- The obligation to open and declare bank accounts, under Law No. 9920/2008 as amended by Law No. 31/2019, has a narrow exemption: only currently registered natural persons who are not registered for VAT.
- If an excluded trader later registers for VAT, the obligation to open a bank account arises automatically at that moment.
- The specific deadline of October 26, 2019, and the opening of e-filing declarations on October 15 were one-time steps in the initial implementation of the law, which have now been years in the past.
- The rules that apply today to every new business are explained in our comprehensive guide to business bank accounts.
On October 4, 2019, the General Directorate of Taxes published a memorandum clarifying who is exempt from the new obligation to open and declare bank accounts, added to Law No. 9920/2008 by Law No. 31/2019. According to this memorandum, only currently registered natural person traders who are not registered for Value Added Tax are exempt from this obligation.
From our daily work, we see that small traders, with a turnover below the VAT threshold, mistakenly believe that every individual trader is exempt from the obligation to have a business bank account, whereas the exemption is specifically related to VAT registration. not with the size of the business in general.
Read also: Business bank account, opening and reporting deadline under Law No. 9920/2008, our complete guide to this obligation.
Who is exempt from the obligation?
Only traders not registered for VAT
The exemption applies narrowly, only to currently registered individual traders who are not registered for VAT. Any legal person, regardless of turnover, and any nonprofit organization registered with the tax authority remains subject to the obligation without exception.
What happens if you register for VAT later?
If a natural person trader who was initially exempt subsequently registers for Value Added Tax, for example because his turnover exceeds the minimum registration threshold, the obligation to open and declare a bank account arises automatically at that moment, without waiting for any specific notification.
Every time there is a tax or financial change that affects your business, we notify you directly by email with a practical explanation.
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The exception is narrow, not general.
Many traders mistakenly interpret any tax relief or exemption as broad and automatic. The bank account case shows that exemptions in Albanian tax legislation tend to be narrow and tied to specific conditions—in this case, VAT registration status—rather than to general perceptions such as business size.
How we handle this with our clients
When a client registers for VAT for the first time, we immediately verify whether they have a new bank account reporting obligation so that they can fulfill it within the usual deadline, without overlooking it as a secondary matter.
Frequently asked questions
Does the October 26, 2019 deadline still apply?
No. It was a transitional period only for businesses that existed at the time. Today, the general 20-day period from new registration applies, as explained in our full guide.
Am I excluded if I have low earnings?
Not necessarily. The exemption relates to VAT registration, not to the size of turnover itself. If you are an unregistered VAT-paying natural person trader, you are exempt. Any legal entity is not exempt, regardless of turnover.
Where can I find the complete rules for the business bank account?
In our complete guide linked above, which explains the current deadline, the entities involved, and the penalties for failure to declare.
