Fines and appeal

The three groups, the meeting, and the eight-day deadline

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Review of the inspection report before filing an objection

Penalties under the Labor Code are not fixed amounts. They are expressed as multiples of the monthly minimum wage and are divided into three groups: up to 50 times, up to 30 times, and up to 20 times. With the minimum wage at 50,000 LEK, this means up to 2,500,000, up to 1,500,000, and up to 1,000,000 LEK. Each violation is penalized separately, while the total does not exceed five times the maximum fine.

This page shows which subsection falls into which group, how fines are calculated, what the deadlines for objection are, and how to file an appeal.

Read also: Inspection and Work Control: The Complete Guide

Three groups of fines under Article 202

Article 202 lists the articles one by one. This table summarizes them as they appear in the law.

GroupMain sectionsMaximum mass
Point 19, 10, 39 first paragraph, 40, 41, 43, 44 second paragraph, 68 item 3, 69, 75, 98, 100, 101, 103, 108, 181, 184 to 18650 fish, up to 2,500,000 LEK
Point 221 paragraphs 3, 4 and 5, 32, 32/1, 33, 34, 36, 38, 42, 70 to 74, 78, 79, 80, 81, 83, 84 to 87, 90, 91 to 96, 111, 116, 119, 139, 140, 148 item 7, 165, 167, 19330 fish, up to 1,500,000 LEK
Point 326 fourth paragraph, 44 first paragraph, 49 fourth paragraph, 5020-fish, up to 1,000,000 LEK

The first group covers discrimination, workplace safety, and the employment of minors. The second group covers the contract, pay, schedule, and leave. The third group covers some more limited obligations.

Fines according to the specific violation

This is the same table, but flipped to the business side.

ViolationArticleUp to
Discrimination in the employment relationship92,500,000 LEK
Lack of safety rules and measures39, 402,500,000 LEK
Lack of information and training on the risks432,500,000 LEK
Employment of minors below the legal age982,500,000 LEK
Contract without the mandatory elements21, third paragraphOne million five hundred thousand LEK
Violation of schedule or of overtime pay78 to 87, 90, 91One million five hundred thousand LEK
Absence of the vacation register95One million five hundred thousand LEK
Lack of security documentation in the enterprise42One million five hundred thousand LEK
Irregular wage payment or lack of calculation116, 119One million five hundred thousand LEK
Pay below the minimum wage111One million five hundred thousand LEK

Read also: Documents required for an inspection

How fines are collected

Article 202, paragraph 5, establishes two rules that completely change the magnitude of the risk.

Any violation is punishable by a fine. When the violation is repeated, or when it affects multiple employees, the total amount of fines shall not exceed five times the maximum fine.

Example. A business with eight employees does not keep leave records for any of them. This is a repeated violation of Article 95 for eight individuals. The maximum fine for the group is 1,500,000 LEK, so the potential cap for this single violation is five times that amount, i.e., 7,500,000 LEK.

Point 6 adds joint and several liability. The employer is responsible for paying the fine even when the violation was committed by a person he appointed to represent him.

Why do fines increase on their own?

Since the threshold is a multiple of the minimum wage, any increase in it raises all fines on the same day, without any legal change.

Minimum wagefifty timesthirty timesTwenty fish
40,000 LEK2,000,000 LEK1,200,000 LEK800,000 LEK
50,000 LEK2,500,000 LEKOne million five hundred thousand LEKOne million Lek

The transition to the minimum wage in 50,000 LEK as of January 1, 2026 He increased all fines by 25 percent, without it being discussed anywhere as a punitive measure.

Besides the fine, what other measures are there?

Inspection legislation recognizes several types of measures, and a fine is only one of them.

  • The warning, with a deadline for correcting the violation.
  • Fine, pursuant to Article 202 of the Code for its violations.
  • Suspension of activity or work when the risk is immediate.

The warning with a correction deadline is the most useful tool for a business, because it allows for adjustments without financial consequences. It requires that the deficiency be corrected within the specified timeframe and documented.

Deadlines for objection and appeal

These deadlines are short and will not be reopened.

ActionDeadline
Advance Notice of Scheduled InspectionNo later than 10 days beforehand.
Notification of the minutes to the entityWithin 48 hours
Submission of objections by the subjectWithin 8 days
Final decisionWithin 30 days

Objections filed within eight days are reviewed before the final decision. This is the phase in which a document submitted in time removes the defect from the minutes.

After the final decision, the process continues with an appeal under the inspection legislation and then to the competent court. The specific appeal deadlines should be checked in the applicable act, as they change with amendments to the inspection law.

Caution: An objection is not an appeal. An objection must be filed within eight days of the minutes and is included in the decision-making process. An appeal comes after the decision and follows a different procedure. Confusing the two causes you to lose the first opportunity, which is the easier one.

How to prepare an objection

Step 1. Read the minutes and note, for each deficiency, the section it cites.

Step 2. For each one, request the document that refutes or mitigates the finding.

Step 3. Distinguish real deficiencies from those that are merely matters of document presentation.

Step 4. For genuine deficiencies, correct them immediately and attach proof of correction.

Step 5. Submit the written objection within 8 days, with attached documents and numbered to correspond with the minutes.

The objection that follows the reading of the minutes is reviewed more quickly and leaves less room for misunderstanding.

Prescription, until when it can be sought

Article 203 of the Code prescribes the limitation periods, which also apply to claims arising from an inspection.

  • The rights of the employee and the employer are time-barred within three years from the accrual of the right.
  • Disciplinary action must be initiated within one year of its imposition, as notified in writing.
  • The employer waives damages if it does not request them in writing within six months of becoming aware.
  • The prosecution of criminal offenses is barred by prescription within two years from the date they are committed, except for prosecutions provided for by the Penal Code.

Read also: Work conflicts and ways to resolve them

Errors we see in fines and appeals

  • The minutes are signed without being read and without any remarks at the time.
  • The eight-day deadline passes as the decision is awaited, and the objection remains outside.
  • The deficiency is corrected, but no evidence of the correction is attached.
  • All statements are opposed indiscriminately, even those that are correct.
  • It is thought that the fine is a fixed amount, whereas the other is a multiple of the minimum wage.
  • It is not taken into account that the same violation for some employees is multiplied up to five times.
  • A warning with a correction deadline is not required where it is feasible.

Frequently Asked Questions about Fines and Appeals

What is the maximum fine under the Labor Code?

Up to 50 times the monthly minimum wage, i.e., up to 2,500,000 LEK with a minimum wage of 50,000 LEK.

How is the fine for a violation calculated for multiple employees?

Each violation is punished separately, but the total does not exceed five times the maximum fine, pursuant to Article 202, paragraph 5.

Do fines increase when the minimum wage goes up?

Yes. They are expressed as multiples of the monthly minimum wage, so they automatically increase without any legal change.

Within what timeframe are objections filed?

Within eight days of notification of the minutes, which are themselves notified within 48 hours.

When is the final decision made?

Within 30 days, in accordance with the inspection legislation.

What is the difference between objection and complaint?

An objection to the minutes must be filed within eight days and is included in the decision-making process. An appeal follows the final decision and follows the procedure provided for in the inspection legislation.

Is the employer liable for the fine incurred by one of his employees?

Yes, as a matter of solidarity, when the violation is committed by a person he has appointed to represent him, pursuant to Article 202, paragraph 6.

How many years does the right to request an employment obligation remain valid?

Three years from the birth of the right, according to Article 203, paragraph 1.

Legal basis

Most fines in an inspection don't come from serious violations, but from missing records, and it's precisely those that are multiplied for each employee up to five times the maximum amount. As external economists, we maintain these records year-round and prepare the objection within the eight-day deadline when required, as part of the monthly subscription.

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