Form FR0615 Reporting Rules: Mandatory "#" Prefix for Eligible Pillar III Pension Contracts

By Order No. VA-71 of 23 October 2026, the Head of Lithuania's State Tax Inspectorate (VMI) amended the rules for completing and submitting Form FR0615 and its supplementary sheet FR0615P, originally approved by Order No. VA-66. The amendment took effect on 24 October 2026 and applies to reporting and amending data for the 2025 tax period and subsequent tax periods.

The update revises paragraph 18 of the rules, which governs entries on sheet FR0615P. Data providers must prepend the symbol "#" to the contract number in field P9 if a Pillar III supplementary pension contract was concluded on or before 31 December 2024, but entered into force after that date. The same "#" prefix is mandatory when a contract was entered into after 31 December 2024 following a participant's transfer between funds, provided that the transferred balance originated from an agreement concluded prior to that date without commingling contributions initiated after 31 December 2024.

Paragraph 18 provides an explicit exception: the symbol "#" must not be added to the contract number when field P1 indicates contribution type code 9, which designates supplementary contributions to Pillar II pension funds.

This administrative procedure implements the transitional rules of Article 21(1)(2) of the Law on Personal Income Tax (GPMĮ). Under this statutory provision, contracts concluded by the end of 2024 retain personal income tax relief through 31 December 2034. Flagging these agreements with the "#" symbol enables VMI to identify qualifying contracts automatically, sparing individuals from manually uploading verification documents or payment proofs during the annual tax return filing.

Pension management companies and other reporting entities must submit Form FR0615 for each calendar year annually by February 15 of the following tax year.