The freezing of a bank account can effectively bring a company’s operations to a standstill: ordinary settlements with counterparties and a significant portion of outgoing transactions become impossible. In 2026, however, the regulatory framework remains in a transitional stage. At present, Articles 111–113 of the Tax Code and the additional safeguard introduced by Presidential Resolution No. PP-33 apply. At the same time, in August the Senate approved further amendments to the procedure for freezing business bank accounts, although the new rules cannot yet be treated as having entered into force. Can the tax authority freeze an account without a court order? Yes, but not arbitrarily. Under the currently effective Article 111 of the Tax Code, the head or deputy head of a tax authority may issue a decision to suspend transactions on bank accounts for a period not exceeding ten days. If the restriction is intended to remain in place for more than ten days, the decision must be made by a court upon an application by the tax authority. Where the matter has been referred to court, transactions remain suspended until the court resolves the issue. For legal entities and individual entrepreneurs, Article 111 provides specific grounds for suspension: The mere existence of tax arrears and the suspension of account transactions under Article 111 are not the same thing. The collection of tax arrears, including through collection orders, is governed by other provisions of the Tax Code. What if the business does not admit the violation? This is where another important safeguard applies. Since 1 May 2025, paragraph 5 of Presidential Resolution No. PP-33 has established a special approach: where a business entity admits a tax offence, transactions on its bank accounts may be suspended by the tax authority. However, if the entrepreneur does not admit that a tax offence has been committed and objects to the freezing of the account, the matter must be decided by a court upon an application by the tax authority. Accordingly, where a business disagrees with the alleged tax offence, its position should be recorded expressly and in writing. The business should separately state both that it does not admit the alleged violation and that it objects to the suspension of transactions. At the same time, PP-33 should not be mechanically extended to every situation covered by Article 111. The Tax Code concerns measures securing the performance of tax obligations, whereas PP-33 specifically addresses tax offences. This distinction may be significant when determining the appropriate legal remedy. What happens after ten days? Ten days is the maximum period for which the tax authority may independently impose the restriction; it is not a universal maximum duration for every account freeze. If the tax authority intends to maintain the restriction for a longer period and refers the matter to court, the account may remain frozen until the court issues its decision. However, the original decision of the tax authority does not automatically become indefinite merely because the account remains blocked in practice. Therefore, after the ten-day period expires, it is necessary to determine whether the tax authority has applied to court, whether relevant court proceedings or a judicial act exist, and what legal basis supports the continued restriction of transactions. This is particularly important in practice, where the legal term of the decision and the actual status of the bank account may not coincide. When must the tax authority lift the freeze? Article 112 of the Tax Code establishes specific deadlines for lifting the restriction. If reporting was not submitted, the decision must be revoked no later than the day following its submission. Where documents, explanations or corrections were not submitted, the restriction must be lifted on the day they are provided. Where inspectors were denied access, the restriction must be lifted no later than the day following the granting of access. Where the taxpayer was absent from its declared address, the restriction must be lifted no later than one day after the tax authority recognises the reasons for the absence as justified. Once a decision to lift the restriction has been adopted, the tax authority must send it electronically to the bank no later than the following day. The bank, in turn, is required to comply with the tax authority’s decision. Therefore, a paper decision alone is not sufficient: it is necessary to verify that the revocation has actually been received by the bank and that outgoing transactions have been restored. Can interest be claimed for an unlawful account freeze? Yes. If the tax authority breaches the statutory deadline for lifting the freeze or the deadline for sending the revocation decision to the bank, interest accrues for each calendar day of delay on the amount of funds in respect of which the suspension applied. Interest is also provided for where the freezing decision itself was unlawful. In such cases, interest accrues for the period from the date on which the bank received the decision suspending transactions until and including the date on which the bank received the decision revoking it. Accordingly, a dispute with the tax authority may concern not only the unfreezing of the account, but also the financial consequences of an unlawful restriction on the company’s activities. How can an account freeze be challenged? Articles 230–231 of the Tax Code allow non-regulatory acts of tax authorities, as well as actions and omissions of their officials, to be challenged before a higher tax authority or in court. The Tax Code also provides for the suspension of enforcement of the challenged decision or action where a complaint is filed in the prescribed manner. In judicial proceedings, the existence of the tax authority’s decision alone is not sufficient. According to the explanations of the Plenum of the Supreme Court, the court must verify both the existence of a statutory ground for suspension and the existence of a decision by the head or deputy head of the tax authority imposing the initial suspension of transactions for a period not exceeding ten days. What changes are planned? On 8 August 2026, the Senate approved a law aimed at reducing the regulatory burden on entrepreneurs. It provides for a clearer distinction in the procedure depending on the position taken by the business itself. It is proposed that, where the taxpayer admits the tax violation and raises no objection, the freeze may be imposed directly by the tax authority. If the entrepreneur objects, however, the matter must be decided by a court. After receiving the objection, the tax authority will be required to apply to court within no more than three days. The entrepreneur’s objections and evidence of the violation must be submitted together with the application. If the court finds the objections to be justified or establishes that the violation has been remedied, the suspension of transactions must be lifted on the day the court decision enters into legal force. The scale of the issue is significant. According to Supreme Court data cited by the Senate, during 2023–2025 economic courts considered more than 960,000 cases involving the suspension of transactions on entrepreneurs’ bank accounts, and approximately 95% of applications filed by tax authorities were granted. However, as of 10 September 2026, these new rules should not be described as already being in force. Current situations must primarily be assessed under Articles 111–113 of the Tax Code currently in force and paragraph 5 of PP-33. What should businesses pay attention to now? When a bank account is frozen, it is not enough simply to ask the tax inspector “when it will be reopened.” The business should obtain the actual decision, identify the specific legal ground for the freeze, determine the date of the decision and its validity period, verify whether court proceedings exist, formally record its objections in writing if it disputes the alleged tax offence, and confirm that the revocation decision has actually been received by the bank. It is especially important to distinguish between two situations: the account remains blocked in practice and there is a valid legal basis for the continued blocking of the account. These are not always the same thing. Where the restriction is unlawful, protection of the business may include not only a demand to unblock the account and a challenge to the tax authority’s decision, but also a claim for the interest provided for under the Tax Code. Legal framework: This material is current as of 10 September 2026.Tax Authority Freezing of Bank Accounts in 2026: Current Rules and Upcoming Changes
