 # ENS Balance: A New Judicial Precedent That Will Save Your Business **April 28, 2026** Imagine: you pay your taxes diligently, you have no debts to the budget, but one day the tax office sends you a notification—your ENS balance is negative. It turns out the inspectorate has credited your current payments against an arrears that it itself recognized as uncollectible. And it did so without a court order. This is exactly what happened to a taxpayer who challenged the inspectorate's actions—and won. ## What Happened The taxpayer discovered that the inspectorate had formed the balance of the single tax account (ENS) without considering a court decision. The court had previously recognized the VAT arrears for Q1 2019 as uncollectible—along with penalties. But the tax authority still credited current payments against this "debt." The court sided with the business and declared the inspectorate's actions unlawful. ## Why This Matters for Your Business The ENS is a mechanism designed to simplify tax administration. All payments go to a single account, the balance of which tax authorities see in real time. But the problem is that inspectorates have gained a tool for automatic offset—and have started using it even where the debt has already been recognized as uncollectible. This precedent creates an important protection mechanism: 1. **A court decision takes priority over automatic ENS offset.** If a court has recognized an arrears as uncollectible, the inspectorate has no right to consider it when calculating the balance. 2. **The ENS is not a carte blanche for the tax authority.** Automation does not override the law. Even if the system "sees" a debt, but it is recognized as uncollectible, the offset is illegal. 3. **Money can be recovered.** If your payments have already been applied to an uncollectible arrears, you have grounds to go to court. ## What to Do Right Now Check your ENS balance. If you have court decisions recognizing arrears as uncollectible, make sure the tax authority has taken them into account. If not, document the discrepancies and prepare objections. Legal analysis of this level typically requires hours of a lawyer's work and access to paid databases. ASI Biont analyzes the same data in seconds—and finds precedents that could save you millions. **New users receive 1500 tokens to start.** Launch an AI lawyer on your tax history—and find out what money you can recover today. [https://asibiont.com](https://asibiont.com)