Last update October 25, 2025
Romania’s E‑Compliance Mandates: E‑Invoicing, E‑Reporting & E‑Transport
SUMMARY
Executive Summary:
Romania has implemented a comprehensive suite of electronic compliance measures – RO e-Factura, e-reporting, RO e-Transport, and RO e-TVA – to combat VAT fraud, improve tax compliance, and streamline tax administration. These mandates impact all businesses operating in Romania, including foreign entities. The timeline for implementation has been phased, with increasing scope and stricter penalties for non-compliance.
1. Electronic Invoicing (RO e-Factura)
- Purpose: Mandatory electronic invoicing system designed to digitize tax compliance and combat VAT fraud. The Ministry of Finance believes this “eliminates the possibility of using false or duplicate invoices”.
- Scope & Timeline:B2G (Business-to-Government): Mandatory since July 1, 2022.
- High-Risk B2B Goods: Mandatory from July 2022 (vegetables, fruits, alcoholic beverages, construction materials, mineral products, and clothing/footwear).
- All B2B Transactions: Mandatory from July 1, 2024. This applies to “all invoices between Romanian taxable persons (companies or PFA)” including “all Romanian-established businesses even if not VAT-registered, as well as non-established businesses registered for Romanian VAT.”
- B2C Transactions: Mandatory from January 1, 2025, excluding simplified invoices (e.g., fiscal cash register receipts).
- Cross-border transactions not taking place in Romania (exports, intra-Community supplies) are out of scope.
- Data & Format Requirements:Structured electronic format (XML) conforming to the Romanian CIUS of the European e-invoicing standard (EN 16931), known as “RO_CIUS”.
- Transmission via the RO e-Factura portal (ANAF’s system), requiring a valid digital certificate and enrollment in Virtual Private Space (SPV) on the ANAF portal for authentication.
- Clearance Process: The tax authority’s system checks the submitted XML. If compliant, the Ministry of Finance applies its digital signature, making it available to the buyer. “The validated e-invoice is then made available to the buyer in the system (the buyer must retrieve it from the portal or via API). This clearance model ensures the tax authority has the data in real-time and the invoice is considered issued only after approval.”
- Deadline: The invoice XML must be sent to the RO e-Factura platform within 5 calendar days of the invoice date.
- Penalties:A grace period existed until May 31, 2024.
- Late Reporting Fines (from June 2024):
- Large taxpayers: RON 5,000 to 10,000 per offense.
- Medium-sized taxpayers: RON 2,500 to 5,000.
- Small legal entities and individuals: RON 1,000 to 2,500.
- Issuing B2B invoices outside the RO e-Factura system: 15% of the invoice’s value.
- Recipients are also obliged to ensure the invoices they receive from Romanian suppliers went through the e-Factura system.
- Late Reporting Fines (from June 2024):
2. Electronic Reporting (Near Real-Time Invoice Reporting)
- Purpose: A precursor and complement to full e-invoicing, requiring invoice data to be reported to tax authorities shortly after issuance.
- Scope:January–June 2024: Applied to all invoices for domestic transactions between taxable persons, including VAT-registered and non-VAT-registered businesses.
- Foreign businesses with a Romanian VAT number also had to report invoices for taxable supplies in Romania.
- Exports and intra-Community supplies were excluded.
- B2C invoices will be included from January 1, 2025.
- Obligation & Process:Businesses had to submit an electronic copy of each invoice within 5 calendar days of the taxable event/invoice issuance.
- The data format was an invoice XML (RO_CIUS format).
- The RO e-Factura portal was the point of submission.
- E-reporting did not require transaction clearance.
- Penalties: Same as e-invoicing penalties, particularly for late or missing reports (June 2024 onwards).
3. Electronic Transport System (RO e-Transport)
- Purpose: An electronic platform for monitoring the road transport of goods, especially those with high tax risk, to reduce evasion in commodity trading.
- Scope:Initially focused on domestic and intra-Community transport of “high fiscal risk” goods (vegetables, fruits, alcoholic beverages, construction materials, mineral products, clothing/footwear, meat, fish, dairy products, and tobacco).
- Expanded in 2024 to cover virtually all significant cross-border shipments (imports, exports, and intra-EU acquisitions and dispatches).
- Implementation Timeline:Operational by July 1, 2022, with reporting mandatory but sanctions delayed until October 1, 2022.
- Enforcement from October 1, 2022.
- Expanded obligations effective January 1, 2024, with penalties for non-compliance applied from July 1, 2024.
- Data and Reporting Process:Registration & access via ANAF’s Virtual Private Space.
- Required information: sender and receiver details, description of goods (TARIC codes), pickup and delivery addresses, expected date of transport, transport vehicle details.
- Unique Identification Code (UIT/ITU) is generated and must accompany the goods.
- UIT code is valid for 5 calendar days from the declared start date of transport.
- Penalties:Fines: RON 20,000 up to RON 100,000 for companies; RON 10,000 to RON 50,000 for individuals.
- Confiscation of undeclared goods.
4. Pre-Filled VAT Returns (RO e-TVA)
- Purpose: To introduce pre-filled VAT returns using data collected from e-invoicing and e-reporting systems, aiming to reduce compliance burden and highlight discrepancies.
- Timeline:New regime from January 1, 2025.
- For taxpayers on the VAT cash accounting scheme, the system will apply from August 1, 2025, onward.
- How it Works:The Ministry of Finance will generate a draft VAT return for every VAT-registered taxpayer by the 5th day of the month following the deadline for the normal VAT return submission.
- Data consolidated from: RO e-Factura, RO e-Transport, SAF-T submissions, cash register data, customs data, etc.
- If discrepancies exceed 20% and RON 5,000, the system will issue a “RO e-TVA compliance notice,” requiring the taxpayer to respond within 20 days.
- Penalties: Failing to respond to a compliance notice can result in fines (RON 5,000–10,000 for large taxpayers, 2,500–5,000 for medium, 1,000–2,500 for others).
Key Takeaways:
- Romania is aggressively digitizing its tax compliance system.
- Mandatory e-invoicing is being rolled out in phases, with B2B transactions fully mandated from July 2024 and B2C from January 2025.
- E-reporting ensured that all transactions were captured even before full e-invoicing.
- RO e-Transport covers a wide range of goods, especially for cross-border shipments.
- Pre-filled VAT returns (RO e-TVA) are coming into effect from January 2025.
- Penalties for non-compliance are significant, including fines and potential confiscation of goods.
Recommendations:
- Businesses operating in Romania should ensure they are compliant with all e-compliance regulations, including e-Factura, e-Transport, and e-TVA.
- Companies should integrate their IT systems with the RO e-Factura portal and RO e-Transport system to automate data transmission and avoid penalties.
- Taxpayers should carefully review the pre-filled VAT returns (RO e-TVA) and respond to any compliance notices promptly.
1. Electronic Invoicing (RO e-Factura)
- B2G (Business-to-Government): Since July 1, 2022, it has been mandatory for all suppliers issuing invoices to public authorities to use RO e-Factura for those invoices. This early phase implemented EU Directive 2014/55/EU in Romanian law and established the e-Factura platform for public procurement invoices. [unifiedpostgroup.com]
- High-Risk B2B Goods: Also starting July 2022, Romania mandated e-invoicing in the B2B sector but limited to specific high fiscal risk products prone to VAT fraud (defined by Ministry of Finance). These categories included vegetables, fruits, alcoholic beverages, construction materials, mineral products, and clothing/footwear. Any company selling such goods domestically had to issue the invoice through RO e-Factura, regardless of whether the buyer was enrolled on the platform. [unifiedpostgroup.com], [ec.europa.eu] [unifiedpostgroup.com]
- All B2B Transactions: Armed with EU authorization in 2023, Romania expanded the mandate to all domestic B2B sales (taxable supplies where both supplier and customer are established in Romania). From July 1, 2024, all invoices between Romanian taxable persons (companies or PFA) must be electronic and transmitted via the national system. This includes B2B services and goods of any type (not just high-risk goods). Notably, the rule covers all Romanian-established businesses even if not VAT-registered, as well as non-established businesses registered for Romanian VAT. (In practice, non-resident VAT-registered companies that issue invoices for Romanian transactions must report them too – if they cannot issue via RO e-Factura, they continue using the e-reporting channel.) [unifiedpostgroup.com], [marosavat.com] [ec.europa.eu], [ec.europa.eu] [marosavat.com]
- B2C Transactions: From January 1, 2025, the e-invoicing/reporting obligation extends to business-to-consumer invoices as well. Any invoice issued by a business to a final consumer (individual) for a domestic sale must be transmitted to the RO e-Factura system. Exceptions: Simplified invoices (such as those printed from fiscal cash registers for retail sales) are excluded and remain outside the e-Factura mandate. Also, certain small entities (nonprofit organizations, foundations, and farmers under special VAT schemes) have a deferred compliance deadline until July 1, 2025, though they may opt in earlier. Cross-border transactions not taking place in Romania (exports, intra-Community supplies) are out of scope of the domestic e-invoicing mandate. [unifiedpostgroup.com], [theinvoicinghub.com] [ec.europa.eu], [theinvoicinghub.com] [unifiedpostgroup.com], [marosavat.com]
- Romania adopts the EU standard EN 16931 for invoice data, using a national Core Invoice Usage Specification “RO_CIUS” as the required format. In practice, this is an XML format containing all mandatory invoice information (seller and buyer details, tax identification, invoice number/date, line items, taxable amounts, VAT breakdowns, etc.) aligned with EU standards. [unifiedpostgroup.com], [marosavat.com]
- Transmission: Invoices are transmitted through the RO e-Factura portal (ANAF’s system). Businesses can connect via API or manually upload invoices (the system provides a web interface). Use of a valid digital certificate and enrollment in Virtual Private Space (SPV) on the ANAF portal is required for authentication. [unifiedpostgroup.com]
- Clearance process: The submitted XML is checked by the tax authority’s system for correctness and completeness. If the invoice conforms to the schema and business rules, the Ministry of Finance applies its digital signature to the invoice, effectively clearing it. The validated e-invoice is then made available to the buyer in the system (the buyer must retrieve it from the portal or via API). This clearance model ensures the tax authority has the data in real-time and the invoice is considered issued only after approval. [unifiedpostgroup.com], [marosavat.com] [marosavat.com]
- Reporting vs. Invoicing: During the transition (H1 2024), if a supplier opted not to issue a full e-invoice through the system (e.g. continued using paper/PDF), they still had to send the invoice data to RO e-Factura for e-reporting purposes. In practice, the process was the same (uploading an XML of the invoice), except the buyer might not have been registered to receive it electronically. As of July 2024, however, issuing through the platform is mandatory for B2B, effectively merging the reporting and invoicing into one step. [marosavat.com], [marosavat.com]
- Under the e-reporting phase, all invoices had to be reported within 5 days of issuance. Recent guidance clarified this as 5 calendar days from the invoice date. (The law also stipulates it must be no later than 5 days from the legal latest date of issuance, to cover cases where an invoice could be issued days after the taxable event.) [unifiedpostgroup.com], [marosavat.com] [theinvoicinghub.com] [ec.europa.eu]
- This 5-day rule remains in effect for the e-invoicing mandate: even when fully electronic, the invoice XML must be sent to the platform within 5 days of creating the invoice. The system is effectively near-real-time, though not necessarily instantaneous at point of sale. (By comparison, Italy’s clearance requires immediate sending; Romania allows a short buffer, similar to Spain’s SII system.) [ec.europa.eu], [theinvoicinghub.com]
- Public sector (B2G) invoices likely follow their procurement contract terms, but they too are transmitted via RO e-Factura and thus would adhere to the same structural format; since B2G was mandatory earlier, most public-sector suppliers are already integrated.
- Grace Period: From January 1 to May 31, 2024, authorities did not impose fines for late or missing invoice submissions, giving businesses time to adapt. This grace period was originally until March 31 and then extended to end of May 2024. [unifiedpostgroup.com], [marosavat.com]
- Late Reporting Fines: Beginning June 2024, failure to report or transmit an invoice on time triggers fines. These are scaled by taxpayer size (per criteria set by ANAF):
- Large taxpayers: RON 5,000 to 10,000 per offense. [marosavat.com]
- Medium-sized taxpayers: RON 2,500 to 5,000. [marosavat.com]
- Small legal entities and individuals: RON 1,000 to 2,500. These fines apply, for example, if a company issues an invoice but does not upload it to the e-Factura system within 5 days. [marosavat.com]
- Issuing Invoices Outside the System: Once e-invoicing is compulsory (B2B as of July 2024), issuing a B2B invoice outside the RO e-Factura system is a serious violation. The law provides for a penalty of 15% of the invoice’s value if a supplier bypasses the electronic system entirely. In other words, a paper invoice issued in a situation where e-invoicing is required could cost the issuer (and the recipient) 15% of the transaction value as a fine. This steep sanction underlines that from H2 2024 onward, the only valid way to invoice domestic B2B transactions is via the central platform. [ec.europa.eu], [marosavat.com]
- Additional Consequences: Starting July 2024, recipients are also obliged to ensure the invoices they receive from Romanian suppliers went through the e-Factura system. Accepting an invoice that should have been electronic can implicate the buyer as well (though the primary 15% fine targets the issuer). All companies had to prepare their IT systems to integrate with RO e-Factura by this date to avoid business disruptions. [ec.europa.eu]
2. Electronic Reporting (Near Real-Time Invoice Reporting)
- All B2B invoices (sales between two companies or traders in Romania) fell under e-reporting from Jan 1, 2024. This included invoices issued by VAT-registered and non-VAT-registered businesses alike, as long as a Romanian established entity was involved. [marosavat.com], [marosavat.com] [marosavat.com], [ec.europa.eu]
- Foreign businesses with a Romanian VAT number also had to report any invoices for taxable supplies in Romania. [marosavat.com]
- The e-reporting requirement explicitly excluded international outbound transactions – export sales and intra-Community supplies did not need to be reported in RO e-Factura, since those are out of Romanian VAT scope. [unifiedpostgroup.com], [marosavat.com]
- B2G invoices were already being sent via e-Factura (since 2022), so they were inherently reported; the e-reporting mandate mainly covered B2B invoices that were not yet mandated to be electronic in early 2024.
- B2C invoices were initially not in scope for 2024, but from January 2025 e-reporting extends to B2C as part of the final phase (often termed “B2C e-reporting”). Indeed, as of 2025, all invoices issued to consumers by Romanian firms must be submitted to the system as well, effectively meaning no gap in reporting for any invoice type. [unifiedpostgroup.com], [marosavat.com]
- Businesses had to submit an electronic copy of each invoice they issued (if not already issued on the platform) within 5 working days of the taxable event/invoice issuance. (Some sources say 5 calendar days; the government ultimately clarified 5 calendar days for B2C, which implies the same for B2B.) This short deadline mirrors systems like Hungary’s RTIR or Spain’s SII, aiming for near real-time data capture. [unifiedpostgroup.com], [marosavat.com] [theinvoicinghub.com]
- The data format for reporting was essentially an invoice XML (RO_CIUS format) containing the invoice details. Many companies chose to just issue their invoices through RO e-Factura voluntarily even before it was fully mandatory, which simultaneously fulfilled the e-reporting requirement. Others uploaded invoice data files purely for reporting (without delivering the e-invoice to the customer through the system). [marosavat.com], [marosavat.com]
- The RO e-Factura portal was the single point of submission – there is no separate “e-reporting” portal. So, from a user perspective, reporting an invoice or issuing an e-invoice were very similar processes, both done via e-Factura. The key difference was whether the buyer was also using the system. If the buyer wasn’t on the platform (common in early 2024 for B2B, or for B2C consumers), the seller still had to report the invoice to ANAF, but also had to deliver a paper/email copy to the buyer outside the system. [unifiedpostgroup.com]
- Notably, e-reporting did not require transaction clearance. The tax authority didn’t need to approve or reject the invoice for it to be valid; it simply had to be reported. (With full e-invoicing from July 2024, clearance became part of issuance.)
- No fines were levied in the first five months of 2024 for failing to report within 5 days. Compliance was encouraged but not enforced with penalties until June 1. [unifiedpostgroup.com]
- From June 2024, late or missing reports incur fines: RON 1k–2.5k (small), 2.5k–5k (medium), 5k–10k (large taxpayers). Each invoice not reported in time could be a separate offense. [marosavat.com]
- These penalties essentially cover the scenario of not sending the data in time. By July 2024, once all B2B had to be actually invoiced through the system, the focus shifts to the 15% value-based fine for non-use of the system (which implies a failure to report at all).
- For B2C e-reporting from 2025, similar penalties would apply if those invoices are not reported.
3. Electronic Transport System (RO e-Transport)
- Vegetables and fruit (e.g. perishable agricultural products),
- Alcoholic beverages,
- New construction materials (e.g. structural steel, concrete, etc.),
- Mineral products (like mineral raw materials),
- Clothing and footwear (textile products), [ec.europa.eu]
- (Later expanded) Meat, fish, dairy products, and tobacco (added to the list in 2024). [assets.kpmg.com], [assets.kpmg.com]
- Launch in 2022: The e-Transport system became operational by July 1, 2022, when the reporting of high-risk goods transports became mandatory. However, recognizing the novelty, authorities delayed enforcement of sanctions. Government Ordinance 106/2022 stipulated that penalties would apply only from October 1, 2022. This gave companies a three-month window to familiarize themselves with the system. [pwc.ro] [pwc.ro], [pwc.ro]
- Enforcement from Oct 2022: As of Oct 1, 2022, transporting high-risk goods without a declaration in e-Transport could result in steep fines and confiscations (detailed below). This effectively made compliance compulsory from that date. [pwc.ro]
- System Requirements: By early 2023, the full procedure was in place (joint Order ANAF/Customs 1190/4625/2022 detailed how to use the system). [pwc.ro]
- Expansion in 2024: Through Emergency Ordinance 115/2023 (published Dec 15, 2023), Romania expanded e-Transport to cover virtually all significant cross-border shipments effective Jan 1, 2024. In addition to high-risk goods, all imports and exports of goods, and all intra-EU acquisitions and dispatches, now require an e-Transport declaration. In practice, this means: [assets.kpmg.com], [assets.kpmg.com] [assets.kpmg.com]
- For an import into Romania, the importer named on the customs declaration must register the transport in e-Transport. [assets.kpmg.com]
- For an intra-Community acquisition (goods arriving from another EU country), the Romanian buyer/recipient must report the shipment. [assets.kpmg.com]
- For an export from Romania, the exporter must report it. [assets.kpmg.com]
- For an intra-Community supply (goods sent to an EU customer), the Romanian supplier must initiate the e-Transport declaration. [assets.kpmg.com]
- Goods in transit through Romania that get stored or split into new shipments on Romanian territory also trigger obligations for the warehouse operator. [assets.kpmg.com]
Essentially, e-Transport moved from a niche mechanism for certain goods to a broad logistics reporting system for most trade flows, making Romania one of the more advanced in the EU in terms of transport traceability.
- Enforcement of new rules: The expanded obligations took effect Jan 2024, but penalties for non-compliance with the newly added categories apply from July 1, 2024. (Authorities encouraged voluntary compliance from Jan to June 2024 even for the new scope, to test the system without fines.) [assets.kpmg.com]
- Additional updates: From March 1, 2024, the list of high-risk goods was widened (adding meats, fish, dairy, and more tobacco products), meaning those product types now also trigger e-Transport if transported. This was part of the same ordinance to strengthen controls on a broader range of goods. [assets.kpmg.com], [assets.kpmg.com]
- Registration & Access: Companies use the online portal (accessible via ANAF’s Virtual Private Space) to interact with RO e-Transport. The system is integrated with tax and customs IT systems. [pwc.ro] [ec.europa.eu], [ec.europa.eu]
- Required Information: When declaring a transport, the user must input key details about the shipment, including:
- Who: Identity of the sender and receiver (names, tax IDs). For intra-EU, it’s the Romanian party (importer/buyer or exporter/seller) who declares and includes info about the foreign counterparty.
- What: Description of goods, usually via commodity codes (TARIC codes) and quantities/weights, plus the value of goods. The inclusion of TARIC (customs) codes is crucial to determine if goods are high-risk and to integrate with customs data. [fiscal-req…ements.com], [assets.kpmg.com]
- Where/Route: The pickup and delivery addresses (or border crossing points) and if applicable, any interim storage in Romania.
- When: The expected date of transport commencement. The system allows declaration up to 3 days before the start of the transport. [ec.europa.eu]
- How: Details of the transport vehicle and operator. The law even envisions requiring GPS tracking devices on transport vehicles for real-time monitoring (Romania signaled intent to mandate GPS units transmitting location for trucks carrying reported goods). [assets.kpmg.com]
- Unique Code (UIT/ITU): Once the data is submitted, the system generates a Unique Identification Code for that transport. (This code is sometimes abbreviated UIT or ITU in texts.) The UIT code must accompany the goods – it needs to be included on the transport documents (CMR or delivery note), either printed or electronically, so that authorities can verify it during transit. [fiscal-req…ements.com] [fiscal-req…ements.com], [fiscal-req…ements.com]
- Validity: The UIT code is valid for a limited window. By law it is valid for 5 calendar days from the declared start date of transport. This provides some leeway if there are minor delays or if the transport starts a bit later than planned, but if the transport doesn’t occur in that window, a new declaration would be needed. [fiscal-req…ements.com]
- Obligations: The shipper must ensure the driver/carrier has the UIT code before the truck is on the road. It is forbidden to transport the specified goods in Romania without a UIT code or with an expired code. Also, once the transport is underway (or the goods have entered Romania for imports), no alterations to the declared data are allowed – the info must match what is carried. If plans change (e.g., route or quantity), the declaration should be updated before commencement. [fiscal-req…ements.com]
- Controls: The e-Transport data allows ANAF and Customs to perform targeted inspections. If a truck is stopped and carrying goods that should have a UIT code, officers will check the code and match it against the cargo. The system’s integration means they have the declared info available.
- Fines: Transporting high-risk goods without a declaration (or other breaches like providing incorrect data or using an invalid code) can lead to fines of RON 20,000 up to RON 100,000 for companies (legal entities). For individuals (which could include sole traders), fines range from RON 10,000 to RON 50,000. Each undeclared transport is an offense. Starting July 2024, these fines also apply to unreported imports/exports and other newly in-scope transports. [fiscal-req…ements.com], [pwc.ro] [fiscal-req…ements.com]
- Confiscation of goods: In addition to monetary fines, the law provides that the undeclared goods may be confiscated by authorities. The valuation for confiscation is based on the invoice of the goods or market value if invoice value is not known. This is a severe consequence – essentially, failing to declare can mean losing the entire shipment’s value, a strong incentive to comply. [fiscal-req…ements.com], [pwc.ro] [pwc.ro]
- Forbidden transports: It is explicitly illegal to carry high-risk goods in Romania without a UIT code present. Also forbidden is the use of a UIT code beyond its validity period (beyond 5 days), and the unloading of goods in Romania that were declared as transit without proper declaration. These acts are treated as contraventions subject to the above fines and sanctions. [fiscal-req…ements.com]
- Enforcement: Since Oct 2022, Romanian fiscal authorities (ANAF’s Anti-Fraud unit and Customs) have been monitoring compliance. With the new all-goods scope in 2024, enforcement likely intensified at borders and on highways. From July 2024, any non-declaration for imports/exports can also be penalized, but Jan–June 2024 for those had an unofficial grace (though OUG 115/2023 didn’t formalize a grace, it simply set penalty applicability from July).
4. Pre-Filled VAT Returns (RO e-TVA)
- Current Situation: Until 2024, Romanian VAT returns (Form D300) were prepared and filed entirely by taxpayers, with no pre-population by ANAF. Taxpayers themselves had to aggregate sales and purchase data, even though some data (e.g., from e-invoices or SAF-T) was available to the tax authority. No pre-filled VAT return was in use up to that point.
- New Regime from 2025: Legislation passed in 2024 (via Emergency Ordinance 70/2024 and amended by 87/2024) creates a system for RO e-TVA – a pre-completed VAT return. Starting January 1, 2025, for each monthly/quarterly VAT period, the Ministry of Finance will generate a draft VAT return for every VAT-registered taxpayer. [ec.europa.eu], [pwc.ro]
- How it Works: By law, the pre-filled VAT return must be made available by the 5th day of the month following the deadline for the normal VAT return submission. For example, if a taxpayer’s January 2025 VAT return is due by Feb 25, 2025, the authorities will send a draft of that return by around March 5, 2025. This RO e-TVA statement will consolidate data from: [ec.europa.eu], [pwc.ro]
- RO e-Factura (e-invoicing/e-reporting) – all sales invoices issued by the taxpayer and reported purchase invoices (if available),
- RO e-Transport – relevant info about goods movements (especially for cross-checking imports/exports),
- SAF-T (Standard Audit File – D406) submissions,
- Other filings like domestic sales/purchase listings (Form D394) and EU recapitulative statements (D390), plus any cash register (e-receipts) data, customs data, etc. basically all data in MOF/ANAF systems related to that taxpayer. [pwc.ro]
- The taxpayer will receive this draft and can compare it to their own records. If the taxpayer’s own VAT return (D300) that they submit matches the pre-filled data, presumably everything is in order. If there are discrepancies beyond a certain threshold (the law sets a difference of at least 20% and RON 5,000 as a significant discrepancy), the system will issue an “RO e-TVA compliance notice” to the taxpayer. The taxpayer then has 20 days to respond with explanations or corrections for the differences. [pwc.ro] [pwc.ro], [pwc.ro]
- Goal: This mechanism is intended to flag inconsistencies (e.g., a company’s VAT return claims less sales than what was reported via e-invoices, or more input tax than the purchases reported by suppliers). It’s a tool against fraud, and also a service to honest businesses to streamline reporting.
- Penalties: Failing to respond to a compliance notice (to explain or reconcile differences) can result in fines, again tiered by size: RON 5,000–10,000 for large taxpayers, 2,500–5,000 for medium, 1,000–2,500 for others. These are similar ranges to the e-invoicing fines, indicating consistent enforcement measures. Additionally, ignoring discrepancies could mark the taxpayer as a higher risk for VAT audits or withheld refunds. [pwc.ro]
- Timeline: The legal provisions for pre-filled returns come into force on January 1, 2025. For taxpayers on the VAT cash accounting scheme (who declare VAT upon cash receipt/payment), the system will apply from August 1, 2025 onward, acknowledging their different reporting cycle. The first pre-filled statements should be generated in early 2025 for the January 2025 period. [ec.europa.eu], [pwc.ro]
- Conclusion: Yes, Romania is introducing pre-filled VAT returns. This is a new development leveraging the e-invoicing and e-reporting data. While no pre-filled return was available prior, from 2025 the RO e-TVA pre-completed return will be part of the compliance process. Taxpayers will still file VAT returns, but they’ll have a draft from ANAF to aid or cross-check. In the long run, this could simplify compliance and reduce errors, as well as give the tax authority a stronger audit trail. The Romanian government’s digital strategy explicitly aims to reduce the filing burden on taxpayers by using collected data, and the e-TVA return is a key step in that direction. [mfinante.gov.ro], [mfinante.gov.ro]
- Unifiedpost Group – “Romania’s electronic invoicing and reporting revolution” (June 2024), detailing the new law and phased obligations. [unifiedpostgroup.com], [unifiedpostgroup.com]
- European Commission eInvoicing Factsheet 2024 – outlines Romania’s e-invoicing standard (RO_CIUS), legal mandates (Law 296/2023), and timelines for B2B/B2C, plus mentions the pre-filled e-VAT return introduction. [ec.europa.eu], [ec.europa.eu]
- Marosa VAT – “E-invoicing in Romania: Complete Guide” (Dec 2024 update), provides deep insights on stages (e-reporting phase, e-invoicing phase, B2C phase), scope of transactions (domestic vs international), and penalties. [marosavat.com], [marosavat.com]
- Romanian Ministry of Finance Press Release (27 July 2023) – announcing EU Council Decision 2023/1553 and the plan for mandatory B2B e-invoicing from 2024. [mfinante.gov.ro], [mfinante.gov.ro]
- PwC Romania Tax Alert (Jan 2023) – explains the RO e-Transport system implementation, categories of goods, and fines, referencing official orders and ordinances. [pwc.ro], [pwc.ro]
- KPMG Romania Newsflash (Jan 2024) – outlines the expanded e-Transport obligations under GEO 115/2023 (import/export, etc.) and enforcement timelines. [assets.kpmg.com], [assets.kpmg.com]
- The Invoicing Hub – update on B2C e-invoicing now mandatory from Jan 2025, confirming scope (all taxable persons, with some exemptions) and 5-day rule. [theinvoicinghub.com], [theinvoicinghub.com]
- PwC Romania Alert (July 2024) – “RO e-TVA pre-filled statement (GEO 70/2024 & 87/2024)”, describing the mechanism of pre-populated VAT returns and legal start dates. [pwc.ro], [pwc.ro]
- Official Gazette references via PwC/EU sources – e.g., OUG 41/2022 for e-Transport launch, Law 139/2022 and Order 1366/2021 for e-Factura format, etc., as cited above. [ec.europa.eu] [ec.europa.eu], [ec.europa.eu]
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