Peer Review of the Automatic Exchange of Financial Account Information 2025 Update

Albania

Overall findings

Effectiveness in practice

Albania’s implementation of the AEOI Standard is partially compliant with the requirements of the AEOI Terms of Reference to ensure the effectiveness of the AEOI Standard in practice. While Albania is on track with respect to exchanging the information in an effective and timely manner (CR2), there are significant issues with respect to ensuring that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures (CR1).

The methodology used for the peer reviews and that therefore underpins this report is outlined in Annex A.

Overall rating in relation to the effectiveness in practice: Partially Compliant

Conclusions in relation to effectiveness in practice

General context

Albania commenced exchanges under the AEOI Standard in 2020.

Table 1 sets out the number of Financial Institutions in Albania that reported information on Financial Accounts in 2024 as defined in the AEOI Standard (essentially because they maintained Financial Accounts for Account Holders, or relating to Controlling Persons, resident in a Reportable Jurisdiction). It also sets out the number of Financial Accounts that they reported in 2024. In this regard, it should be noted that Albania requires the reporting of Financial Accounts based on a prescribed list of exchange partners and some accounts may be required to be reported more than once (e.g. jointly held accounts or accounts with multiple related Controlling Persons), which is reflected in the figures below. These figures provide key contextual information to the development and implementation of Albania’s administrative compliance strategy, which is analysed in the subsequent sections of this report.

Table.1. Number of Financial Institutions reporting and Financial Accounts reported

	Number
Number of Financial Institutions reporting Financial Accounts in 2024	19
Number of Financial Accounts reported in 2024	261 918

Table 2 sets out the number of exchange partners to which information was successfully sent by Albania in the past few years (including where the necessary frameworks were in place, containing an obligation on Reporting Financial Institutions to report information, but no relevant Reportable Accounts were identified). These figures provide key contextual information in relation to Albania’s exchanges in practice, which is also analysed in subsequent sections of this report.

Table.2. Number of exchange partners to which information was successfully sent

	2021	2022	2023	2024
Number of exchange partners to which information was successfully sent	69	75	74	75

In order to provide for the effective implementation of the AEOI Standard, in Albania:

• Albania’s General Directorate of Taxation (the tax authority) has the responsibility to ensure the effective implementation of the due diligence and reporting obligations by Reporting Financial Institutions and for exchanging the information with Albania’s exchange partners, and has an agreement with the Financial Intelligence Unit and relevant Regional Taxation Directorates in Albania to jointly carry out verification activities;

• technical solutions necessary to receive and validate the information reported by Reporting Financial Institutions were put in place through an online portal; and

• the Common Transmission System (CTS) is used for the exchange of the information, along with the associated file preparation and encryption requirements.

It should be noted that the review of Albania’s legal frameworks implementing the AEOI Standard concluded with the determination that Albania’s domestic legal framework is In Place But Needs Improvement and its international legal framework is In Place. This has been taken into account when reviewing the effectiveness of Albania’s implementation of the AEOI Standard in practice and where particular identified gaps in Albania’s legal frameworks directly impact its implementation in practice, these are mentioned below.

Detailed findings

The following table contains the detailed findings for Albania, organised per Core Requirement (CR) and then per sub-requirement (SR) as extracted from the AEOI Terms of Reference (see Annex B).

CR1 Effectiveness in practice: Jurisdictions should ensure that in practice Reporting Financial Institutions correctly implement the due diligence and reporting procedures, which includes a requirement for jurisdictions to have in place an administrative framework to ensure the effective implementation of the CRS.

Rating: Partially Compliant

Albania’s implementation of the AEOI Standard is partially compliant with respect to ensuring that Reporting Financial Institutions are correctly conducting the due diligence and reporting procedures. More specifically, while Albania is meeting expectations with respect to collaboration with its exchange partners to ensure effectiveness (SR 1.6), there are significant issues with respect to ensuring effectiveness in a domestic context, such as through having an effective administrative compliance framework and related procedures (SR 1.5). Albania should continue its implementation process to ensure its effectiveness, including by addressing the recommendations made.

SR 1.5 Jurisdictions should ensure that in practice Reporting Financial Institutions identify the Financial Accounts they maintain, identify the Reportable Accounts among those Financial Accounts, as well as their Account Holders, and where relevant Controlling Persons, by correctly conducting the due diligence procedures and collect and report the required information with respect to each Reportable Account. This includes having in place:

• an effective administrative compliance framework to ensure the effective implementation of, and compliance with, the CRS. This framework should:

  i. be based on a strategy that facilitates compliance by Reporting Financial Institutions and which is informed by a risk assessment in respect of the effective implementation of the CRS that takes into account relevant information sources (including third party sources);

  ii. include procedures to ensure that Financial Institutions correctly apply the definitions of Reporting Financial Institutions and Non-Reporting Financial Institutions;

  iii. include procedures to periodically verify Reporting Financial Institutions’ compliance, conducted by authorities that have adequate powers with respect to the reviewed Reporting Financial Institutions, with procedures to access the records they maintain; and

• effective procedures to ensure that Financial Institutions, persons or intermediaries do not circumvent the due diligence and reporting procedures;

• effective enforcement mechanisms to address non-compliance by Reporting Financial Institutions;

• strong measures to ensure that valid self-certifications are always obtained for New Accounts;

• effective procedures to ensure that each, or each type of, jurisdiction-specific Non-Reporting Financial Institution and Excluded Account continue to present a low risk of being used to evade tax; and

• effective procedures to follow up with a Reporting Financial Institution when undocumented accounts are reported in order to establish the reasons why such information is being reported.

Findings:

In order to ensure that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures, Albania implemented some of the requirements in accordance with expectations. However significant issues were identified. The key findings were as follows:

• Albania has adopted a strategy to ensure compliance with the AEOI Standard and is in the process of implementing this strategy. Once implemented, Albania’s compliance strategy should facilitate compliance and it appears to incorporate a credible approach to enforcement. Albania intends to keep its compliance strategy under review to ensure its effectiveness on an ongoing basis. However, Albania has not yet implemented many key aspects of its compliance plan (including the development of a risk matrix), and has not yet carried out a risk assessment to inform its compliance strategy but is planning to do so by taking into account a range of relevant information sources, such as tax reporting, feedback from exchange partners and information from the AML authorities. Further, there does not appear to be a formalised plan or activity undertaken to ensure that the interaction between Albania’s AEOI and AML frameworks always results in reporting in accordance with the AEOI Standard.

• Albania maintains a list of Reporting Financial Institutions based on the lists of entities licensed by the Bank of Albania and the Albanian Financial Supervisory Authority. Albania is planning to expand the information sources used to understand its population of Financial Institutions, including relevant non-regulated Entities, by utilising its tax database, the Foreign Financial Institution list for FATCA purposes, lists of members of the venture capital association and engagement with the entities regulated to provide financial services and large Reporting Financial Institutions. Albania has taken actions to ensure that Reporting Financial Institutions are classifying themselves correctly under its domestic rules and are reporting information as required by sending nudge letters to the Entities that may qualify as Reporting Financial Institutions. Albania intends to keep its understanding of its Financial Institution population up to date on a routine basis.

• The institution responsible for implementing Albania’s compliance strategy appears to have the necessary powers to discharge its functions. With respect to resourcing, Albania has assigned the equivalent of six full time staff and four part time staff (including two from the IT department) who are supported by four part time staff from the Legal Department, the Taxpayers Service Department and the Project Management Directorate.

• Albania has started to verify compliance with the requirements. Activities include compliance questionnaires in relation to common issues identified being sent to five Reporting Financial Institutions in 2024 where one Reporting Financial Institution was identified as coherent in reporting, two Reporting Financial Institutions reported a significantly higher number of Financial Accounts as undocumented, one Reporting Financial Institution failed to identify Controlling Persons and one Reporting Financial Institution reported a low number of accounts. In addition, reminders were sent to all Reporting Financial Institutions in 2025 highlighting the most frequently encountered reporting issues in 2024 (i.e. increases of undocumented accounts reported, improper classification of accounts identified by exchange partners and a low numbers of accounts reported). Two desk-based reviews were conducted in 2025 in response to undocumented accounts being reported by one Reporting Financial Institution, as well as on the basis of feedback from an exchange partner. Issues with the classification of accounts were identified (in one case due to an internal system error and in another case where an exchange partner jurisdiction indicated that accounts of an international organisation were incorrectly treated as individual accounts). The Reporting Financial Institutions corrected the issues identified. Albania has not yet applied dissuasive penalties and sanctions for non-compliance.

• It appears that Albania is ready to take effective action to address circumvention of the requirements if such circumvention is detected. Although, it is noted that Albania is constrained by the lack of a legal basis to prevent persons or intermediaries, other than Financial Institutions, from adopting practices intended to circumvent the reporting and due diligence procedures. Furthermore, Albania has not yet taken effective action to ensure self-certifications are obtained.

• It is noted that Albania does not have a jurisdiction-specific list of Non-Reporting Financial Institutions or Excluded Accounts for ongoing monitoring.

Table 3 provides a summary of the specific activities undertaken, or that are planned to be undertaken, in relation to each of the key parts of the framework described above.

Table.3. Activities undertaken

Activity type	Activities undertaken
Communication and outreach	Albania has carried out some communication and outreach activities, such as issuing Frequently Asked Questions, updating the Competent Authority website with various relevant materials for Financial Institutions, publications on social networks, and creating a dedicated email address and phone line for CRS queries. Albania also sends pop-up messages as reminders to comply with the CRS to taxpayers in their personal accounts on its tax portal. Since 2020, Albania has carried out physical meetings with the RFIs and the Albanian Association of Banks on a regular basis, including meetings with the RFIs, as well as with members of the Albanian Microfinance Association during 2024-2025.
Verifying that Financial Institutions are reporting as required	Albania has started to carry out annual verification activities to ensure that Financial Institutions are reporting as required. This is based solely on a review of lists of licensed entities with reporting obligations maintained by the Bank of Albania and the Albanian Financial Supervisory Authority. On this basis, reminder letters were sent to Financial Institutions that failed to report.
Verifying whether the information reported is complete and accurate	Albania has started desk-based checks to verify whether the information being reported is complete and accurate. Albania has sent compliance questionnaires to five RFIs in 2024. In addition, Albania has sent reminders to all RFIs in 2025 flagging the most frequently identified reporting issues encountered in 2024 (i.e. undocumented accounts, incorrect account classification and a low number of account reports). Albania has also undertaken two desk-based reviews in 2025 of RFIs in relation to undocumented accounts that were reported by one RFI, as well as on the basis of feedback from a partner competent authority. No in-depth reviews or onsite visits have yet been conducted.
Enforcement	Following the activities mentioned above, Albania has not yet imposed penalties and sanctions, but has plans to do so in the near future.

With respect to the Financial Account information collected and exchanged by Albania, the presence of the key data points of the Tax Identification Numbers and dates of birth appeared to be in line with most other jurisdictions, as did the level of undocumented accounts.

Feedback from Albania’s exchange partners indicated that, compared to what they generally experience when seeking to match information received from their exchange partners with their taxpayer database, they achieved a much lower level of success when seeking to match information received from Albania. Furthermore, 14 exchange partners highlighted issues with respect to the information received such as missing dates of birth, missing or invalid TINs, incomplete address data and incorrect names and surnames. Follow-up discussions confirmed that Albania is aware of these issues and is seeking to improve the situation.

Based on these findings, it has been concluded that Albania is partially expectations in ensuring that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures, including by having in place the required administrative compliance framework and related procedures. More specifically, significant issues have been identified, including with respect to implementing a complete and overarching compliance strategy to identify the population of Reporting Financial Institutions and to verify Reporting Financial Institutions’ compliance with the due diligence and reporting obligations. Albania should therefore continue its implementation process accordingly, including by addressing the recommendations made.

Recommendations:

Albania should further implement its compliance strategy to underpin its compliance activities, including ensuring it is informed by a risk assessment that takes into account a range of relevant information sources.

Albania should continue to carry out activities to ensure that Reporting Financial Institutions correctly apply the definitions of Reporting Financial Institution and Non-Reporting Financial Institution and report information as required and carry out activities to identify non-regulated Entities that are Financial Institutions for the purposes of the AEOI Standard.

Albania should continue to develop and implement an appropriate framework, including in-depth reviews, to verify whether Reporting Financial Institutions are effectively implementing the AEOI Standard, including the active monitoring of the interaction of its AML framework and its CRS framework to ensure that the collection and reporting of information is always in accordance with the AEOI Standard.

Albania should implement effective enforcement mechanisms to address non-compliance by Reporting Financial Institutions, including the application of dissuasive penalties and sanctions as appropriate, and routinely apply them where non-compliance is identified.

Albania should further implement its procedure to monitor and verify whether Reporting Financial Institutions are obtaining valid self-certifications as required, including dedicated communication activities.

Albania should continue its follow up activities with Reporting Financial Institutions that report undocumented accounts to ensure that the requirements are being complied with.

Albania should continue to address the issues raised by its exchange partners.

SR 1.6 Jurisdictions should collaborate on compliance and enforcement. This requires jurisdictions to:

• use all appropriate measures available under the jurisdiction’s domestic law to address errors or non-compliance notified to the jurisdiction by an exchange partner; and

• have in place effective procedures to notify an exchange partner of errors that may have led to incomplete or incorrect information reporting or non-compliance with the due diligence or reporting procedures by a Reporting Financial Institution in the jurisdiction of the exchange partner.

Findings:

In order to collaborate on compliance and enforcement, it appears that Albania implemented all of the requirements in relation to issues notified to them (i.e. under Section 4 of the MCAA or equivalent) in accordance with expectations. While no such notifications have yet been received, Albania has the necessary systems and procedures to process them as required. It also appears that Albania will notify its partners effectively of errors or suspected non-compliance it identified when utilising the information received.

Based on these findings it was concluded that Albania is fully meeting expectations in relation to collaborating with its exchange partners to ensure that Reporting Financial Institutions correctly conduct the due diligence and reporting procedures. Albania is encouraged to continue its implementation process accordingly.

Recommendations:

No recommendations made.

CR2 Effectiveness in practice: Jurisdictions should exchange the information effectively in practice, in a timely manner, including by sorting, preparing, validating and transmitting it in accordance with the AEOI Standard

Rating: On Track

Albania’s implementation of the AEOI Standard is on track with respect to exchanging the information effectively in practice, including in relation to sorting, preparing and validating the information (SR 2.4), correctly transmitting the information and in a timely manner (SR.s 2.5 – 2.8) and providing corrections, amendments or additions to the information (SR 2.9). Albania is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

SR 2.4 Jurisdictions should sort, prepare and validate the information in accordance with the CRS XML Schema and the associated requirements in the CRS XML Schema User Guide and the File Error and Correction-related validations in the Status Message User Guide (i.e. the 50000 and 80000 range).

Findings:

Feedback from Albania’s exchange partners did not raise any specific concerns with respect to their ability to process the information received from Albania and therefore with respect to Albania’s implementation of these requirements and this has improved over time.

Based on these findings it was concluded that Albania is fully meeting expectations in relation to sorting, preparing and validating the information. Albania is encouraged to continue its implementation process accordingly, to ensure its ongoing effectiveness.

Recommendations:

No recommendations made.

SR 2.5 Jurisdictions should agree and use, with each exchange partner, transmission methods that meet appropriate minimum standards to ensure the confidentiality and integrity of the data throughout the transmission, including its encryption to a minimum secure standard.

Findings:

In order to put in place an agreed transmission method that meets appropriate minimum standards in confidentiality, integrity of the data and encryption for use with each of its exchange partners, Albania linked to the CTS.

Based on these findings it was concluded that Albania is fully meeting expectations in relation to agreeing and using appropriate transmission methods with each of its partners. Albania is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.6 Jurisdictions should carry out all exchanges annually within nine months of the end of the calendar year to which the information relates.

Findings:

Two exchange partners highlighted delays in the sending of information by Albania (representing 2% of its partners). This represents an improvement in the timeliness of sending information. It was noted that Albania successfully addressed all of the issues and sent the information as soon as possible thereafter.

Based on these findings it was concluded that, overall, Albania is meeting expectations in relation to exchanging the information in a timely manner. Albania is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

SR 2.7 Jurisdictions should send the information in accordance with the agreed transmission methods and encryption standards.

Findings:

Feedback from Albania’s exchange partners did not raise any concerns with respect to Albania’s use of the agreed transmission methods and therefore with Albania’s implementation of this requirement.

Recommendations:

No recommendations made.

SR 2.8 Jurisdictions should have the systems in place to receive information and, once it has been received, should send a status message to the sending jurisdictions in accordance with the CRS Status Message XML Schema and the related User Guide.

Findings:

Two exchange partners highlighted delays in the sending of status messages by Albania, representing nearly 2% of its partners, which has decreased over time. It was noted that Albania appears to be successfully addressing the issues to ensure that status messages are sent in accordance with the requirements, although one jurisdiction noted that one status message expected has still not been received.

Based on these findings it was concluded that, overall, Albania is meeting expectations in relation to the receipt of the information. It was also noted that there is room for improvement with respect to timeliness of sending status messages. Albania is encouraged to continue to ensure the ongoing effectiveness of its implementation, including in relation to the areas highlighted.

Recommendations:

Albania should ensure it sends status messages to all of its exchange partners in a timely manner.

SR 2.9 Jurisdictions should respond to a notification from an exchange partner as referred to in Section 4 of the Model CAA (which may include Status Messages) in accordance with the timelines set out in the Commentary to Section 4 of the Model CAA. In all other cases, jurisdictions should send corrected, amended or additional information received from a Reporting Financial Institution as soon as possible after it has been received.

Findings:

Albania appears ready to respond to notifications and to provide corrected, amended or additional information in a timely manner. No such concerns were raised by Albania’s exchange partners and therefore with respect to Albania’s implementation of these requirements.

Based on these findings it was concluded that Albania appears to be meeting expectations in relation to responding to notifications from exchange partners and the sending of corrected, amended or additional information. Albania is encouraged to continue to ensure the ongoing effectiveness of its implementation.

Recommendations:

No recommendations made.

Comments by the assessed jurisdiction

No comments made.