Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025

Andorra

Andorra joined the Global Forum in 2009. Andorra underwent its Second Round of EOIR Peer Review in 2019 (Andorra’s 2019 Report),1 which assessed the legal and regulatory framework in force as at 29 July 2019 and its practical implementation, including in respect of EOI requests received and sent, during the review period from 1 April 2015 to 31 March 2018. Andorra received an overall rating of Largely Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	LC
Ratings	LC	LC	C	C	LC	C	C	C	C	LC

Status of implementation of recommendations issued in the peer review report

Andorra received seven in-box recommendations in relation to Elements A.1, A.2, B.2 and C.5.

This monitoring report assesses the actions taken by Andorra to address the recommendations issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that one recommendation is “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”, three recommendations are “in the process of being addressed”, three recommendations “have not been addressed”, issues a new recommendation on Element C.5, and it advises on actions required.

Element A.1: Availability of ownership information

1. Ownership information of inactive companies

 

Recommendation (A.1, practice)	Andorra should review its system whereby a significant number of inactive companies remain with legal personality on the Companies Register.
Underlying factor	A notable number of inactive companies that maintain legal personality and do not comply with their filing obligations raises concerns that updated legal and beneficial ownership information might not be available in all cases. (see paragraphs 68 et seq. of Andorra’s 2019 Report for more information)
Summary of actions reported	New criteria for considering a company as “inactive” are under consideration. Andorra is designing an awareness campaign for companies to bring them up to date, prior to initiating administrative proceedings and the possible imposition of sanctions. Legislative amendments are also under consideration.
Conclusion	Andorra has taken preliminary steps to address the recommendation, but no material progress has been reported for more than three years since the recommendation was issued. It is urged to make substantive progress before the next self-assessment.
Status determined	Has not been addressed
Actions required	Andorra should submit a schedule for completion of steps to address the recommendation and an update on the progress made by 31 March 2026. In particular, Andorra should – Provide information on the steps taken towards minimising the risk that the significant number of inactive companies that retain legal personality may pose to the availability of ownership information. Provide updated statistics on the number of companies that have regularised their situation and the number of companies that are currently considered as inactive. Provide an explanation regarding the new criteria under consideration for determining a company as inactive, the status of their adoption/ implementation and how they influence the proportion of affected companies as well as the availability of ownership information.

2. Supervision of the beneficial ownership register

 

Recommendation (A.1, practice)	Andorra should supervise the implementation in practice of the new obligations and take enforcement actions, where necessary.
Underlying factor	As the legal requirements for companies to maintain updated beneficial ownership information and to register their beneficial owners with the Companies Register have recently been introduced in Andorra since 1 January 2018, no supervisory and enforcement actions have yet been carried out. (see paragraphs 81 et seq. of Andorra’s 2019 Report for more information)
Summary of actions reported	The Companies Register has worked to implement a program to register accurate and up-to-date information on the beneficial owners, including by improving the forms, developing a computer application which facilitates access, and conducting trainings. AML-obliged persons are mandatorily required to consult the information held in the beneficial ownership register.
Conclusion	Andorra has made progress to address the recommendation. It is urged to make further substantive progress before the next self-assessment.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Andorra should – Provide details regarding the monitoring processes adopted by the Companies Register to verify compliance with the reporting obligations and the accuracy of beneficial ownership information. Provide statistics on the level of compliance and the supervisory and enforcement measures conducted.

Element A.2: Availability of accounting information

3. Accounting records of inactive entities

 

Recommendation (A.2, practice)	Andorra should review its system whereby a significant number of inactive companies remain with legal personality on the Companies Register.
Underlying factor	A notable number of inactive companies that maintain legal personality and do not comply with their filing obligations raises concerns that accounting records might not be available in all cases. (see paragraphs 137 et seq. of Andorra’s 2019 Report for more information)
Summary of actions reported	New criteria for considering a company as “inactive” are under consideration. Andorra is designing an awareness campaign for companies to bring them up to date, prior to initiating administrative proceedings and the possible imposition of sanctions. Legislative amendments are also under consideration.
Conclusion	Andorra has taken preliminary steps to address the recommendation, but no material progress has been reported for more than three years since the recommendation was issued. It is urged to make substantive progress before the next self-assessment.
Status determined	Has not been addressed
Actions required	Andorra should submit a schedule for completion of steps to address the recommendation and an update on the progress made by 31 March 2026. In particular, Andorra should – Provide information on the steps taken towards minimising the risk that the significant number of inactive companies that retain legal personality may pose to the availability of accounting information. Provide updated statistics on the number of companies that have regularised their situation and the number of companies that are currently considered as inactive. Provide an explanation regarding the new criteria under consideration for determining a company as inactive, the status of their adoption/ implementation and their impact on the proportion of affected companies as well as the availability of accounting records.

Element B.2: Rights and Safeguards

4. Appeal rights

 

Recommendation (B.2, practice)	Andorra should monitor the exercise of the right of appeal to ensure that its use is compatible with an effective exchange of information.
Underlying factor	During the review period, 38% of the EOI requests were subject to appeal and, in 14 cases, the whole procedure has lasted more than 180 days and, in one case, more than one year. Taking into account that the appeal procedure in Andorra has suspensive effect on the exchange of information, this may impede effective EOI and affect the timeliness of Andorra’s responses to the EOI requests of its peers. (see paragraphs 210 et seq. of Andorra’s 2019 Report for more information)
Summary of actions reported	An appeal is not an obstacle to exchanging information and information has been provided in all cases, where there was an appeal, as the actors involved with exchange of information are more familiar with the process and collaborate fully.
Conclusion	Andorra has taken monitoring actions to address the recommendation. It should make further progress before the next self-assessment. While it is positive to note that all requested information was exchanged, the time taken to dispose appeals remains largely the same as at the time of the 2019 Report.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Andorra should – Provide information, including statistics, on the steps taken to minimise the consequences of appeals on the timeliness of exchanges.

5. Exceptions to prior notification

 

Recommendation (B.2, practice)	Andorra should monitor the practical implementation of the exceptions to prior notification to ensure that responses are always provided in a timely manner.
Underlying factor	The exceptions to prior notification introduced in the Andorran legislation have been tested in practice only recently. While the seven first cases processed in the first quarter of 2018 were answered in an average time of 205 days, Andorra’s response time has significantly decreased after the review period. (see paragraphs 217 et seq. of Andorra’s 2019 Report for more information)
Summary of actions reported	Requests for applying an exception to prior notification reduce a step in the response procedure. Such an exception has been requested in a limited number of cases between 2019 and 2024.
Conclusion	Andorra has taken monitoring actions to address the recommendation and the practical implementation of the exceptions to prior notifications have not affected the timeliness of exchanges. Andorra is no longer required to report on this recommendation.
Status determined	Considered provisionally addressed in the context of the monitoring process, subject to detailed validation
Actions required	No immediate action required.

Element C.5: Effective Exchange of Information

6. Timeliness of exchanges

 

Recommendation (C.5, practice)	Andorra should continue to improve the timeliness of its replies.
Underlying factor	Peers were in general satisfied with the timeliness and quality of the answers provided and the timeliness has further improved at the end of the review period. However, the requested information was not provided in all cases in a timely manner. (see paragraphs 295 et seq. of Andorra’s 2019 Report for more information)
Summary of actions reported	Timeliness of exchanges was affected by the pandemic related restrictions, diversion of staff, the general elections in 2023 and the workload of the EOI Unit. Exchange of information is now a priority, and Andorra is working hard to quickly respond to pending requests.
Conclusion	The recommendation has not been addressed more than three years since it was issued. There has been backsliding since the 2019 Report and the peer input has raised important concerns regarding the timeliness of exchanges. Andorra is urged to make substantive progress before the next self-assessment.
Status determined	Has not been addressed
Actions required	Andorra should submit a schedule for completion of steps to address the recommendation along with an update on the progress made by 31 March 2026. In particular, Andorra should – Report actions taken to improve the timeliness of exchanges.

7. Status updates

 

Recommendation (C.5, practice)	Andorra should monitor the effectiveness of its new internal procedure to ensure it provides status updates to EOI partners within 90 days in all those cases where it is not possible to provide a complete response within that timeframe.
Underlying factor	Andorra has made progress in providing status updates within 90 days in the event that it was unable to provide a complete response within that time to its EOI partners, in particular in the recent period. However, it did not provide such status updates within that timeframe in all cases. (see paragraphs 305 et seq. of Andorra’s 2019 Report for more information)
Summary of actions reported	Andorra reported that since 2018, status updates are sent at each stage of the request.
Conclusion	Andorra has made progress to address the recommendation. It is urged to make further substantive progress before the next self-assessment. The peer input reflects that the issue persists and the statistics for 2024 show that there is room for improvement.
Status determined	In the process of being addressed
Actions required	In its next self-assessment in 2028, Andorra should – Report actions taken to systematically provide status updates in all EOI requests where a response could not be provided within 90 days.

EOIR experience

Over the monitoring period, Andorra received 113 requests and did not send any requests. France, Spain and Colombia were the top three treaty partners in respect of incoming requests. Andorra reported providing full and final responses in 29% of all the received requests and indicated 57% as pending requests. Five requests (corresponding to 4%) were withdrawn by partners as the responses were not received in a timely manner and the requested information was no longer useful.

Seven members provided peer input on Andorra. Peers have reported that they were generally satisfied with respect to the quality of responses provided by Andorra. However, three peers indicated important concerns regarding the timeliness of responses. There is a pre-existing recommendation (Recommendation 6) on the issue of timeliness of exchanges, which has not been addressed. Andorra is expected to submit a schedule for completion of steps to address the recommendation along with an update on the progress made by 31 March 2026.

In addition, Andorra is recommended to ensure that adequate resources are available for effective exchange of information. Andorra is expected to submit a schedule for completion of steps to address the recommendation along with an update on the progress made by 31 March 2026.

Finally, peers flagged the issue regarding the systematic provision of status updates, which is also covered by a recommendation in the 2019 Report (Recommendation 7). While the steps taken by Andorra to address the recommendation are acknowledged, the peer input reflects that the issue persists and the statistics for 2024 show that there is room for improvement. Andorra should continue to monitor the issue and report actions taken in this regard in the next self-assessment in 2028.

New developments having a bearing on the EOIR standard

No recent developments that could have a bearing on the EOIR standard (other than those reported to address recommendations) have been reported by Andorra or have otherwise come to light.

Next steps

Andorra should continue taking actions towards implementing the standard effectively.

Under the first round of enhanced monitoring, a new recommendation is issued to Andorra

8. Adequate resources for effective exchange of information

 

Recommendation (C.5, practice)

Andorra is recommended to ensure that adequate resources are available for effective exchange of information.

Underlying factor

While there are six persons involved in exchange of information on request (including the Competent Authorities), they all handle several other tasks. Prior to and during the monitoring period, all EOI personnel were diverted to other programmes. This led to a lack of dedicated resource persons for exchange of information due to the competing priorities of the EOI personnel and significantly affected effective exchange of information. Peers raised ongoing concerns in this regard, some of whom also reported delays in communication and withdrawal of five requests during the monitoring period.

The following next steps are expected from Andorra:

• For the three recommendations where lack of material progress has been identified for more than three years since the last review, Andorra should submit to the PRMG - i) a schedule for completion of steps to address the recommendation and ii) an update, including details on the progress on such recommendations by 31 March 2026.

  • Recommendation 1, on legal and beneficial ownership information on inactive companies (Element A.1)

  • Recommendation 3, on accounting information of inactive companies (Element A.2)

  • Recommendation 6, on timeliness of responses to EOI requests Recommendation 6, on timeliness of responses to EOI requests (Element C.5)

  • Recommendation 8, on adequate resources for effective exchange of information (Element C.5).

• Submit its next self-assessment, including on the new recommendation issued, in 2028 under the second round of enhanced monitoring.

• See also the Chapter 1 (Scope and methodology, discussion under PRMG decisions on “Statuses determined and actions required”) which explains the next steps expected on recommendations that are “considered provisionally addressed in the context of the monitoring process, subject to detailed validation”.

Views/response of the monitored jurisdiction

Andorra thanks the Global Forum Secretariat and the Peer Review and Monitoring Group for their work. Andorra would like to reiterate its unwavering commitment to the international standard on transparency and exchange of information upon request (EOIR). Since 2009, Andorra has initiated a transformation process committed to transparency, international standards of exchange of tax information and the consolidation of a modern and fulfilled national tax and economic regulatory framework, equivalent to those of our neighbouring countries. Andorra agrees with the findings of the report and accepts the recommendations. It commits to mobilising all the required resources to addressing them within the indicated deadlines.

Note

← 1.  OECD (2019), Global Forum on Transparency and Exchange of Information for Tax Purposes: Andorra 2019 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/7f57533b-en.