An enforcement fine from Skatteetaten – can it be waived?
Act quickly. An enforcement fine is not primarily a punishment for something you have already done – it exists to force a filing through. If the fine has started to run, file what is missing first and consider the appeal alongside it.
What is an enforcement fine?
Skatteetaten can use an enforcement fine (tvangsmulkt) where a business does not file its tax return, VAT return, a-melding, shareholder register statement, excise duty return or certain third-party information. It can also be used where the business does not comply with a bookkeeping order (bokføringspålegg), or fails to give information Skatteetaten has asked for during an audit. An enforcement fine should not be confused with additional tax. Additional tax is an administrative sanction that can be imposed for incorrect or incomplete information. The enforcement fine, by contrast, exists mainly to make the business act.
How large can the fine get?
The court fee in 2026 is NOK 1,345. For the tax return and the VAT return the standard rate is half a court fee per day – NOK 672.50 per day in 2026 – with a normal maximum of NOK 67,250. For a bookkeeping order the standard rate is one court fee per day, NOK 1,345 in 2026, and the total fine can reach one million kroner. The a-melding has its own rules. In 2026 the rate is normally NOK 134 per day per income recipient for whom mandatory information is missing. The maximum fine is NOK 1,345,000 per period.
Can the fine be waived?
Yes. There is no guarantee, but the rules give several openings. An enforcement fine should not accrue where it was impossible to meet the obligation for reasons not attributable to the business itself. In addition, Skatteetaten can reduce or cancel a fine that has already accrued in particular cases. Guidance from the Directorate of Taxes issued in July 2026 indicates that relevant factors can include serious and sudden illness or injury, a death, an acute situation at the accountant or another assistant, documented faults in the filing or in electronic systems, incorrect information or procedural errors on Skatteetaten's part, and whether the business otherwise has a good filing history. Misunderstanding the rules, poor communication between the business and its accountant or auditor, weak finances, or information having been filed under the wrong entity are normally not enough on their own.
How do you appeal?
The appeal deadline is normally six weeks from the date the decision was received. The appeal goes to Skatteetaten and should explain which decision is being appealed, why the fine should be reduced or cancelled, what change is sought, and the documentation supporting it. If the tax office does not change its decision, the case goes on to the Directorate of Taxes, which is the appeal body for enforcement fines. As a general rule the fine has to be paid while the appeal is being considered.
What if you also get additional tax?
For the same failure to file, an enforcement fine that has been paid must be deducted when the additional tax is calculated. That does not necessarily apply where the fine and the additional tax relate to two different matters.
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This is general guidance, not advice on your specific case. Deadlines, rates and amounts change – always check the current rules, or get in touch with us.
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