In the first quarter of 2026, a new and concerning practice began to arise in Belarus: tax authorities are suspending transactions on the bank accounts of legal entities absent at their place of registered legal address. This is due to changes to the Tax Code effective as of January 1, 2026.
According to media reports, there were multiple cases where transactions on corporate bank accounts were suspended without prior notice to the legal entities. Some legal entities, both commercial and non-profit, using the so-called rented or purchased legal addresses, essentially “mailbox” addresses, are coming under increased scrutiny by tax authorities.
For example, iDriveCorp offers legal addresses for rent at its offices in the Minsk District. A total of 459 legal entities are registered there (with lease contracts signed with 308 of them). Recently, 166 of the company’s tenants have had their accounts frozen. Accounts were suspended even if the legal entity had its own office at its registered legal address, but no employees were there at the time of the tax inspection, which was carried out without prior notice. According to tax authorities, “the account freeze will be removed once the violations have been eliminated”. However, the letters from the tax office do not explain exactly how the organisation can prove that it is located at its registered address and that whatever the tax authorities consider to be a violation has been resolved.
As experts note, while the legal address used to be a somewhat vague concept open to various interpretations, and in practice it was possible to register a large number of legal entities (including public organisations) in one place, the situation has now changed. The legal address has evolved from a formal requirement into a point of tax control.
The option of a virtual legal address, which exists in many countries, is not provided by Belarusian laws on legal entities. The new bill on the registration of legal entities, recently adopted in its second reading, does not introduce any new provisions in this regard, either - although it expands the scope of online communication between legal entities and registration authorities, as well as new reporting and communications portal for public associations.
Ineffective sanctions are an obstacle to eliminating the violations
In practice, however, freezing an organisation’s account effectively paralyses its operations, including its ability to pay rent and salaries. Thus, the penalty itself amplifies the barrier that caused the penalty in the first place.
Simply changing a legal address from a shared office to a separate office involves financial costs (which are particularly burdensome for civil society organisations). Furthermore, if licenses and other documents are tied to the legal address, changing it will entail additional complications and expenses.
This new practice creates opportunities for abuse, as tax inspectors do not give prior warnings about their visits and do not contact organisations via email or by phone using the contact information provided during registration.
Common characteristics of such business entities with frozen accounts include, according to the legal analysis:
- Registration at an address where dozens, or even hundreds, of legal entities are simultaneously registered;
- Absence of any indication that the manager or office staff is actually present at that address;
- The formal use of the legal address without conducting any actual business activities at that location.
Civil society organisations (especially private institutions and public associations) typically fall under these criteria. This is due to economic reasons: many organisations do not need an office because of the nature of their activities; a “legal address” is sufficient for conducting correspondence. There is no specific information on how many CSOs were subject to such inspections and faced account freezes.
Legal grounds in the Tax Code, and the expanded regulation of tax authorities
The legal grounds for freezing the bank accounts are the amendments to Article 56, point 2, of the Tax Code, which took effect on January 1, 2026. These amendments included sub-point 2.5, which grants tax authorities the right to suspend transactions on an account or an electronic wallet, if they establish that a Belarusian legal entity is not present at its place of state registration.
In accordance with point 4 of Article 56 of the Tax Code, a decision to freeze transactions on accounts and electronic wallets should be sent to the bank (payment service provider) no later than one business day following the date of its adoption and is subject to mandatory enforcement.
Key points in understanding these provisions:
- The tax authority has the right to establish the absence of a legal entity at its place of state registration;
- Upon confirmation of such a fact, the suspension of transactions on accounts and e-wallets is permitted;
- The inspection act serves as confirmation.
The form of such an inspection act was established by Resolution №11 of the Ministry of Taxes and Fees dated February 27, 2026, which took effect on April 1, although inspections of this kind (and the resulting account freezes) had already been recorded earlier in 2026.
According to the resolution, when verifying a legal entity’s location at its place of state registration, an employee or any individual must be present to sign the inspection report at the location. Under the law, the “place of location of a legal entity”, commonly referred to in business practice as the “legal address”, is defined as the premises where the company’s head body is located. It is this address that is specified in the articles of incorporation, recorded in the Unified State Register, and to which legally significant communications for the company are sent. The originals of the founding documents, the Book of Comments and Suggestions, and the employees’ employment records must be kept at this same address.
How this works in practice, according to the local legal practitioners:
- The tax authority conducts an on-site inspection of the organisation at its official registration address.
- If the organisation is found to be absent, an inspection act is drawn up.
- Based on this act, the tax authority has the right to issue a decision suspending transactions on accounts or e-wallets.
- The decision is sent to the bank (and the taxpayer) within the timeframes established by the Tax Code—in practice, the freeze can occur quickly after the decision is made. Payments to the budget and state off-budget funds, however, can still be made - the suspension does not apply to them.
Additionally, in its clarifications regarding changes effective January 1, 2026, the Ministry of Tax and Fees emphasises this very mechanism: the fact of absence is confirmed by an inspection act regarding the legal entity’s location at the official registration address.
According to tax authorities, a report stating that a taxpayer was not found at their registered address cannot be appealed in court. Business owners who contacted the tax authorities to ask how they could eliminate violations were advised to rent a separate office where no other legal entities are registered and, accordingly, to change their registered address. If this practice becomes widespread, demand for physical offices will increase, which means rental prices will rise as well.
The current Decree №1 of 2009 on the registration of legal entities requires CSOs, just like any other legal entity, to have a registered legal address, and this address must be located in a non-residential space. However, there is no prohibition against dozens or even hundreds of organisations sharing the same legal address within a single location. In practice, many CSOs use such registered addresses as the most cost-effective option, especially if the nature of the organisation’s activities does not necessitate a large, separate office.
It appears that, taken together, the implementation of these provisions violates international standards, since there is no prior notification of inspection visits, or information process for legal entities in advance. This results in serious consequences, such as accounts freezing – a measure that should be last resort rather than the first response.
The problem persists despite a bill passed on April 17 It should be noted that strict provisions regarding registration location remain in the draft “On State Registration and Liquidation (Termination of Activities) of Legal Entities”, which is currently being finalised. On April 17, this law was passed in its second reading by the House of Representatives and was sent to the upper house of parliament (the Council of the Republic) for consideration. This bill is intended to replace the Decree №1, which currently regulates these issues. This legislative update is not a true reform, but rather a technicality in line with replacing all decrees by laws due to the 2022 amendments to the Constitution, which removed the "decree" as a special type of legal act issued by the president alone from legislation.
This bill, like the current decree, will regulate issues of state registration and liquidation of a wide range of legal entities, including thousands of non-commercial organisations, private institutions, unions of legal entities, consumer cooperatives, and gardeners’ communities. The registration and liquidation of other forms of CSOs, such as foundations, public associations, political parties, religious organisations, and trade unions will continue to be regulated by separate laws with stricter procedures, including requirements on the legal address. The requirement for public associations to have a separate legal address (as a place of location) and the prohibition on locating them in the founder’s residential premises are stipulated in Article 8 of the Law on Public Associations. In some cases, however, the registered address of a commercial organisation may be the residential address belonging to its founder.
In conclusion, the new law on registration of legal entities will not correct the inequality of different forms of CSOs in the registration process; better conditions for some commercial legal forms remain.
The emerging practice of inspecting organisations at their legal addresses could lead to widespread allegations of violations and the freezing of civil society organisations’ bank accounts.