Fines for a missed IMPIC filing
Missing a mandatory IMPIC filing is an administrative offence punishable by a fine of 5 000 € to 500 000 € for companies and 2 500 € to 500 000 € for individuals.
Where the figures come from
A real-estate entity falls under article 4(1)(d) of Law 83/2017, so the bracket is article 170(1)(d): 5,000 € to 1,000,000 € for a company. Missing the article 46 filing is a plain offence under article 169(d), and article 170(2) halves the maximum for those, which is where the 500,000 € ceiling comes from. Ranges reaching 5,000,000 € belong to credit and financial institutions and do not apply here.
Failing to appoint a compliance officer is an especially serious offence instead, so its maximum is not halved. Article 171 also raises the ceiling to twice the economic benefit obtained, whenever that is determinable and higher.
Why a gap is easier to detect now
Article 46(5) has required the tax authority to share what it holds with IMPIC since 2020, and in June 2026 IMPIC announced a protocol with the tax authority to cross-check property transactions. The tool was described as under development at the time of the announcement, but past transactions remain on record.
Source: Law 83/2017, articles 46, 169, 169-A, 170 and 171, as amended by Law 58/2020. Informative only, not legal advice. Mandatory Communications on the IMPIC website ↗