Deferral of fiscalization sanctions until 2022: a legal history

Key points
  • Normative Act No. 36, dated December 24, 2021, added a transitional provision to Law No. 9920/2008, postponing the implementation of sanctions for fiscalization until after June 30, 2022, for only three narrow categories of taxpayers.
  • The categories were: small businesses with simplified profit taxation that sell only for cash and are not registered for VAT, water suppliers and the regulated electricity market, and banks for e-bill payment notifications.
  • This deadline passed years ago, so today these categories are subject to the same invoicing rules as the rest of businesses.
Updated October 18, 2026. Published January 8, 2022. The original act provided for a specific transitional period until June 30, 2022. The content has been rewritten to document it as legal history, since the transitional period ended long ago.

Normative Act No. 36, dated December 24, 2021, of the Council of Ministers, added a transitional provision to Chapter XV of Law No. 9920, dated May 19, 2008, “On Tax Procedures in the Republic of Albania,” as amended. The amendment postponed the enforcement of sanctions for administrative violations related to Law No. 87/2019 “On the Invoice and the Monitoring System of Turnover” until after June 30, 2022, solely for three clearly defined categories of taxpayers.

From our daily work, we see that old references like this sometimes confuse small businesses, creating the impression that there may still be a grace period, even though this specific deadline passed more than four years ago.

Which categories were temporarily excluded?

The postponement applied only to taxpayers registered under the simplified profit tax for small businesses, not registered for VAT, who sold exclusively for cash to end consumers; to water suppliers for end consumers; and to the regulated electricity market; and banks or financial institutions, for notifying payments of e-invoices issued by taxpayers. Outside these three categories, the regulatory act did not change anything.

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Why does it matter today?

If your business falls into one of these three categories, the period for deferring sanctions ended on June 30, 2022. If you have any doubts about whether you are still compliant with fiscalization, contact your economist to verify, as non-compliance with current rules may result in full sanctions.

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About the author

Andi Haxhillari is an economist and the founder of AlProfit Consult, an accounting, tax advisory, and financial management firm in Tirana, established in 2015. He holds the professional title of Certified Accountant, certificate no. 359, issued by the Certification Authority of the Ministry of Finance on July 4, 2012. He graduated with a Master's degree in Accounting and as a General Economist from the Faculty of Economics at the University of Tirana. For more than ten years, he has worked as an external economist for small and medium-sized businesses in Albania.

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