All businesses are being forced to submit balance sheets/ NCC reacts: We verify the tax lists

2026-07-07 09:58:00, Ekonomi CNA

All businesses are being forced to submit balance sheets/ NCC reacts: We verify

The debate continues between the National Business Center (NBC) and the Alliance of Freelance Professionals (APL) regarding the obligation to file financial statements for businesses organized as legal entities and limited liability companies with annual turnover under 5 million lek.

For several days, according to the Alliance of Freelance Professionals, the Central Bank of Albania has been requiring businesses to submit financial statements regardless of their annual turnover. This has sparked debate among institutions and business associations, who argue that the request is not based on the legal framework in force. The main concern is that businesses that do not submit financial statements risk administrative fines of up to 60 thousand lek.

On July 6, the Alliance of Freelance Professionals sent a letter to the Central Bank of Albania, requesting an official clarification on whether businesses with a turnover of less than 5 million lek are required to file financial statements. According to the Alliance, current legislation on accounting and the Income Tax Act stipulate that this obligation only applies to businesses with income above this threshold.

Following concerns raised by freelancers, the Central Bank of Albania (CBA) has reacted by clarifying in a letter addressed to freelancers that the institution verifies entities that are required to file financial statements based on the lists forwarded by the General Directorate of Taxation (GDT).

In its response, the NBC emphasizes that the institution's competencies are determined by the law "On the National Business Center" and that the filing of financial statements is a mandatory data for registration under the law "On Business Registration".

However, regarding the determination of entities that must file financial statements, the Central Bank explains that it carries out verification based on lists sent by the General Directorate of Taxes, which identify entities that have this obligation for each year. For any clarification on inclusion in these lists, the Central Bank directs businesses to contact the tax authorities as the competent institution.

Following this response, the Alliance of Freelance Professionals reacted again with another letter addressed to the institution, emphasizing that the obligation to file financial statements is not regulated by tax legislation, but by Law No. 25/2018 "On Accounting and Financial Statements", National Accounting Standard No. 15 and the relevant bylaws.

According to the APL, tax legislation regulates the relationship between the taxpayer and the tax administration, while filing with the Central Tax Office has a public and declarative character, as the financial statements become accessible to all interested parties. For this reason, the Alliance of Free Professionals argues that the determination of entities that have the obligation to file cannot be based solely on the lists of the General Directorate of Taxes.

In its response to the Central Tax Office, APL requests that the institution refer to the specific legal provision on which it relies to implement the tax administration's lists in determining the obligation to file financial statements with the Central Tax Office, arguing that only a clear interpretation of the law can avoid ambiguities and penalties for businesses.

Return of response from the National Business Center

"In response to your e-mail, we inform you that the Competences of the National Business Center are clearly defined in Law No. 131/2015 "On the National Business Center".

Specifically, the CBK carries out the registration of entities defined in the law regulating business registration, handles the procedures for licensing, authorization or permits, their amendment and revocation, according to the law regulating licenses, authorizations and permits, and the registration of beneficial owners.

Referring to letter “a”, point 3 of article 43 and article 46 of law no. 9723, date 03.05.2007, “On business registration”, as amended, the filing of financial statements constitutes mandatory data for registration, which must be filed in any case no later than 7 months from the date of closing each financial year, with an application by the person authorized to represent the reporting entity, on the e-Albania portal, for the performance of which he must be provided in advance with an electronic signature by the National Agency for the Information Society (NAIS).

Meanwhile, regarding entities that have the obligation to file financial statements, we would like to clarify that the National Business Center verifies entities that have the obligation to file financial statements, in the list provided by the General Directorate of Taxes, which lists all entities that have the obligation to file financial statements according to the relevant years.

Regarding the above, to obtain the information requested by you, please contact the tax authorities in their capacity as the competent institution for the administration and provision of this information.

The Alliance of Freelance Professionals responds to the National Business Center

"After consulting with our experts in the field, a professional response as an effort to contribute to this issue.

We would like to emphasize that the obligation to file financial statements is regulated by Law No. 25/2018 “On Accounting and Financial Statements”, SKK No. 15 and the relevant sub-legal acts referred to above, and not by tax legislation. The latter regulates the relationship between the taxpayer and the administration in particular and is not public in nature, but private between the two parties. Deposits in e-Filing are not made public, while in the Central Tax Office they are. In fact, the GDT has been correct with the submissions we made on March 31 and has also made public posts that reinforce our position and emphasizing it regardless of responsibility!

For this reason, we believe that the determination of entities that have this obligation should be based on the relevant legal framework and not on lists maintained by the General Directorate of Taxation, which is an institution implementing tax legislation.

The tax administration is only one stakeholder among many, while filing with the Central Tax Office has a declarative and public effect for all stakeholders.

Given that the essence of our request remains the same, please refer to the specific legal provision on which the CNB relies to consider the implementation of this legal provision on mandatory filing with the CNB according to the list from the GDT./ Monitor