under the forgiveness conditions. However, if you continue the case and it ends with a final decision in favour of the tax administration, you will not have the right to forgiveness for that liability.
(3) Tatimpaguesit që kanë çështje tatimore në gjykatë apo në proces ankimimi administrativ. Për detyrimet objekt të gjykimit, përveç nëse heqin dorë nga procesi. Nëse jeni në gjyq e sipër me organet tatimore/doganore lidhur me një detyrim, duhet ose ta fitoni gjyqin në rrugë normale, ose të tërhiqni padinë/ankimin në mënyrë vullnetare për të hyrë në skemën e faljes. Ligji lejon që, pasi tatimpaguesi të heqë dorë nga ankimi apo padia, detyrimi i tij të mbyllet sipas kushteve të faljes. Por, nëse vijoni gjyqin dhe ai përfundon me vendim të formës së prerë pro administratës tatimore, atëherë nuk do të keni të drejtë për falje mbi atë detyrim.
If your liability arises simply from ordinary activity (e.g., unpaid tax, administrative fine, late-payment interest) and is not connected to a criminal offence or an active court process, you benefit from the forgiveness. If, on the other hand, you have been found to have engaged in deliberate evasion and have been criminally sanctioned, or are in the middle of an investigation/court case for this, then you are excluded from this amnesty. This ensures that the fiscal amnesty helps those with real financial difficulties, and not those who have committed serious intentional violations.
Which tax liabilities are forgiven?
The law categorises tax liabilities by time period and provides different treatment for each category. Below you will find which debts are fully erased, which are partially erased, and what the taxpayer must pay in each case. It is essential to identify which category your unpaid liabilities fall into to understand how much of your debt will be forgiven and how much (if any) you must pay to qualify.
The principles below apply equally to liabilities owed to the central tax administration, local administration (local taxes), and liabilities payable at customs (import VAT, customs duties, excise, etc.). Therefore, any reference to “tax liability” below also applies equally to customs liabilities for the relevant periods.
Liabilities for the period up to 31 December 2014
For all unpaid tax liabilities belonging to tax periods up to the end of 2014, the law offers full forgiveness, without conditions. This means that all unpaid local taxes, taxes, or fees up to 31.12.2014 are erased 100%, so the taxpayer does not need to pay either the principal (base liability) or fines/late interest, because everything is erased. This is a complete zeroing of old tax liabilities up to 2014, expected to release a significant part of debt.
For liabilities up to 31.12.2014 related to social and health insurance contributions, forgiveness is partial. 100% of all fines and late-payment interest related to contributions are erased, but the principal contribution amount must be paid by the taxpayer. The base amount of contributions is not forgiven for this period; for example, if an employer failed to pay contributions for 2012, they must pay the contribution amount, while all related fines and interest will be erased.
This exception exists because contributions are linked to pension and healthcare benefits. However, if the contributor has already paid the base contribution amount but only fines and late interest remained, these are automatically erased by the system.
Liabilities for the period up to 31 December 2014
Liabilities from 2015–2019 receive partial forgiveness, meaning part of the debt must be paid by the taxpayer and the remainder will be forgiven. The law provides two alternative schemes, and the taxpayer may choose whichever fits best:
Option A: Immediate payment of 50%
If the taxpayer pays 50% of the principal (base liability) by 30 June 2026, then the remaining 50% is erased (forgiven). In other words, you pay half the debt and the other half is forgiven. In addition, 100% of all fines and late-payment interest related to that liability are forgiven as soon as half the principal is paid. This option rewards taxpayers who can quickly mobilise half the liability, saving them the other half.
Option B: Instalment payment of 75%
If the taxpayer cannot pay half immediately, they may choose to pay equal monthly instalments until 31 December 2026, paying a total of 75% of the principal. In this scenario, 25% of the principal is forgiven (the state forgives one quarter, not half, because extra time is granted). In this case too, all fines and late-payment interest are erased 100% once the taxpayer has paid 75% of the principal within the deadline. Monthly instalments may extend throughout 2026 (the tax administration is expected to clarify instalment procedures in the implementing instruction). If you choose this option, it is important to strictly respect the instalment plan until the end of 2026, because failure to pay the full 75% within the deadline will make you lose the right to forgiveness.
What happens to penalties (fines/interest) for 2015–2019?
In both options, 100% of fines and late-payment interest linked to 2015–2019 liabilities are fully erased once the principal payment condition is met (either 50% by June 2026 or 75% by December 2026). The law also provides a special scenario: if for 2015–2019 the taxpayer has already paid the full principal, but only fines and late interest remain unpaid, then these penalties are erased automatically by the system (since the condition—payment of the base liability—has been fulfilled). So, if you have settled the tax but still have outstanding fines/interest for those years, they are forgiven without requiring any additional payment.
Example: Suppose a business has ALL 1,000,000 of unpaid tax liability from 2018 and has accumulated ALL 200,000 in fines and late interest. Under Option A, the business pays ALL 500,000 by 30 June 2026 and benefits from the erasure of the remaining ALL 500,000, together with full erasure of the ALL 200,000 in penalties/interest. Under Option B, the business may pay ALL 750,000 in instalments by 31 December 2026 (e.g., ALL 31,250 each month for 24 months) and benefits from forgiveness of the other ALL 250,000 and full erasure of the ALL 200,000 in penalties/interest. In both cases, once conditions are met, the 2015–2019 liability is zeroed and the business is released from the burden of old debt.
Liabilities for the period up to 31 December 2014
For liabilities from 2020–2024, the law takes a more limited (stricter) approach, as these are considered relatively recent debts that taxpayers normally should have paid and can still be settled. For this period, no part of the principal is forgiven; the state does not reduce the unpaid tax amount, but offers relief by erasing 100% of fines and late-payment interest, provided that the taxpayer pays the full principal by 31 December 2026.
In other words, if you have any unpaid tax from 2020–2024, you must pay 100% of that liability within 2026; as a reward, the state will forgive all related fines and late interest. If you do not pay the principal for those years, then there is no forgiveness at all—neither for the principal (which is not forgiven anyway) nor for fines/interest (the condition for forgiving them is payment of the principal). So, this measure for 2020–2024 is essentially full settlement of the base liability with removal of penalties, an opportunity for taxpayers to liquidate the debt without the burden of additional fines and interest.
Example: A company has ALL 300,000 unpaid tax for 2021 and ALL 60,000 penalties (fine and interest). Under the law, the company must pay ALL 300,000 (100% of the principal) by 31 December 2026, and once it does so, the ALL 60,000 penalties will be erased automatically.
Social and health insurance contributions (2015–2024)
The law treats social/health insurance contributions for 2015–2024 separately. The principle is the same as for 2020–2024: the taxpayer must pay 100% of the unpaid contribution by 31 December 2026, and the state forgives 100% of the related fines and late-payment interest. Although for ordinary taxes 2015–2019 allowed partial forgiveness of the principal (50% or 25%), for insurance contributions no principal forgiveness is provided, even for 2015–2019: contributions must be paid in full; only penalties are forgiven.
This scheme also applies to self-employed persons in agriculture, who have had special contribution schemes; they also benefit from forgiveness of fines/interest if they pay the overdue base contributions.
Example: A self-employed farmer has ALL 100,000 unpaid pension contributions for 2015–2020 and ALL 30,000 in fines and late interest. They must pay ALL 100,000 within 2026, and the full ALL 30,000 penalties will be forgiven.
Other liabilities automatically forgiven (fines and specific cases)
Beyond the major categories above, the law also clears various other accumulated liabilities often considered uncollectible or bureaucratic. These forgiveness measures are automatic, without requiring payment by the taxpayer, aiming to reduce administrative burden and clean records. The main categories are:
Liabilities of deregistered (closed) taxpayers up to 31.12.2024
If a business or individual has been closed (by court decision in the QKB or deregistered with taxes) and still has unpaid tax liabilities, all such liabilities are fully erased. These debts are considered hopeless to collect (the entity no longer exists), so they are removed from the system.
Automatic system fines for late filings up to 31.12.2024
These include administrative fines automatically imposed by the electronic tax system when a business delayed filing monthly/quarterly returns (e.g., VAT return, insurance return, etc.), regardless of whether the liability was zero. All such fines imposed up to end of 2024 are fully forgiven.
Fines for returns not filed at all (non-filing) for periods up to 31.12.2024
Where a taxpayer did not file a tax return at all for a period (e.g., did not file annual financial statements or a VAT return for a month), the law forgives the non-filing fines for those periods, provided the missing returns are submitted by 30 June 2026. Any missing return up to 2024 that is filed by 30.06.2026 will have its non-filing penalty erased.
Fines for late submission of financial statements up to 31.12.2024
These fines (usually issued when balance sheets are filed after the legal deadline) are fully erased.
Fines and interest from retrospective payroll adjustments
If a business corrects payrolls for past periods (e.g., declares someone at a higher salary late), penalties/interest can arise. The law forgives all fines and late interest created as a result of payroll changes in past periods.
Fines created from retroactive application of a legal act or court decision
Where a legal act or court decision is applied retroactively and generates penalties for taxpayers, those penalties are forgiven, so businesses are not penalised for events beyond their control.
Mechanism of offsetting with tax credits
A technical element (Article 8) concerns cases where the taxpayer has a credit surplus in their tax accounts. The law provides that before a tax liability is erased, the administration will offset that liability with any available tax credit you have. Only the remaining part after deducting the credit will be forgiven. An exception applies to social/health insurance contributions, which cannot be offset with credits from other taxes. For example, if you have a ALL 50,000 tax liability that would be forgiven and at the same time you have a ALL 20,000 unused VAT credit, the state will first offset ALL 20,000 against the liability, and only the remaining ALL 30,000 will be erased for free. This ensures forgiveness does not create unfairness (a taxpayer cannot receive both a cash benefit from the credit and forgiveness of the liability at the same time).
Procedure and deadlines: How to benefit from the forgiveness
The law is implemented automatically by the tax and customs administrations, but taxpayers must take certain concrete steps to meet the conditions. Below is a practical step-by-step guide:
Verify your unpaid liabilities up to 31.12.2024
Check your tax account in the tax portal (e-filing/e-tax), local tax liabilities, or customs liabilities. Compile a list of all liabilities shown as tax/customs debt (central taxes, local taxes, contributions and customs) and identify the period for each (up to 2014; 2015–2019; etc.).
File missing declarations (if any)
If you find unfiled returns for years up to 2024 (e.g., VAT return, annual profit tax return, financial statements, etc.), you must file them by 30 June 2026 for non-filing fines to be forgiven. The tax administration will automatically forgive non-filing fines once it receives overdue returns by 30.06.2026.
Filing does not impose tax unless there was an actual liability; many small businesses had non-filing fines even when activity was inactive, so filing now simply removes the fine.
Choose the payment option for 2015–2019 liabilities (if applicable)
Decide whether to follow: (a) immediate payment of 50% by 30 June 2026 (for forgiveness of the remaining 50%), or (b) instalment payment until 31 December 2026 for 75% (for forgiveness of the remaining 25%). Make a financial plan to ensure payments are made within the deadlines.
Plan payment of 2020–2024 liabilities
If you have tax/customs liabilities for 2020–2024, you must pay 100% of the principal. Plan your budget so you settle these principals during 2026, preferably as early as possible, because only after paying the full principal will fines/late interest be forgiven.
Settle social/health insurance contributions (if applicable)
For any unpaid pension or health contributions, ensure you pay the full contribution amount by 31 December 2026 to benefit from forgiveness of related fines and interest. This also applies to contributions for 2015–2019.
Withdraw appeals or lawsuits if you want forgiveness for those liabilities
If any unpaid liability is under administrative appeal or court proceedings, you must decide: either continue the legal process (and not benefit from forgiveness for that liability), or withdraw the appeal/lawsuit to enter the forgiveness scheme. The law requires explicit withdrawal before the liability can be forgiven.
Make payments within the prescribed deadlines
Execute payments within deadlines. Payments to the Tax Administration/Customs are made as usual (through the bank or online via e-Albania). It is vital not to exceed the deadlines, as the administration will monitor compliance.
Wait for confirmation of forgiveness
Forgiveness is applied by the tax and customs authorities, which will calculate automatically which liabilities meet the conditions and issue the relevant administrative acts. After you have paid what you owe and submitted the required documents, the tax systems will reflect the erasure of forgiven amounts. An administrative act (decision) will be issued by the Tax Directorate confirming forgiveness, officially notified and reasoned. Keep all documentation (payment orders, filing confirmations, etc.) in case questions arise.
Do not delay—use the forgiveness period!
Deadlines are non-negotiable: the scheme ends on 31 December 2026. If you do not meet the conditions in time, after that date your debts will remain normal obligations with all fines and late interest. The tax administration will very likely resume enforced collection procedures after the amnesty closes. This is a unique opportunity to restructure your fiscal situation—use it while it is available.
In most cases, the taxpayer does not need to submit a formal application; it is enough to meet the conditions above, and forgiveness is applied ex officio (by the administration itself). However, for any uncertainty or specific situation, do not hesitate to contact the tax administration or consult fiscal specialists to ensure the correct procedure is followed and no benefit is missed.
Frequently Asked Questions (FAQ)
The law applies until 31 December 2026. After that date you cannot benefit from forgiveness.
Yes. For 2015–2019 liabilities, if you pay 50% by 30 June 2026, the remainder is erased; or if you pay 75% (in monthly instalments) by 31 December 2026, 25% is erased.
All unpaid tax and customs liabilities up to 31 December 2014 are fully erased. (For social insurance contributions, only fines and late interest are forgiven, not the contribution principal.)
No. No special application is required; forgiveness and erasure are applied automatically once you meet the law’s conditions (e.g., payments within deadlines).
Only if you withdraw the lawsuit/appeal. Taxpayers with liabilities under court or administrative appeal can benefit only after withdrawing at any stage of the process.
Contributions must be paid 100%. The law forgives only fines and late interest (for periods up to end of 2024), provided the contribution is paid by 31 December 2026.
Yes. Customs liabilities are treated like taxes: full erasure for unpaid liabilities up to end of 2014 and partial forgiveness (with payment of 50% or 75% within 2026) for 2015–2019. In customs too, fines and late interest are forgiven when conditions are met.
Yes. Fines for unfiled or late-filed declarations up to 31 December 2024 are erased, provided any missing declaration is filed by 30 June 2026.
You must first offset the credit against unpaid liabilities. Only after deducting the credit can forgiveness apply to the remaining part of the liability. (This rule does not apply to social insurance contributions.)
Yes. Liabilities of deregistered (closed) businesses up to 31 December 2024 are fully erased by the administration.
Yes. Law No. 86/2025 includes unpaid local taxes in the forgiveness/erasure scheme if conditions are met.
No. The fiscal amnesty applies only to tax liabilities owed to the tax administration or customs (taxes, fees, contributions and related fines). Fines or sanctions from other institutions (e.g., for non-registration of beneficial owners) are not included.
In conclusion, the Fiscal Forgiveness Law 2025 is a golden opportunity for many taxpayers in difficulty: it reduces the financial burden, lowers the stock of tax debt, and cleans the system of liabilities carried for more than a decade. By following the guidance above, any affected entrepreneur or individual can simplify the process and benefit from legal relief without getting entangled in bureaucracy. Stay informed about implementing guidance issued by the Ministry of Finance, respect deadlines and conditions, and make sure you seize this chance to restructure your finances. Fiscal forgiveness is not “peace” forever, but it is certainly a welcome breathing space at this moment—use it wisely.
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