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i.MAS Fines in Lithuania: How to Avoid Up to €6,000 in i.SAF and i.SAF-T Penalties

Every Lithuanian company registered for VAT files an i.SAF register every month, even an empty one, and has to produce a full SAF-T audit file within about ten days when VMI asks. A missed register is a fine of up to €390 under the Code of Administrative Offences; ignoring a written VMI request can reach €6,000.

Nordlet Team · · 9 min read

i.MAS is the electronic data system of Lithuania's State Tax Inspectorate (VMI). A Lithuanian company that is registered for VAT sends VMI its sales and purchase invoice registers (i.SAF) every month by the 20th, including months with no invoices. When VMI opens a control action, it can demand the company's full accounting data as a SAF-T file (i.SAF-T), with at least 10 days' notice. Late, missing or wrong data is an administrative offence under Article 187 of the Code of Administrative Offences (ANK), with a warning or a fine of €200 to €390. Failing to hand over income or profit data after a written VMI reminder carries €400 to €6,000.

This article sets out what each part of i.MAS requires, who it applies to, what the fines are, and the exceptions that VMI itself publishes. Every rule below links to its source at the end.

What i.MAS is

VMI lists five subsystems in i.MAS today:

Subsystem What it does Who uses it
i.SAF Monthly registers of VAT invoices issued and received VAT payers
i.SAF-T Full accounting data in the SAF-T XML format, on VMI's request Profit-seeking legal entities
i.VAZ Electronic waybills for road transport of goods within Lithuania The person who prepares the waybill
i.APS Remote bookkeeping services for small businesses Optional
i.EKA Smart electronic cash registers Businesses using such registers

For most companies, three of these carry an obligation: i.SAF, i.SAF-T and i.VAZ.

i.SAF: every month, even with no invoices

Who files. Every legal entity registered for VAT. There is no turnover threshold and no exemption by industry. A one-person company that registered for VAT voluntarily has the same obligation as a company with a thousand invoices a month.

When. By the 20th of the following month. A deadline on a weekend or public holiday moves to the next working day. The exact 2026 dates are in Business Tax Deadlines in Lithuania 2026.

Months with no invoices. VMI requires the registers to be submitted anyway, empty. A month with no sales and no purchases is still a filing, and a missing empty register counts as a missing register.

On leaving VAT. A company that deregisters as a VAT payer submits its last registers within 20 days of deregistration.

The exceptions VMI publishes.

  • Individuals registered for VAT file every half-year by default, by the 20th of the first month of the next half-year, unless their VAT period is monthly.
  • VAT payers in the small-business scheme (SVS) that started on 1 May 2025 have no obligation to submit i.SAF registers.

What VMI does with it. VMI matches the seller's sales register against the buyer's purchase register. An invoice that appears on one side and not the other, or with a different amount, is flagged for review. This is why errors in i.SAF lead to questions even when the VAT return itself is correct.

i.SAF-T: the full ledger, at least 10 days after VMI asks

What it is. A single XML file with the company's general ledger, customers and suppliers, sales and purchase invoices, payments, stock movements and fixed assets, in VMI's SAF-T structure (based on the OECD SAF-T standard).

When it is due. Only when VMI asks, during a control action such as an audit or a tax check. It is not filed periodically. VMI's rule is that at least 10 days must pass between the day the request is served and the day the data is due. A shorter period is possible only at the taxpayer's request or with its consent.

Who must be able to produce it. Profit-seeking legal entities. VMI phased the obligation in by net sales: companies above €8 million from 2017 data, above €700,000 from 2018 data, and above €300,000 from 2019 data. Branches of foreign companies, public sector bodies and non-profits are not obliged.

Why this is the risky one. i.SAF is routine: it happens every month, and a mistake shows up quickly. An i.SAF-T request may come once in several years, for a period that can be years in the past, and it covers everything at once. Ten days is enough to export a file from accounting software that already holds the data in the right structure. It is not much time to rebuild a ledger, fix customer and supplier codes, and map every account and VAT code to VMI's classifiers. VMI provides a free test environment where a company can check that its file validates before any request arrives.

i.VAZ: before the goods move

The person who prepares the waybill, usually the consignor, submits the waybill data to i.VAZ no earlier than 7 days before the planned dispatch and no later than the dispatch date and time on the waybill.

It applies when all three conditions hold:

  • the goods are carried by road, only within Lithuania;
  • both consignor and consignee are businesses or individuals carrying out economic activity;
  • there is a commercial carriage relationship between the parties.

Carriage on one's own account (Road Transport Code, Article 38) does not need to be reported. Small companies without accounting software can enter waybills by hand in the i.MAS portal.

The fines

The fines are set in Article 187 of the Code of Administrative Offences (ANK), which covers failure to submit, late submission, and submission of wrong documents and data that the tax administrator needs.

Offence ANK article Penalty
Data or documents for the tax administrator (such as i.SAF, i.SAF-T or i.VAZ data) not submitted, submitted late, or submitted wrong 187(2) Warning, or a fine of €200 to €390
Income, profit or asset data not submitted after a written VMI reminder, in order to avoid taxes 187(3) €400 to €6,000
Knowingly false data submitted 187(4) €1,000 to €6,000
Goods carried without the required transport documents 214 €190 to €3,770 depending on the value of the goods, and the goods are confiscated

Three points that are often stated wrongly:

  • €390 is the top of the first-offence range, not a separate repeat fine. Article 187 has no separate part for repeat offences. A repeat offence is an aggravating circumstance (ANK Article 36), which pushes the fine towards the top of the range.
  • €6,000 is not a general i.MAS fine. It is the upper limit for refusing to hand over income, profit or asset data after VMI has reminded the company in writing, and for knowingly false data.
  • A fine does not replace the filing. The registers or the SAF-T file still have to be submitted, and any VAT that the check finds is assessed separately, with late-payment interest.

How many companies miss i.SAF

VMI does not publish a yearly count of late or missing i.SAF filings or of the fines it imposes. The most recent official figures come from the National Audit Office's 2019 audit of i.MAS:

  • almost 72,000 taxpayers were obliged to submit i.SAF registers;
  • about 66,800 VAT payers submitted them in a month.

On those two figures, about 5,000 obliged taxpayers, roughly 7 %, did not submit in a given month. This is our calculation from the audit's two numbers, not a figure the audit states, and the data is from 2019. The same audit reports that checks based on i.SAF and i.VAZ data led to €3.7 million of additional VAT being declared in 2017 and €7.6 million in 2018. Each of those registers is matched against the other side's register, so a gap in one company's filing is visible to VMI from its customers' and suppliers' data.

How to make sure nothing is missed

The deadlines are fixed and the formats are published, so the work is in keeping the data complete as it happens, not in a rush before the 20th:

  1. Record every invoice with the fields i.SAF needs at the time it is issued or received: counterparty VAT and company codes, country, VAT point date, and the VMI VAT classifier (PVM1, PVM2 and so on), not only the rate.
  2. Submit every month, including empty months. Put the 20th in the calendar of whoever is responsible, with the shifted date when it falls on a weekend.
  3. Validate a SAF-T file before VMI asks. Generate one for a past year and check it in VMI's test environment. Errors found this way cost nothing; errors found during a 10-day request do.
  4. Keep the company's VMI certificate valid. An expired certificate stops web-service filing on the day it is needed.

How Nordlet handles i.MAS

Nordlet is an accounting system with an API. For a Lithuanian company it:

  • Builds and sends i.SAF. The deadline calendar shows the i.SAF due date for each month with the weekend shift applied. File now builds the register from the posted sales and purchase invoices and sends it to i.MAS under the company's own certificate; automatic filing sends it a few days before the due date, never twice for one period. A month with no invoices is sent as an empty register. Each warning names the document and the field that is missing. Through the API: POST /v1/declarations/lithuania/isaf/generate.
  • Builds and sends i.SAF-T. POST /v1/declarations/lithuania/saft/generate produces the full file or one section (general ledger, sales invoices, purchase invoices, payments, stock movements, assets) for any date range. POST /v1/declarations/lithuania/saft/send uploads it to i.SAF-T and tracks its processing; the submission is confirmed as a separate step, because a confirmed file can no longer be corrected.
  • Builds i.VAZ waybills. POST /v1/declarations/lithuania/ivaz/generate takes up to 100 waybills; ivaz/amend and ivaz/cancel produce the follow-up messages.

Certificates are uploaded once in Settings → Compliance, with a warning 30 days before they expire. The full list of what Nordlet files in Lithuania and the other 29 countries is on the filing support page, and the data each Lithuanian filing needs is in Lithuania's Compliance Stack for Developers. To try it with your own company, get started here.

FAQ

Does a company with no invoices in a month still submit i.SAF?

Yes. VMI requires the registers to be submitted empty. A month without an empty register is treated as a missing filing.

What is the fine for a late i.SAF?

Under ANK Article 187(2), a warning or a fine from €200 to €390. A repeat offence is an aggravating circumstance that moves the fine towards the top of that range; there is no separate repeat-offence amount in Article 187.

How long does a company have to provide SAF-T when VMI asks?

At least 10 days from the day the request is served. VMI can set a shorter period only at the taxpayer's request or with its consent.

Does every company have to be able to produce SAF-T?

Profit-seeking legal entities do, following the phase-in by net sales (above €300,000 from 2019 data). Branches of foreign companies, the public sector and non-profits are not obliged. VMI also states that there is no SAF-T obligation where the accounts are kept only in Excel, but a company in that position still files i.SAF monthly and still has to give VMI its accounting records during a check.

Do small-business-scheme VAT payers file i.SAF?

No. VAT payers in the SVS scheme, available from 1 May 2025, have no obligation to submit i.SAF registers.

Can i.SAF be filed without accounting software?

Yes. VMI accepts data entered by hand in the i.SAF subsystem, as well as XML files and web-service uploads. Manual entry takes time for every invoice and does not help with an i.SAF-T request, which has no manual entry option.

Sources