Ing. Viktória Horáčiková
Tax Advisor
From 1 January 2026, an amendment to the Tax Procedure Code will come into effect, tightening sanctions for administrative offences. It increases both the minimum and maximum penalties for the most common breaches of tax obligations. At the same time, it introduces a motivational mechanism: if a taxpayer pays the assessed tax or tax difference within 15 days of receiving the decision in the assessment procedure, the penalty will automatically be reduced to two thirds.
Article summary
From 1 January 2026, penalties for tax offences will become stricter. The amendment to the Tax Procedure Code increases the minimum and maximum sanctions for the most common breaches, such as failure to file a tax return, failure to meet registration or notification obligations, or failure to comply with obligations imposed by the tax administrator.
For companies and entrepreneurs, this means that even smaller administrative failures may become significantly more expensive from 2026. At the same time, the amendment also introduces a motivational element. If a taxpayer pays the assessed tax or tax difference within 15 days of receiving the decision in the assessment procedure, the penalty will automatically be reduced to two thirds.
It is therefore important to keep tax deadlines, registration obligations, internal processes and responses to requests from the tax administrator under control. With the new penalty rates, prevention becomes a significantly cheaper solution than subsequent correction.
Who and what the changes apply to
The amendment concerns sanctions for administrative offences under Sections 154 and 155 of the Tax Procedure Code, particularly where a taxpayer:
- fails to file a tax return within the deadline or even within the deadline set in a request
• fails to meet the registration obligation, for example when mandatory registration arises
• fails to meet the notification obligation
• fails to comply with an obligation imposed by a decision of the tax administrator
• breaches non-monetary obligations under the Tax Procedure Code or special regulations
How the penalty rates are changing (overview)
Practical table – the most common offences, until 31 December 2025 vs. from 1 January 2026
| Most common tax offence | Penalty until 31 December 2025 | Penalty from 1 January 2026 |
|---|---|---|
| Failure to file a tax return | €30 – €16,000 | €100 – €30,000 |
| Failure to file a tax return even after a request from the tax administrator | €60 – €32,000 | €100 – €60,000 |
| Failure to meet the registration obligation | €60 – €20,000 | €100 – €30,000 |
| Failure to meet the notification obligation | €30 – €3,000 | €100 – €10,000 |
| Failure to comply with an obligation imposed by a decision / non-monetary obligations | €30 – €3,000 | €100 – €10,000 |
Motivational element: the penalty is reduced to 2/3 if paid within 15 days
The amendment adds a new paragraph 17 to Section 155. If a taxpayer pays the monetary amount assessed by a decision, meaning the tax, tax difference, determined amount or difference in the claimed amount, within 15 days of receiving the decision in the assessment procedure, the penalty will be reduced to two thirds of the established amount.
The transitional provisions also address the first application. In the case of a penalty under Section 155(1)(f), the penalty will be imposed directly in the reduced amount of 2/3 for the first time if the decision is delivered after 31 December 2025 and the tax difference is paid within 15 days.
What we recommend to clients to avoid sanctions
- Check deadlines – tax returns, reports/notifications and responses to requests from the tax administrator
- Do not underestimate registrations – when an obligation arises, for example VAT registration, the risk of a penalty is significantly higher
- Set up internal processes – responsibilities, approvals and substitutability. With penalties starting at €100, even a “small” failure can become costly
- If you receive a decision in an assessment procedure, consider payment within 15 days – this may automatically reduce the penalty to 2/3
FAQ
From when do the increased penalties for tax offences apply
The increased penalties for tax offences apply from 1 January 2026.
Who do the changes apply to
The changes apply to taxpayers who fail to meet their obligations under the Tax Procedure Code. This mainly includes failure to file a tax return, failure to meet the registration obligation, failure to meet the notification obligation or breach of non-monetary obligations.
What will the minimum penalty be from 2026
For the most common offences, the minimum penalty will increase to €100.
How will the penalty for failure to file a tax return change
The penalty for failure to file a tax return will increase from the original range of €30 to €16,000 to the new range of €100 to €30,000.
What happens if a taxpayer fails to file a tax return even after a request from the tax administrator
If a taxpayer fails to file a tax return even after a request from the tax administrator, the penalty will increase from the original range of €60 to €32,000 to the new range of €100 to €60,000.
How is the penalty for failure to meet the registration obligation changing
For failure to meet the registration obligation, the penalty will increase from the original range of €60 to €20,000 to the new range of €100 to €30,000.
Can the penalty be reduced
Yes. If a taxpayer pays the assessed tax, tax difference or another determined amount within 15 days of receiving the decision in the assessment procedure, the penalty will be reduced to two thirds of the established amount.
What should companies do to avoid penalties
Companies should check their tax deadlines, not underestimate registration obligations, set up internal responsibilities and, if they receive a decision, consider payment within 15 days in order to benefit from the penalty reduction to two thirds.
How can tax advisory and accounting help prevent penalties
Properly maintained accounting and ongoing tax advisory help companies and entrepreneurs keep track of tax deadlines, registration and reporting obligations, the accuracy of filings, and communication with the tax authority. With higher penalties from 2026, professional review of accounting and tax obligations is an important preventive measure that can significantly reduce the risk of sanctions.
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