The Tax Administration published the Tourism Sector Plan 2026a few days ago. This is not a routine announcement. It is the first document of its kind that integrates artificial intelligence, automatic monitoring of platforms like Booking and Airbnb, and alarm systems for any discrepancy between real and declared activity.
This plan affects three groups of people. Individuals who rent out properties through online platforms and have not declared this individual income in the DIVA (Annual Individual Income Tax Declaration). Businesses that apply the wrong VAT rate, often without knowing they are in error. And operators who have declared turnover that does not match the prices and capacity listed publicly.
The tourist season has begun. The first phase of inspections has already started. This blog explains what is being checked, how the new system works, and what you can do if you feel exposed.
What is the 2026 Tourism Sectoral Plan and what has changed this year
The Tax Administration approves a sectoral plan for tourism every year. The 2025 plan ocused primarily on raising awareness among entities regarding DCM no. 160/2025 and the declaration of capacities. The 2026 plan goes significantly further and introduces several new instruments.
Artificial intelligence as a control instrument. The system scans business photos on Google Maps and identifies whether the visible invoices contain the QR code, the invoice serial number, and the tax transaction identification number—the three elements that confirm fiscalization.
Automated weekly monitoring. The CPCM system (the central portal for taxpayer control and management in the cash transaction subsystem) compares fiscalized invoice data with VAT returns every week. Any discrepancy generates an automatic alert and categorizes the taxpayer according to their risk level. Categorization is also based on time slots; a turnover analysis by hour, identifying businesses with real activity but zero invoices during peak times.
Booking and Airbnb as sources of tax data. Prices, capacities, ratings, and comments listed on platforms are compared with the declared turnover. The system generates an estimated turnover and compares it with the declared one. Discrepancies trigger an alternative assessment.
Alternative tourism as new territory. Mountain guides, cabins, campsites, agritourism, and cultural operators are explicitly targeted for the first time. Many of them are completely informal.
POS Deadline May 30, 2026. Law No. 79/2025 obliges all accommodation structures to have a POS terminal by May 30, 2026. This deadline is very close.
Who is targeted
The 2026 plan defines seven targeting criteria. Fulfilling just one of them is sufficient to be included in the monitoring list.
The criteria are:
- NACE Rev. 2 activity code in groups I5510-I5630 (hotels, guesthouses, apartments, agritourism, bar-restaurants, fast food, nightlife venues);
- Registration with the Ministry of Tourism;
- Documented activity during 2025-2026, regardless of active or passive status;
- New registration during 2026;
- Identifiable presence through Booking.com or Airbnb;
- Contract with the National Coastal Agency (AKB) for beach stations;
- Receipt of funds from the Agricultural and Rural Development Agency (AZHBR).
And another innovation. Any business that has received grants or subsidies for agritourism automatically enters the targeted population, even if it does not yet have full tax activity.
Furthermore, entities with passive passive tax status but an active listing on platforms are classified as high risk. Switching to the passive register does not hide digital presence.
The Three Main Issues
Individuals with Airbnb and the DIVA obligation
Article 15 of Law No. 29/2023 "On Income Tax" classifies income from the rental of real estate that is not business income as individual income. The tax rate is 15% of the net amount received, after deducting the commission kept by the platform. The declaration is made annually through DIVA March 31 of the following year.
The law does not allow for expense deductions for this category. Costs for cleaning, reconstruction, or supplies are not deductible from the tax base. The net income received is taxed.
The declaration threshold is 50,000 ALL of untaxed income per year. Even two weeks of seasonal rent can exceed it. The tax administration is cross-referencing data on commissions paid by platforms with DIVA declarations to identify untaxed income.
VAT 6%
The reduced 6% VAT rate for accommodation services does not depend on the type of business or activity code. It depends on the certificate issued by the Ministry of Tourism that classifies the structure as an accommodation structure. Without this certificate, the mandatory rate is 20%. Certification is linked not to the entity, but to the property serving as the accommodation structure.
This mistake is very common. Many businesses are registered as hotels or tourism in the National Business Center (QKB) and assume the 6% rate applies automatically. It does not. Certification requires a specific procedure, technical documentation, and physical inspection by the Ministry of Tourism. The process takes several weeks to two months on average.
The 2026 plan explicitly lists the application of the 6% VAT rate without certification as high-risk behavior. This means that entities without a certificate have already been identified as problematic.
Furthermore, even if the structure has the accommodation certificate, bar-restaurant services within it are always taxed at 20%. The 6% rate applies only to the provision of sleep and direct accommodation services, not for everything else within it.
Discrepancy
Article 72 of Law No. 9920/2008 "On Tax Procedures" authorizes the tax administration to calculate tax liability based on indirect data, including market prices, declared capacities, and third-party information.
Booking and Airbnb are third-party sources within the meaning of the law. When declared turnover is inconsistent with listed prices and capacity, taxes calculate the estimated turnover and perform an alternative assessment. After this, the burden of proof shifts to the business. The business must prove it had lower occupancy, not the tax administration.
Three Practical Cases
Each case illustrates a different situation. Many readers will recognize themselves in one of them.
The Individual with two apartments
Besnik has two studios in Saranda. He bought them as an investment a few years ago and has listed them on Airbnb since the 2022 season. He thought this was property income like any other rent and did nothing.
has not opened a business. He has no NUIS (NIPT). He has not filled out any DIVA.
Earnings over three years: 2 studios × 80 EUR/night × 20 nights/month × 5 months = 16,000 EUR/year. For three years: 48,000 EUR received.
Legal obligations:
Tax base after Airbnb commission (approx. 8%): 44,160 EUR, approximately 4,990,000 ALL.
Tax: 15% × 4,990,000 ALL = 748,500 ALL.
Tax evasion penalty under Article 116 of the Tax Procedures Law: 100% of the undeclared tax = 748,500 ALL additional.
Late payment interest under Article 76: approximately 0.06% per day accumulated over the three-year period = approx. 190,000 ALL.
Total exposure: approx. 1,687,000 ALL or approximately 14,900 EUR.
Out of 48,000 EUR received, almost 1 in 3 euros is owed to the state as late tax, penalties, and interest. And this calculation is based only on DIVA. If the volume and frequency of rent are considered a commercial activity, additional fiscalization and VAT obligations apply.
The statute of limitations under Article 73 of the Tax Procedures Law is five years. Taxes can review the 2020-2024 period now.
The Guesthouse with 6% VAT without a certificate
Arjana has a guesthouse with 8 rooms in Himara. She is registered with the tax authorities, issues electronic invoices, and declares VAT every month. She thinks she is fully compliant.
But she has never completed the certification procedure as an accommodation structure with the Ministry of Tourism. She applies the 6% rate to all accommodation services.
Tax situation:
Annual turnover: 12,000,000 ALL.
VAT paid at 6%: 720,000 ALL/year.
Mandatory VAT without accommodation certificate (20% rate): 2,400,000 ALL/year.
Unpaid annual difference: 1,680,000 ALL.
For two years:
Unpaid VAT: 3,360,000 ALL. Tax evasion penalty 100%: 3,360,000 ALL additional. Accumulated interest: approx. 430,000 ALL.
Total exposure: approx. 7,150,000 ALL, approximately 63,300 EUR solely from the incorrect VAT rate issue.
Arjana has paid regularly. She has invoices and a system. The problem is that she paid the wrong rate, and the difference between the 6% and 20% rates over two years of activity generates massive exposure.
If the bar-restaurant service (where the rate must always be 20%) and the issue of employees with fictitious salaries are added, the exposure increases significantly.
Many businesses like Arjana see themselves as compliant because they pay VAT. An audit does not only look at whether you pay, but whether you pay the correct rate.
The Case of Discrepancy
Hotel Adriatiku has 20 rooms. Booking shows an average price of 55 EUR/night. The profile has over 180 comments accumulated over three years, a sign of stable activity.
The Tax authorities take this data and perform the calculation based on capacity and public prices:
20 rooms × 70% occupancy × 150 days × 55 EUR × 113 ALL/EUR = 13,167,000 ALL estimated turnover.
Hotel Adriatiku has declared 4,800,000 ALL annual turnover.
The Discrepancy: 8,367,000 ALL triggers an alternative assessment according to Article 72 of the Law on Tax Procedures.
Now the business must prove that it had lower bookings using physical reservation logs, payrolls, rental certificates, and any other justifying documents. If there is no evidence, the tax assessment becomes a mandatory liability.
On the difference of 8,367,000 ALL, the following are applied: VAT (6% or 20% depending on certification), profit tax if the total turnover exceeds the threshold, a 100% tax evasion penalty, and interest. If employees are also declared at minimum wage while the business has such activity, the effects of contributions and wage tax are also added.
Summary
Three typical cases · accumulated tax exposure
How penalties are accumulated under the law
Prescription period: 5 years · Article 73 of Law No. 9920/2008 · 2020–2024 period within the deadline.
Every time there is a tax or financial change that affects your business, we notify you directly by email with a practical explanation.
Send me free notificationsHow penalties are calculated
Many taxpayers think that if discovered, you only pay the late tax. It doesn't work that way.
The law provides for three layers of penalties applied jointly.
The first layer is the unpaid tax itself, the full amount of unfulfilled liabilities.
The second layer is the tax evasion penalty according to Article 116 of the law on tax procedures. The amount is 100% of the undeclared tax. This is not a small routine penalty; it is a doubling of liabilities.
The third layer is the late interest according to Article 76: 120% of the interbank rate of the Bank of Albania, which currently results in about 4.5% per year. This interest is calculated from the day the liability should have been paid until the day of actual payment.
Additionally, if the business has undeclared employees, the penalty according to Article 119 is 200,000 ALL for each undeclared employee for taxpayers registered for VAT.
The three phases of the plan and where we are today
The plan is structured into three phases. Understanding each helps you understand what comes next.
Phase I: Identification and Awareness has already started. The system identifies the targeted population and sends personal notifications via the e-Filing platform. If you have received a POP-UP notification or email from Taxes via e-Filing, you are already in Phase I. This is the phase where voluntary action has minimal cost.
Phase II: Verification and Monitoring starts before the summer season. It involves intensive field verifications, unannounced employee checks, invoicing inspections, and active comparison of platform data. Cooperation with the Labor Inspectorate and law enforcement is explicitly foreseen.
Phase III: Assessment and Reporting comes after the season. Corrective measures for those who have not voluntarily formalized, consolidation of findings, and referral of very high-risk cases to tax investigation.
We are in Phase I. This is the only window where action changes the result.
Fiscal Amnesty: the opportunity many are missing
Law No. 86/2025 on Fiscal Amnesty is still in force. This law provides the opportunity for formalization and correction of liabilities from past periods under eased conditions, reduction of penalties, and tax protection for corrected periods.
It is also worth knowing: Article 69 of the income tax law provides for a zero percent profit tax rate until December 31, 2029, for taxpayers with gross income below 14,000,000 ALL per year. This applies to commercial individuals, the self-employed, and LLCs (SHPK). Many small tourism businesses do not know they have no profit tax obligation at all until 2029. Their main exposure is not profit tax, but VAT and employment liabilities.
When an audit has started, Amnesty conditions no longer apply. Action now makes sense.
What to do now
If you are an individual with income from Airbnb or Booking
Check if you have filled out DIVA for every year with income over 50,000 ALL. If not, the only chance for protection is self-declaration before the audit begins. The process is done via e-Filing. The tax is 15% on the amount received after the platform commission. The law does not allow expense deductions.
If you are a business with accommodation activity
Verify if you have the accommodation structure certificate from the Ministry of Tourism. If not, start the procedure now. Certification takes an average of several weeks to two months. Without a certificate, the mandatory VAT rate is 20%. Also, check if bar-restaurant income has been declared at the 20% rate and not 6%.
If you have bar-restaurant activity together with accommodation
Make sure you separate invoices correctly according to service and rate. Accommodation at 6% only if you have the certificate, bar and restaurant always at 20%. If you applied 6% to all services, you have a direct discrepancy.
If your Booking prices do not match the declared turnover
Review your declarations. If there is a large gap between the estimable turnover from your capacity and prices and what was declared, prepare for an alternative assessment. Keep detailed occupancy records and any justifying documentation.
Install the POS terminal before May 30, 2026
This deadline is mandatory and little time remains. Non-compliance adds additional penalties.
Frequently asked questions
Do I need to open a NUIS (NIPT) if I only rent two apartments via Airbnb?
Not necessarily, if the activity is not considered commercial. However, you still have the DIVA obligation regardless. If the volume of apartments, occupancy frequency, and income are high, the Tax Authorities may classify it as a commercial activity and require NUIS (NIPT) registration and fiscalization. Read this article to understand more.
We have paid VAT regularly. Are we protected?
Not if the rate was incorrect. Paying VAT at the 6% rate without the proper certificate is not treated as a regular declaration. The difference between the 6% and 20% rate over the entire historical turnover remains mandatory.
Does the zero profit tax rate apply to small hotels as well?
Yes, if the annual gross income is below 14,000,000 ALL. This applies equally to commercial individuals, the self-employed, and LLCs (SHPK). The primary exposure for these businesses is not profit tax, but VAT and employment obligations.
What happens if an inspector arrives and there is a discrepancy?
An alternative assessment is activated pursuant to Article 72 of the Law on Tax Procedures. The burden of proof shifts to you. If you lack justifying documentation, the tax assessment becomes a mandatory liability, and a 100% penalty plus interest will be applied.
How many years back can the Tax Authorities go?
Five years, according to Article 73 of the Law on Tax Procedures. This means the 2020-2024 period is still within the statute of limitations.
This material has been prepared for informational purposes only and does not replace individual tax advice. Every specific situation may have unique characteristics that affect the analysis and specific obligations.