The Association, continuing its institutional efforts to guarantee the constitutional right of organisation and professional membership of auditors in office of the Supreme Audit Institution, has addressed the Commissioner for Protection from Discrimination and the People's Advocate, requesting the examination of the restrictions provided for in the internal acts of KLSH.

On 21.09.2026, the Association of External Public Auditors officially addressed the Chairman of the Supreme Audit Institution, Mr. Arben Shehu, requesting the review and amendment of Article 12 of the Code of Ethics and Article 45 of the Internal Regulation of KLSH.

According to the Association's assessment, the wording and interpretation of these provisions create unjustified restrictions for KLSH employees, preventing or limiting their possibility of becoming members and of taking part in professional organisations with lawful purposes.

In the request addressed to KLSH, the Association argued that membership in a professional organisation which aims at the development of the profession, continuing education, the exchange of experience, the improvement of auditing standards and the promotion of professional ethics cannot automatically be considered a conflict of interest or an activity incompatible with the public function.

The Association requested that the relevant provisions be assessed against Article 46 of the Constitution of the Republic of Albania, which guarantees that:

“Everyone has the right to organise collectively for any lawful purpose.”

In this context, the Association proposed that the general restrictions be replaced with clear rules for identifying, declaring and managing concrete cases of conflict of interest, without undermining the independence, impartiality, confidentiality and integrity of the audit activity.

Despite the constructive character of the request and the expressed readiness for institutional cooperation, the Supreme Audit Institution did not reply to the Association, and no attempt to reformulate and interpret these restrictive provisions has been found up to the moment the subsequent request was prepared.

The Association considers that a matter which relates directly to the exercise of the fundamental rights and freedoms of employees merits institutional examination, legal reasoning and an official reply.

In the absence of a reply and of efforts to reformulate and interpret these restrictive provisions by KLSH, the Association of External Public Auditors, on 18.10.2026, addressed the Commissioner for Protection from Discrimination (KMD) and the People's Advocate (AP), requesting the intervention of these institutions, within their legal competences:

• Examination of the restrictions provided for in the Internal Regulation and the Code of Ethics of KLSH, in order to assess whether they constitute unjustified or discriminatory treatment of employees who wish to become members of professional associations and non-profit organisations.
• Assessment of the compatibility of the relevant provisions with the Constitution of the Republic of Albania, the legislation in force and international standards on freedom of association.
• Requesting information and documentation from KLSH, in order to clarify the legal basis and the reasoning on which the restrictions on professional membership rest.
• Examination of the lack of an institutional reply, of the initiative to reformulate and interpret these restrictive provisions by KLSH, and of the reasons for not communicating an official position.
• Taking measures and issuing the relevant recommendations, should unjustified restrictions or legal problems be found, for the amendment, repeal or reformulation of the restrictive provisions.

In its reasoning, the Association also referred to Article 11 of the European Convention on Human Rights, as well as to the precedent of the institutional treatment of the matter of the trade-union right of organisation of the employees of the Republican Guard.

We consider that institutional dialogue, transparency and respect for constitutional rights must be guiding principles in relations between public institutions and professional organisations.

For this reason, we have addressed the Commissioner for Protection from Discrimination and the People's Advocate, confident that the matter will be subject to a full, objective and impartial examination.