Albania has around 1,200 private hospitals, clinics, and medical centers. Tens of thousands of individuals work in them, from surgeons to receptionists. And almost none of them declare their actual salaries.
This fact was made known during the latest announcement of To the Tax Administration. Not a technical price list. But a clear signal that the government knows, has the data, and has decided to act.
What exactly happened, what it means legally, how much the additional cost is, and what you need to do now are the questions we address in this article.
What Did the Tax Administration Publish?
The General Directorate of Taxes has published Indicative payroll list for 39 professions in the medical and aesthetic sector. Along with the list, it has also arrived. Official messageAny taxpayer who declares wages below the indicative thresholds will be classified as a tax risk subject and will be subject to verification by specialized units.
The notice also specifies something else that should not be overlooked without analysis and reflection: the artificial alteration of the job title—namely, listing a physician as an “assistant” or a nurse as a “service worker” to lower the declared salary—will be treated as an infringement and verified.
Some of the indicative levels, according to the official document, are:
- Specialized Surgeon (Neuro / Cardio / Orthopedics / Plastic Surgery): 215,000 LEK/month
- Anesthesiologist / Intensive Care: 215,000 LEK/month
- Pediatrician / Gynecologist / Neonatologist: 210,000 LEK/month
- General Practitioner: 163,000 LEK/month
- Family Physician: 165,000 LEK/month
- Dental and Oral Surgeon: 170,000 LEK/month
- Dentist and Stomatologist: 110,000 LEK/month
- Head Nurse: 125,000 LEK/month
- General Nurse: 100,000 LEK/month
- Pharmacist: 110,000 LEK/month
- Medical Laboratory Technician: 100,000 LEK/month
- Receptionist / Medical Secretary: 85,000 LEK/month
- Esthetician and Cosmetologist: 80,000 LEK/month
- Personal Trainer: 120,000 LEK/month
- Barber and Hairstylist: 75,000 LEK/month
The full list of 39 professions is available at official page of Taxes.
Any declaration below the indicative threshold categorizes the taxpayer as a high-risk subject. This is not a warning. It is an automatic tax analysis procedure.
It's Not the First Time: How It Began with Construction
To understand the true weight of this announcement, you need to put it in the proper context.
In December 2025, the Tax Administration published Guiding wages for the construction sector. Salaries ranged from 80,000 to 160,000 LEK, with engineers between 115,000 and 150,000 LEK, and the crane operator as the highest category. Along with the list, it was announced that the focus of tax inspections from December 2025 will be primarily on construction entities with wages below the indicative threshold.
What happened after that announcement? Data from INSTAT for the fourth quarter of 2025 show that construction costs rose by 6 percent year-over-year, with wage expenses being the main driver of the increase. The question of whether construction firms raised wages voluntarily or did so under tax pressure remains open, but it is very likely a combination of both.
Now, three months after the previous one, the tax authorities are turning to medicine and aesthetics. And there's nothing to suggest that this will be the last sector.
Construction, then medicine and aesthetics. Which one will be third? Strategic logic suggests sectors with high informality and relatively easy control: tourism, gastronomy, private education, retail services.
Read also: Social Security and Health Insurance: Rates and Calculation for 2025
Is There a Legal Basis? Analysis of the Most Important Question
This is the question that many avoid, but which has practical importance. Are indicative salaries legally binding?
Legal basis
Indicative salaries are not a decision of the Council of Ministers. They are not a tax directive with normative effect. They are not the minimum legal wages under the Labor Code. Legally, they are an internal administrative act of the Tax Administration, based on its authority to conduct risk analysis.
The legal basis is found in Law No. 9920/2008 “On Tax Procedures”, as amended. Specifically, the provisions that grant the Tax Administration the authority to assess taxpayers based on risk indicators and to reconstruct the tax base when there is credible reason to believe that the declared data do not reflect reality. Article 69 of the law provides the tax authority with the right to determine the tax base indirectly, relying in particular on comparisons with similar activities and sectoral norms.
So, the list doesn't force you to pay that salary. But it automatically puts your business under audit if you declare below the threshold. And during the audit, you have to prove that your declared salary is real and justified, not the tax authorities.
Where the Fundamental Problem Lies
The problem is not only legal. It is also methodological. The indicative pay list was published without any explanation of how it was constructed. It is not known whether it is based on data from previous inspections, market surveys, public sector figures, or any kind of statistical methodology. There has been no public consultation with private medical sector associations. There is no transition period.
This is precisely the opposite of what countries with consolidated tax systems do. And this makes the list legally challengeable, even if it isn't necessarily challenged in practice, because small businesses rarely have the resources and capacity to initiate appeal procedures.
If you receive a tax verification notice, you have the right to appeal. But the burden of proof is on you: you must demonstrate with documentation that the declared salary is genuine and in accordance with the specific conditions of your business.
Objective Factors That May Justify Salaries Below the Indicative Level
The law doesn't forbid you from justifying yourself. Some objective arguments that might hold up during a verification are: low activity volume, especially for businesses with part-time work, local market conditions outside Tirana, where real wages differ significantly, service contracts or other forms of non-traditional employment, and the individual's actual pay history, if it has been stable and documented.
None of these arguments guarantees success, but good documentation is the difference between a manageable audit and a severe penalty.
How This Is Done Elsewhere: Examples from Around the World
The practice of sectoral references to combat tax evasion is not an Albanian invention. But the way it is implemented differs radically.
Italy and “Studi di Settore”
Italy, the country we are so often compared to, has been experimenting for decades with similar instruments. Since the 1990s, the Agenzia delle Entrate has implemented “Industry Studies“Detailed sectoral studies on the typical revenue and turnover of each business category, built on real statistical data from millions of entities.
This system, although it had known flaws, had several essential characteristics. It is based on statistical models using data collected over the years. It consults with professional associations and the chamber of commerce. It issues a notice of agreement before any verification, giving the taxpayer the opportunity to explain any discrepancies. And it provides clear appeal procedures.
Italy abandoned this system in 2019 and replaced it with ISA (Synthetic Index of Tax Reliability), Synthetic indicators of fiscal reliability, a system with a completely different logic: not penalizing those who are “below standard,” but rewarding those with high reliability with administrative advantages.
Italy tested the sectoral benchmarking system for 25 years and abandoned it. Key findings: it functions as a pressure mechanism but does not reduce structural tax evasion without simultaneously addressing excessive taxation and market informality.
Greece and the Limits of Tax Pressure
Greece is the most culturally proximate example. With an informal economy estimated over the years at between 20 and 30 percent of GDP, Greek administrations have tried various forms of sectoral pressure, often with limited results. Studies conducted by organizations such as Dianeosis have highlighted the central paradox: the self-employed and small businesses have historically hidden 57 to 58 percent of their revenues, whereas formal employees manage to hide only about 0.5 to 1 percent. Therefore, formal oversight has clear limits if the structure of the informal economy is not simultaneously addressed.
Lessons from Greece suggest that without formalization incentives, tax pressure drives businesses toward alternative forms of evasion rather than transparency.
What We Can Learn from These Examples
All of these systems have done something that is completely missing from the Albanian list: transparent methodology, consultation with the sector, a transition period, and incentive mechanisms for those who voluntarily formalize. Albania has gone straight to the pressure phase without going through the preliminary stages.
Read also: Tax Law Changes 2026: What's Changing for Businesses
What It Really Costs: Three Scenarios
The calculations below are based on the current insurance rates under the legal framework as of January 2026. The employer pays 15 percent social security contributions and 1.7 percent health insurance, for a total of 16.7 percent of gross pay. Current wages are an estimate based on market information, assuming that typical businesses report between 60 and 65 percent of the indicative wage.
The table shows only the effect of employer contributions. Payroll tax falls on the employee, not the employer, and is not included here.
Scenario A: Small Dental Practice, 5 Employees
This model refers to a typical dental practice with one dentist, one dental technician, two medical assistants, and one receptionist. It is the most common private small medical business model.
| Position | Current salary (LEK) | Indicative salary (LEK) | Gross difference |
|---|---|---|---|
| Dentist | 68.000 | 110.000 | +42.000 |
| Dental Technician | 52.000 | 80.000 | +28.000 |
| Medical Assistant | 55.000 | 85.000 | +30.000 |
| Medical Assistant | 55.000 | 85.000 | +30.000 |
| Receptionist | 55.000 | 85.000 | +30.000 |
| Gross total/month | 285.000 | 445.000 | +160.000 |
| Employer contributions (16.7%) | 47.595 | 74.315 | +26.720 |
| Total employer cost/month | 332.595 | 519.315 | +186.720 |
Annual cost increase: approximately 2,240,000 LEK, or about 22,400 EUR.
For reference, this amount is equal to the annual net profit of many small dental practices. It's not marginal cost; it's a structural shift in the financial model.
Scenario B: Average Medical Clinic, 10 Employees
This model refers to a clinic with 2 general practitioners, 1 specialist, 2 nurses, 1 head nurse, 1 pharmacist, 1 lab technician, 1 imaging specialist, and 1 receptionist.
| Position | Current salary (LEK) | Indicative salary (LEK) | Gross difference |
|---|---|---|---|
| General Practitioner | 100.000 | 163.000 | +63.000 |
| General Practitioner | 100.000 | 163.000 | +63.000 |
| Specialist (Cardiologist) | 120.000 | 200.000 | +80.000 |
| Nurse | 65.000 | 100.000 | +35.000 |
| Nurse | 65.000 | 100.000 | +35.000 |
| Head Nurse | 80.000 | 125.000 | +45.000 |
| Pharmacist | 70.000 | 110.000 | +40.000 |
| Medical Laboratory Technician | 65.000 | 100.000 | +35.000 |
| Imaging / Radiology | 65.000 | 100.000 | +35.000 |
| Receptionist | 55.000 | 85.000 | +30.000 |
| Gross total/month | 785.000 | 1.246.000 | +461.000 |
| Employer contributions (16.7%) | 131.095 | 205.813 | +74.718 |
| Total employer cost/month | 916.095 | 1.451.813 | +535.718 |
Annual cost increase: approximately 6,430,000 LEK, or about 64,300 EUR.
This additional figure would have to be fully covered by increases in service prices or by reductions in other costs. In a medical market where prices don't rise easily and patients are cost-sensitive, this pressure is very real.
Scenario C: Private Clinic or Hospital, 20 Employees
This model refers to a structure with surgeons, anesthesiologists, various specialists, a full nursing staff, and administrative personnel.
| Category | Current cost/month (LEK) | Indicative cost/month (LEK) | Growth |
|---|---|---|---|
| Gross total (20 employees) | 1.713.000 | 2.756.000 | +1.043.000 |
| Employer contributions (16.7%) | 286.071 | 440.796 | +154.725 |
| Total employer cost/month | 1.999.071 | 3.196.796 | +1.197.725 |
Annual cost increase: approximately 14,370,000 LEK, or about 143,700 EUR.
For organizations of this size, this isn't just an accounting problem. It's a strategic decision: how do you re-engineer the business model when labor costs rise by 60 percent overnight, in theory?.
These calculations show only the effect of social security contributions and gross wages. Payroll taxes affect the employee, but they also have indirect effects: changes in net pay can, and will, influence employees' expectations and the employer's ability to recruit.
Read also: How to Build a Financial Plan That Works for Your Business
The Real Questions That Need to Be Asked
The public discussion about indicative salaries has been superficial, focusing mainly on whether they are “fair.” But the real questions are much more complicated.
Is this wage level attainable for the private sector?
The public health system pays doctors well below the announced indicative levels. A general practitioner in the public sector receives around 80,000 to 100,000 LEK. The indicative list shows 163,000 LEK for the same profile. If the private sector is de facto forced to pay 163,000 LEK, there are two outcomes: either private service prices rise sharply, or the well-intentioned public-sector doctors intensify their departure to the private sector. Neither is necessarily bad, but neither is planned or managed.
Is the medical job market homogeneous?
The list applies the same indicative salary for Tirana and for Shkodër, Saranda, and Gramsh. A small family clinic in Peshkopi and a medical center in downtown Tirana operate under completely different market conditions: different volumes, different service prices, and different levels of competition. The list makes no distinction.
What happens with the other forms of cooperation?
The medical sector has a variety of employment relationships: part-time doctors, doctors on service contracts, and collaborating doctors without a formal employment relationship. The indicative list appears to refer to the monthly salaries of employees on a standard employment contract. But what about the doctor who works two days a week in a private clinic and three days in a public hospital? No official clarification has been issued.
Does formalization bring real pressure or the reconfiguration of structures?
This is the greatest risk of such instruments, and their international history bears witness to it. When the cost burden rises suddenly and without a gradual phase-in, businesses often fail to formalize. They find alternative forms: reconfiguring contracts as external services, splitting the structure into small legal entities, or simply shifting wages into the gray market—formally recorded at a lower level but compensated informally outside the system. Italy and Greece learned this the hard way.
Are there effective appeal mechanisms?
Theoretically, yes. But tax appeals in Albania are lengthy, costly, and uncertain. Small businesses, those with 3 to 10 employees, do not have the real capacity to initiate legal proceedings against the Tax Administration. The practical effect is that the pressure is felt many times more severely by small businesses than by large ones, even if the law formally treats them the same.
Concrete Steps You Need to Take
Regardless of your assessments of the policy's fairness, your response should be measured and based on facts, not on fear or indifference.
Step 1: Analyze Your Current Payroll
Compare each position against the indicative list. Identify the gap for each employee. This gives you an accurate picture of your current tax exposure and helps you understand whether you are in the high, medium, or low risk zone.
Step 2: Calculate the Total Cost of Formalization
Don't focus only on the difference in gross pay. Also calculate the employer's contributions (16.71%), the employee's payroll taxes (if the rate changes), and the effect on service prices. This figure shows whether gradual formalization is possible without structural changes, or whether it requires a complete overhaul of the business model.
Step 3: Check Position Titles
The Tax Administration has explicitly stated that it will verify cases of artificial reclassification. Ensure that every declared position corresponds to the employee's actual function. Notations such as “service employee” for someone performing nursing duties are precisely what the system aims to identify.
Step 4: Document Your Specific Business Conditions
If there are objective reasons justifying salaries below the indicative level, document them. Low activity volume, part-time contracts, local market conditions, years of experience, and salary history are all possible arguments. A solid documentation file is very valuable if a review takes place.
Step 5: Consult before any change.
Do not make hasty changes without consulting. Raising wages under pressure without careful financial planning can create new problems: contractual issues with employees if not everyone is treated equally, financial issues if margins don't cover the additional cost, and tax issues if the changes aren't properly documented.
The View from Both Sides
This discussion deserves a full analysis, not just from one side.
From a tax perspective, the argument has real merit. The informality of wages in the private medical sector is documented and widely acknowledged. Doctors with formal salaries of 60,000 to 80,000 LEK, while the clinic bills services at prices suggesting much higher incomes, is a reality and not speculation. An employee working for low undeclared wages loses significant social and health benefits, and this harm to him is real.
From the businesses' perspective, the argument also has merit. The margins of small private clinics are often very narrow, especially in the early stages of operation. Operating costs, medical equipment, rent, electricity bills, and administrative expenses are real and high. A sudden 50 to 60 percent increase in wage costs, without a transition period or support mechanisms, can destabilize financially healthy businesses.
Both perspectives are valid. The right solution lies somewhere in the middle: gradual formalization, transparent methodology, sectoral consultation, and support mechanisms for small businesses taking the step to formalize. All of these are missing from the current form of the list.
Frequently Asked Questions (FAQ)
Am I legally required to pay salaries according to the indicative list?
No, not directly. The list does not have the force of a regulatory act. But if you declare below the indicative threshold, the business is automatically classified as a taxpayer at risk and becomes subject to verification. The practical effect is very similar to an obligation.
What happens if I get verified and can't justify my salary?
The tax authority reconstructs the tax base and levies an additional tax on the differences, together with the fines and interest provided for by Law No. 9920/2008 “On tax procedures"“Fines for failing to declare or for inaccurately declaring wages can be severe. There is a right to appeal, but the process is lengthy.
Does the list affect businesses in the aesthetics sector?
Yes. The list includes barbers (75,000 LEK), aestheticians and cosmetologists (80,000 LEK), manicurists and pedicurists (80,000 LEK), and gymnastics and sports instructors (80,000 LEK). The personal trainer has the highest indicative rate in this category, at 120,000 LEK.
Can I challenge the list if local market conditions are different?
Yes, this is a legal possibility. But the burden of proof is on you: you must present concrete documentation, such as employee contracts, pay history, activity certificates, and objective evidence regarding local market conditions.
What happens to the doctor who works part-time?
The list refers to full monthly salaries. For a part-time employee, prorated pay may be justified if the contract and work schedules are properly documented. Good documentation is key in these cases.
AlProfit Consult: Your Business's External Economist
If your business operates in the medical or aesthetic sector and you want to clearly understand your current tax exposure, we will analyze your specific situation.
- Payroll and insurance administration
- Tax risk analysis and preventive planning
- Accounting and financial reporting
- Tax advisory and risk minimization
- Support during tax audits and procedures
- External economist dedicated to clinics and healthcare businesses.
Contact: +355 69 323 2349 or [email protected]
In the End: What to Expect
The indicative pay list is a clear signal that the direction of tax policy has changed. It's not just about this list, but about a pattern of oversight that will continue and expand. The private medical sector is second only to construction. The system's logic suggests it won't be the last.
But it doesn't make sense to view this solely as a threat. Real wage formalization also entails genuine social contributions for employees, a fairer tax base, and a more sustainable long-term business model. Businesses that manage this transition with planning and care, rather than panic, will emerge stronger.
The indicative list didn't come as a surprise. The sector knew this moment would arrive. The only difference now is that the date has arrived. And those who have started planning today are always in a much better position than those who are waiting for the door to be knocked on.