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- Passive tax: Businesses are increasingly complaining about erroneous account blocking
Passive tax: Businesses are increasingly complaining about erroneous account blocking
This year, entrepreneurs began to complain more often about the erroneous blocking of their accounts by the tax service — lawyers note an increase in the number of such requests by 10-15%. This is due to the automation of control against the background of a large number of changes in the reporting rules. Sometimes money remains unavailable for several weeks, which literally freezes the work of companies. The Federal Tax Service told Izvestia that such cases are still not widespread. They deal with each case in detail. The tax service even gave their recommendations to the business. What to do to solve the problem faster is in the Izvestia article.
Why does the tax service block business accounts?
Against the background of stricter control by the tax service, businesses began to complain more often about erroneous blocking of their accounts, lawyers told Izvestia.
The editorial staff studied the appeals of entrepreneurs in the official chat of the Federal Tax Service. For example, one of them writes: "By mistake, the individual entrepreneur's account was blocked for the lack of filing 3 personal income tax for 2025. There weren't even any notifications!"
Another person said that he works under the simplified taxation system (STS); he also lost access to money. "During the call, the inspector corrected the error and formed an unblocking decision, which no longer passes through the system due to some kind of malfunction in it. The account has been blocked for the fourth day. Due to the fact that the decision does not reach the bank," his message says.
There are also complaints from entrepreneurs about the automated simplified Taxation System (AMS) in the chat. In this case, the tax is calculated by the Federal Tax Service itself according to data from banks and cash registers. A person does not have to submit most reports, and the obligation to pay insurance premiums is canceled. However, when working in this mode, you need to meet income limits (up to 60 million rubles per year), and there are restrictions on the number of employees — there should be no more than five people. The USN requires submitting a declaration once a year, paying insurance premiums for yourself and the staff. The fee is calculated by the taxpayer himself.
The appeals say that some entrepreneurs have had their accounts blocked on the TSA due to non-payment of VAT, although they should not transfer it. Moreover, access to funds was not returned even after "all the deadlines set by the regulations" had passed. This refers to the obligation of the Federal Tax Service to send to the bank a decision to cancel the account lock no later than one business day after the issue is resolved. It takes another day to transfer the decision to the credit institution, which removes the restrictions within a few hours. The whole process should take up to three days.
In another appeal, it is said that the Skolkovo resident lost access to the account due to the lack of an income tax return, although he received an exemption from it.
The number of such complaints has increased by about 10-15% over the past few months, Artem Oknyaev, the founder of the De Jure law firm, estimated. Natalia Kajrishvili, head of the Finkling accounting agency, says that in recent months, clients have increasingly written the same thing: they went to the bank in the morning, but the account was blocked, almost always by mistake. And even when the inspectorate recognizes this or receives the necessary documents, access to money may be limited for several more days, or even weeks. She also noted an increase in the number of such requests from businesses by about 10-15% this year.
Opora Russia did not see this trend. But the executive director of the organization, Andrey Shubin, clarified that account blocking is an extreme measure that causes business paralysis and the inability to fulfill obligations.
In turn, Inna Ivanova, head of the "Pre-trial resolution of Tax Disputes" department of the Tax Disputes Practice at Lemchik, Krupsky & Partners, confirmed that there have indeed been more such appeals recently. Most often, we are talking about situations when the Federal Tax Service incorrectly defines the obligation of entrepreneurs to submit certain reports, she explained. This is especially noticeable in relation to participants in special tax regimes and preferential categories of taxpayers.
The Federal Tax Service continuously analyzes taxpayers' appeals through all feedback channels," the agency told Izvestia.
— The described cases are isolated, do not have a mass character, and are dealt with in detail by the service separately for each applicant, — the service specified.
They stressed that the Federal Tax Service has the right to send a notification of non-fulfillment of the obligation to submit a declaration. It is informational in nature and does not oblige the taxpayer to provide explanations. For example, if companies (such as Carousel users) do not have to provide such reports, then this message does not require a response.
— At the same time, the mailing list among AUTOSN users was not widespread, as statistics confirm — it affected only 0.09% of special-mode users. And the relevant clarifications have already been brought individually to the payers of auto insurance," the tax service added.
They advised to closely monitor compliance with income limits. They also recommended checking whether the tax authority has received the declaration.
Why errors occur
The increase in the number of complaints is related to the automation of the control of the Federal Tax Service against the background of a large number of changes in the rules of tax reporting, experts say. If the databases were updated asynchronously or the system incorrectly determined the taxpayer's obligation, there is an automatic requirement to submit reports, Natalia Kajrishvili explained. This is followed by a decision to suspend operations on the account.
There are more similar cases after changes in legislation. Since 2025, for example, the rules for working with the calculation and payment of value-added tax on the Unified tax System have changed. Employees of the Federal Tax Service have to reconfigure control algorithms on the go and take into account a lot of different exceptions, the expert explained.
But there is also a deeper and more systemic problem that puts enormous pressure on business, which is the tax service's work to identify and reset one—day firms, says Alexander Kazus, a lawyer and managing partner at SKP law firm. In the first half of 2026, 101.7 thousand companies were excluded from the Unified State Register of Legal Entities by the decision of the Federal Tax Service. Almost a third of them provided false information, the expert noted.
"This mechanism is aimed at combating unscrupulous taxpayers, but in practice, bona fide partners have to prove their innocence themselves and bear the risk of financial losses," stressed Alexander Kazus.
How does a business face account freezes?
If the inspection quickly confirms that the lock is incorrect, in practice the issue can be resolved in one to three working days, Inna Ivanova noted. If you need to adjust the data or interact with several departments of the Federal Tax Service, the procedure can sometimes take a week or more.
— While the account is inactive, payments to suppliers, rent, salary, taxes, and loans are suspended. Then the deadlines for contracts are disrupted and a cash gap appears," Natalia Kajrishvili listed.
For a small business, even a few days without access to a checking account is a serious problem, since it often does not have a significant reserve of liquidity, agreed Artem Oknyaev from De Jure. And if, after confirming the error, the funds remain blocked for weeks, the administrative measure actually turns into a financial sanction, he stressed.
Moreover, businesses are forced to incorporate this risk into their activities: to keep an additional reserve of funds, distract accounting and lawyers for correspondence with the inspectorate, and constantly monitor the correctness of information in information systems.
If the account is still blocked, then the business should fix the dates, Inna Ivanova advised. Because in case of unlawful restrictions or violation of the terms of restoring access, the entrepreneur must be compensated. Interest is charged on the blocked amount.
What to do when an account is blocked
In case of a freeze, first you need to find out the number and basis of the decision of the Federal Tax Service, as well as check the status of reporting, experts advise.
— Even if the requirement is erroneous, a call to the inspection will not solve the problem. You need to write an appeal through your personal account, attach documents (confirmation of the tax regime, exemption, absence of employees or timely reporting), — Natalia Kajrishvili from Finklining advised.
The Federal Tax Service also has a service called "Operational assistance: account unblocking and security questions." You can use it to describe the situation, attach documents, and speed up the removal of the lock. This mechanism works for organizations, sole proprietors, and individuals. The tax service must review the application within 24 hours.
The expert also advises to check separately that after the cancellation of the decision, the information about unblocking actually goes to the bank. If the issue is not resolved promptly, you should involve the management of the inspectorate and file a complaint with a higher tax authority, advises Inna Ivanova from Lemchik, Krupsky and Partners.
At the same time, it is not necessary to submit reports that the entrepreneur is not required to submit solely for the sake of formally unblocking the account. In some cases, such a "zero" declaration may, on the contrary, raise additional questions and incorrect tax obligations, she stressed. According to the expert, it is advisable to first eliminate the very reason for the erroneous suspension.
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