Tax Amnesty 2026 and Forgiveness of Tax Penalties: A Complete Guide under Law No. 86/2025 and Directive No. 11/2026

Tax Amnesty 2026 is an extraordinary opportunity that the Albanian government has opened for businesses and individuals with outstanding tax obligations. Law No. 86/2025 waives tax obligations, erases fines and interest, and offers differentiated payment plans for different periods. But the law adopted in December 2025 remained unenforceable until it was issued. Instruction No. 11, dated May 14, 2026, which established the precise procedures for enforcement by the tax administration.

The law is now fully in effect. The first deadline for the largest benefit—the payment of 50% of the obligation for the 2015–2019 period—closes on June 30, 2026. After this date, the remaining option is payment of 75% by December 31, 2026. For obligations for the 2020–2024 period, only fines and late‐payment interest are waived, provided that the principal is paid in full by December 31, 2026.

This comprehensive guide explains who benefits, who is excluded, which tax fines are automatically waived, how the two payment options for the 2015–2019 period are calculated, how the tax credit offset mechanism works, and what steps you should take based on your specific situation.

Read also Fiscal Peace Agreement (Law No. 84/2025): a practical guide for entrepreneurs

What does Law No. 86/2025 provide?

Law No. 86/2025 “The initiative on the cancellation, waiver, and payment of tax obligations to the central and local tax administrations and of duties payable at customs is the broadest fiscal amnesty undertaken in Albania over the years.” Its purpose is to cleanse the tax system of liabilities accumulated over more than a decade, which in practice have become impossible to collect, mainly due to late‐payment interest and fines that have multiplied the original debts.

The law took effect on January 1, 2026, and applies until December 31, 2026. Therefore, all actions leading to amnesty must be taken within 2026. After this date, its provisions cease to apply and any remaining unpaid obligations revert to the normal regime, with all penalties.

This law should not be confused with the Fiscal Peace Agreement (Law No. 84/2025), which is an entirely different measure related to voluntary agreements for declaring earnings for future periods. The 2026 fiscal amnesty deals only with past unpaid obligations and does not impose conditions on taxpayers' future activities.

Instruction No. 11/2026 clarified five essential points.

Minister of Finance Directive No. 11, dated May 14, 2026, supplemented the framework laid out by the law and clarified several points that had created uncertainty in practice. Below are the key clarifications that change the specific way you must proceed.

Liabilities outside the electronic system are also waived

The guidance explicitly clarifies that automatic deletion is not limited to obligations recorded in the e-Tax information system but also covers those recorded solely in the manual accounting of the regional tax directorates. Many businesses have old liabilities that, for technical or administrative reasons, do not appear in e-Tax. If these liabilities relate to periods before December 31, 2014, they are deleted under the same conditions as those in the system.

The date of the document determines the period, not the date of accounting.

This is one of the most practically valuable clarifications. If the constatation act or the notice of liability bears the date December 31, 2014 or earlier, the liability is subject to deletion, regardless of whether it was recorded in the system years later. But be careful, this case is not handled automatically. The deletion is carried out manually by the regional offices, so if you are in this situation you must contact the regional tax directorate and request the manual procedure.

Example. A business received a tax assessment dated October 2014, but the liability was entered into the system in February 2015. According to the guidance, this liability pertains to the period before December 31, 2014, and is deleted regardless of the date of accounting.

Closed businesses are fully forgiven, regardless of the period

For entities deregistered from the QKB or administratively by December 31, 2024, all obligations, principal, fines, and late-payment interest are canceled, regardless of the tax period. No payment is required. There is no distinction between 2016 and 2023. The deletion is carried out automatically. The only exception is social security and health insurance contributions, for which the principal is never deleted.

Many former administrators or partners of dissolved companies don't realize that old liabilities still appear in the tax system. The 2026 tax amnesty is the chance to finally close those chapters.

Fines for DIVA are waived without the need to submit the declaration

Individuals with fines for failure to file the Annual Individual Income Tax Return (DIVA) for periods up to December 31, 2024, benefit from automatic cancellation without having to submit the unfiled returns. This clarification is of practical value for individuals with income from rent, dividends, or other taxable sources who have accumulated fines for past periods.

The deadline to withdraw the appeal is November 30, 2026.

Taxpayers who are in the process of administrative or judicial appeal may enter the amnesty procedure only if they withdraw their appeal. The waiver is submitted by an official request to the relevant Regional Tax Directorate before the payment of the principal amount, but no later than November 30, 2026. The decision is irrevocable, so it requires careful analysis before undertaking it.

Full table of deadlines

Below are the key deadlines of the law, organized by type of obligation and condition of benefit.

Situation	Payment term	Deadline	What do you gain?
Tax obligations as of December 31, 2014	No payment required	Automatic	Waiver of 100% of the principal, fines, and late fees.
Liabilities 2015–2019 (Option A)	Payment of the 50% principal in a lump sum.	June 30, 2026	Deduction of the remaining 50% + 100% in fines and late fees
Liabilities 2015–2019 (Option B)	Payment of 75% of the principal	December 31, 2026	Deletion of the remaining 251 TP3T plus 1,001 TP3T in fines and late-payment interest.
Obligations 2020-2024	Payment of 100% of the principal	December 31, 2026	Waiver of 100% fines and interest charges
Social and health contributions 2015–2024	Payment of the 100% contribution	December 31, 2026	Waiver of fines and late fees
Unsubmitted Declarations (non-filing fines)	Submission of missing statements	June 30, 2026	Dismissal of failure-to-declare fines
Businesses deregistered by December 31, 2024	Without condition	Automatic	Deletion 100% of all obligations
Active Administrative or Judicial Appeal	Official waiver of the appeal	November 30, 2026	The right to access the amnesty procedure

Who benefits from the forgiveness of tax obligations?

The law has been drafted in a very comprehensive manner. All taxpayers—businesses or individuals—who have unpaid tax obligations to the central tax administration, unpaid local taxes, or unpaid customs duties are eligible to benefit. The taxpayer's current status does not matter. Both active and passive (suspended) taxpayers, deregistered (closed) taxpayers, or those with any other status in the e-Tax system are eligible.

Even if the business was closed years ago but still has unpaid obligations in the system, it falls within the scope of this law's beneficiaries. Likewise, entities indebted to customs (importers with outstanding customs duties) enjoy the same debt-forgiveness opportunities.

In short, any taxpayer with tax or customs debts recorded as of December 31, 2024, may qualify for the benefits of the amnesty, except for the specific cases excluded below. This makes the 2026 fiscal amnesty one of the broadest tax amnesty campaigns ever undertaken in Albania.

Who is excluded from forgiveness?

The law has established several important exceptions, with the aim of not rewarding serious tax violators or those who are under investigation or judicial proceedings. The following do not benefit from the amnesty:

1. Taxpayers (individuals or businesses) against whom there is a final court ruling for tax or customs criminal offenses. Thus, entities convicted of tax evasion, smuggling, or similar offenses do not benefit.
2. Taxpayers who are currently under criminal investigation for tax or customs matters, until the investigation is concluded.
3. Taxpayers who have a final court decision in favor of the Tax or Customs Administration regarding the duties that are the subject of the benefit.
4. Taxpayers in administrative or judicial appeal proceedings, unless they withdraw their appeal by November 30, 2026.

If your obligation arose solely from everyday activity (unpaid tax, administrative fine, late interest) and is not connected to a criminal offense or an ongoing legal proceeding, you benefit from the amnesty. If you are in the appeals process and believe your case is more favorably resolved through amnesty, you may withdraw your appeal to enter the scheme.

Which tax obligations and fines are waived?

The law divides obligations by time period and provides different treatment for each category. Accurately identifying the period is essential to understand how much of your debt is forgiven and how much you must pay to qualify.

The following principles apply equally to obligations to the central tax administration, local taxes, and customs duties. Any reference to “tax liability” also covers customs duties for the relevant periods.

Liabilities for the period up to 31 December 2014

For all unpaid tax liabilities relating to periods up to December 31, 2014, the law provides a full amnesty, with no payment conditions. All unpaid taxes, local taxes, fees, and customs duties are 100% canceled. The taxpayer is not required to pay either the principal, the fines, or the late‐payment interest.

Social security and health insurance contributions are an exception. Even for this period, the principal of those contributions is not waived because it is tied to pension and health care benefits. All penalties and their interest are canceled, but the principal must be paid.

So if an employer still owes unpaid contributions for 2012, they are only required to pay the amount of the contributions, while all associated fines and interest are automatically waived.

Liabilities for the period from January 1, 2015 to December 31, 2019

For this period, the law provides a partial waiver. A portion of the principal must be paid; the rest is forgiven. The taxpayer may choose between two options.

Option A. Immediate payment 50%

The taxpayer pays 50% of the principal by June 30, 2026. As a result, the remaining 50% of principal is written off, and 100% of penalties and late‐payment interest are also written off. This option rewards taxpayers who have the liquidity to mobilize payment immediately.

Option B. Payment of 75%

If you cannot pay 50% by June 30, you may pay 75% of the principal by December 31, 2026. In this case, 25% of the principal is forgiven, and 100% of penalties and late‐payment interest are also waived. So the state forgives a quarter instead of half, since it is giving you additional time.

In both options, as soon as the payment condition is met, the fines and late fees are automatically waived. In fact, if you have already paid the entire principal for the 2015–2019 period and only the fines and late‐payment interest remain, the latter will be waived without any additional payment.

Specific example. A business has an unpaid tax liability of 1,000,000 LEK from 2018 and 200,000 LEK in accumulated fines and late fees. Under Option A, the business pays 500,000 LEK by June 30, 2026, and receives forgiveness of the remaining 500,000 LEK plus 200,000 LEK in fines and late fees. With Option B, the business pays 750,000 LEK by December 31, 2026, and receives forgiveness of another 250,000 LEK plus 200,000 LEK in fines and interest. In both cases, the liability for the years 2015–2019 is zeroed out.

Liabilities for the period from January 1, 2020 to December 31, 2024

For this period, the approach is more limited. The principal (the underlying obligation) is not forgiven at all. However, if the taxpayer pays 100% of the principal by December 31, 2026, then 100% of penalties and interest will be waived.

Therefore, for obligations 2020–2024, there is no reduction in the amount of unpaid tax. The relief lies in the removal of all penalties for delays, which are often substantial compared to the principal. If you do not pay the principal, there is no forgiveness—neither of the principal (which in any case is never forgiven) nor of the fines (which are contingent on payment).

A concrete example. A company has 300,000 LEK in unpaid tax from 2021 and 60,000 LEK in penalties. Under the law, the company must pay 300,000 LEK by December 31, 2026. Once paid, the 60,000 LEK in penalties are automatically waived. The company has paid only the tax it actually owed in 2021, without the burden of penalties.

Social Security and Health Insurance Contributions (2015–2024)

The principal of contributions is never forfeited, regardless of the period. This is the general principle of insurance law, because the principal is tied to the pension and health care benefits of the contributor.

But penalties and interest on contributions for the 2015–2024 period are 100% waived, provided the principal is paid in full by December 31, 2026. Although a partial waiver of principal is allowed for ordinary taxes for the 2015–2019 period, there is no principal waiver for contributions for any period.

This scheme also applies to self-employed farmers, who have separate contributory schemes. They benefit from the waiver of fines and late-payment interest if they pay their outstanding basic contributions within the deadline.

Fines and specific cases that are automatically waived

In addition to the above categories, the law automatically forgives a number of fines and obligations without requiring payment from the taxpayer. These cases clear the records of obligations that, in practice, were uncollectible or bureaucratic.

Tax obligations of taxpayers registered until December 31, 2024. If a business or individual has been closed (by a court decision in the Commercial Register Court or deregistered for tax purposes) and has outstanding tax liabilities, all of these liabilities are fully forgiven. The only exceptions are social and health contributions.

Automatic system penalties for late filings until December 31, 2024. Administrative fines automatically imposed by the electronic tax system for delays in filing returns (VAT, insurance, etc.) are fully waived. Many small businesses had accumulated fines simply because they filed a return late, even when they had no tax to pay.

Fines for completely unfiled declarations (non-declaration) until December 31, 2024. If the taxpayer has not filed any tax return for a given period (VAT return, financial statement, annual return), the failure-to-file penalties are waived, provided that the missing returns are filed by June 30, 2026. DIVA is an exception, as it is waived without the need to submit the missing return.

Fines for late submission of financial statements and the resolution on the allocation of the result by December 31, 2024.These fines (imposed when financial statements are filed after the legal deadline) are completely waived.

Fines and late-payment interest resulting from retrospective payroll changes. When a business corrects its payroll records for past periods, fines and interest are normally charged. The law waives all of these for changes resulting from legislative or regulatory acts with retroactive effect, or from final court judgments.

Administrative fines for periods up to December 31, 2024. All administrative tax fines for this period are waived.

Mechanism of offsetting with tax credits

Before the tax administration writes off a liability, it checks whether you have a credit balance in your tax accounts, for example a VAT or other tax surplus. If you do, that surplus is automatically applied against the liability, and only the remaining amount is forgiven.

Social security and health insurance contributions are an exception. Contribution obligations cannot be offset with credits from other taxes.

Example. If you have 50,000 LEK in tax liability that would be forgiven and at the same time 20,000 LEK in unused VAT credit, the administration will first deduct 20,000 LEK from the liability (offsetting that portion with your credit), and only 30,000 LEK of the remaining amount is forgiven. This mechanism ensures that the benefit of the credit and the benefit of the forgiveness do not unfairly accumulate.

Step-by-step procedure to benefit from the amnesty

The tax administration automatically enforces the law, but the taxpayer must take concrete steps to meet the requirements and avoid losing benefits. Below is the complete practical procedure.

Step 1. Verify your obligations in e-Filing.

Log in to your e-Filing account and review all outstanding obligations. Break down the obligations by periods (up to 2014, 2015–2019, 2020–2024) and by type (central tax, local tax, contributions, customs duties). This breakdown is essential to understand which amnesty schemes apply to you.

Within 20 days of the entry into force of Directive No. 11/2026, each regional tax directorate compiles the list of taxpayers benefiting from the deletion and the list of those excluded. The relevant notification is sent to you electronically via e-Filing.

Step 2. Submit the missing statements.

If during the verification you find that you have undeclared returns for periods up to December 31, 2024 (VAT return, annual corporate income tax return, financial statements), submit them by June 30, 2026. As soon as the tax administration receives the overdue returns within the deadline, the penalties for failure to file are automatically waived.

DIVA is an exception. For her, fines are waived without having to submit the missing statements.

Step 3. Select the payment option for the 2015–2019 obligations.

If you have obligations from this period, decide which option you will follow. Option A (50% until June 30, 2026) saves you more money. Option B (75% until December 31, 2026) gives you more time. The choice depends on your ability to pay. If you're undecided, assess your business's cash flow over the next six months.

Step 4. Plan the payment of obligations for 2020–2024

For this period, you must pay 100% of the principal by December 31, 2026, to benefit from the waiver of fines and late fees. If possible, pay early, not at the last minute, because the system is expected to be heavily loaded during December.

Step 5. Pay social security and health contributions.

For any unpaid contributions (whether as an employer or as a self-employed individual), pay the full principal amount by December 31, 2026. Only then will the penalties and late-payment interest be waived. This also applies to contributions for the 2015–2019 period, where, unlike with taxes, the principal is never forgiven.

Step 6. Give up complaining if you think it's worth it.

If you have a liability currently under administrative or judicial appeal and you determine that entering amnesty is more favorable than continuing the appeal, submit an official waiver request to the Regional Tax Directorate. The deadline is November 30, 2026, but the request must be submitted before the principal payment is made.

The decision is irrevocable. If you withdraw and then change your mind, you cannot reinstate the appeal. Consult your accountant or tax advisor before making the decision.

Step 7. Make payments on time.

Payments are made as usual through the bank or via the electronic system on e-Albania. Keep every payment receipt as documentation. You may make partial payments early and complete them on time; this is allowed.

Step 8. Wait for confirmation from the administration.

Once you have paid what you owe and submitted the documents, the administration automatically reflects the deletion in your account. For each taxpayer, an individual administrative act is issued confirming the pardon or exemption. This act can be appealed to the administrative court if you disagree with it.

Check if you qualify for amnesty with our online tool.

To quickly understand whether you qualify and what steps you need to take, we have created a simple assessment tool. Based on your category (active business, closed business, individual), the type of obligation, and the period, the tool tells you whether you qualify, which option is most favorable, and what the next step is.

Check if you qualify →

Why it Matters

Tax amnesty is rare. Law No. 86/2025 is one of the broadest measures of tax forgiveness in years. But laws without implementing guidelines remain procedural frameworks. Instruction No. 11/2026 turned this law into something concrete and actionable.

Taxpayers with liabilities from 2015–2019 who choose the June option can save about half of their debt plus all fines and late-payment interest. Businesses that have closed with old liabilities can permanently close those chapters without paying anything. Individuals with automatic fines or DIVA fines need not take any action; the deletion is carried out automatically.

The deadline will not be extended. The procedure now exists. The next step is yours.

Frequently Asked Questions about the 2026 Tax Amnesty

Until when can you benefit from this law?

The law applies until December 31, 2026. After this date, no amnesty benefits may be claimed. The first deadline for the greatest benefit—payment of 501 TP3T of the principal for obligations from 2015 to 2019—closes on June 30, 2026.

Can I pay only part of the liability and have the rest forgiven?

Yes, for the 2015–2019 obligations. If you pay 50% of the principal by June 30, 2026, the remaining 50% is forgiven. If you pay 75% of the principal by December 31, 2026, 25% of the remaining balance is forgiven. In both cases, penalties and late-payment interest are 100% forgiven.

Which liabilities are fully forgiven automatically?

All unpaid tax and customs obligations as of December 31, 2014 are 100% canceled. The social contributions principal is the exception, as it is never forgiven, but its fines and late‐payment interest are automatically canceled. Also, obligations of businesses that have been deregistered as of December 31, 2024, are automatically canceled.

Do I need to apply to benefit from forgiveness?

No, no separate application is required. The waiver is applied automatically by the administration once you meet the legal requirements (timely payments, submission of missing returns, etc.). Only to withdraw an appeal is an official request to the Regional Tax Directorate required.

Are obligations that are the subject of litigation or appeal forgiven?

Only if you withdraw the complaint or appeal before November 30, 2026. The withdrawal is officially submitted to the tax or customs authority and is irrevocable.

Are social insurance contributions included in the forgiveness?

Partially. The principal of contributions is never waived, regardless of the period. However, penalties and their late-payment interest are fully waived, provided that the contribution is paid in full by December 31, 2026. For the period before December 31, 2014, fines and late‐payment interest on contributions are waived unconditionally.

Are customs liabilities also included?

Yes. Customs duties are treated the same as taxes. Full cancellation for duties up to December 31, 2014, partial relief (Option A: 50% or Option B: 75%) for duties for the 2015–2019 period, and forgiveness of penalties and interest for the 2020–2024 period, provided the principal is paid in full.

I have tax returns that haven't been filed. Are the penalties waived?

Yes, provided that the missing returns are filed by June 30, 2026. Once you file the returns, any penalties for non-filing or late filing are automatically waived. The only exception is DIVA, which is forgiven without requiring you to file the missing return.

What if I have a credit balance (e.g., VAT credit)?

A credit excess is first offset against outstanding liabilities, and only the remaining amount is forgiven. This rule applies to taxes but not to insurance contributions.

If the business is closed, are its liabilities forgiven?

Yes. The obligations of businesses deregistered by December 31, 2024 are automatically and completely wiped out, regardless of the period. The only exceptions are social security and health contributions.

Are local tax obligations included?

Yes. Law No. 86/2025 also includes unpaid obligations for local taxes under the same terms and deadlines as central taxes.

Are administrative penalties from other institutions included (e.g., for beneficial owners)?

No. Tax amnesty applies only to obligations to the tax or customs administration. Administrative fines imposed by other institutions, such as for registering beneficial owners with the Central Registry of Beneficial Owners (QKB), are not included.

How will I know if my liabilities have been written off?

The tax administration sends an official notice via e-Filing and issues an individual administrative act for each taxpayer. You can also verify in your tax account that the liability balances have been zeroed out.

Is there a limit on businesses facing criminal tax proceedings?

Yes. Taxpayers who have been convicted by a final court ruling or are under investigation for tax or customs offenses do not benefit from the amnesty. Their list is prepared by the tax authorities and updated every month.

Can I make payments in installments for Option B (75%)?

Yes, the law provides for monthly installment payments of equal amounts until December 31, 2026. The exact procedure for installment payments is detailed in Instruction No. 11/2026. If you choose this route, strictly adhere to the installment plan, because failure to pay the full 75% within the deadline will cause you to lose the waiver.