Briefing Document & Podcast: Romanian E‑Invoicing & E‑Reporting

Last update June 7, 2026

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Romania’s E‑Compliance Mandates: E‑Invoicing & E‑Reporting 

1. Executive Summary

Romania has embarked on an aggressive and comprehensive tax digitalization journey, primarily driven by the imperative to reduce one of the highest VAT gaps in the European Union (30% in 2023). This initiative has culminated in a multi-faceted digital tax control ecosystem encompassing mandatory e-invoicing (RO e-Factura), SAF-T reporting (D406), e-transport monitoring (RO e-Transport), and pre-filled VAT returns (RO e-TVA).

At its core, the RO e-Factura system operates a centralized clearance (CTC) model for B2B and B2G transactions, meaning invoices must be validated and digitally sealed by the government platform (ANAF) before gaining legal validity. For B2C, it functions as a post-issuance reporting model. This positions Romania as an early mover in the EU, significantly ahead of the EU’s ViDA (VAT in the Digital Age) timeline. The system is backed by a Council Implementing Decision (EU) 2023/1553, authorizing derogations from standard EU VAT Directive articles to enable mandatory electronic invoicing without recipient consent.

The rollout has been phased, with mandatory B2B e-invoicing for all domestic established taxable persons operational since January 2024 (reporting) and July 2024 (full clearance). Mandatory B2C e-invoicing followed from January 2025, and the scope expanded further in January 2026 to include individuals with CNP and certain non-established VAT-registered buyers. Penalties for non-compliance are substantial, including 15% of the invoice value for B2B transactions not processed via the platform. While initial compliance presents significant challenges, particularly for SMEs, the long-term goal is administrative modernization and a fairer business environment through enhanced fiscal control.

2. Introduction & Country Context

Romania’s tax digitalization journey is characterized by its ambition and accelerated pace over the last five years. This push is primarily fueled by the country’s persistent VAT gap, which stood at 30% in 2023, a figure the National Recovery and Resilience Plan (NRRP) aims to reduce by 5 percentage points by 2026.

The foundation of this system is the RO e-Factura platform, established by Government Emergency Ordinance (OUG) No. 120/2021. This legislation provided the framework for a staged rollout:

• November 2021: Voluntary B2G and B2B use.
• July 2022: Mandatory B2G e-invoicing; B2B mandatory for high fiscal risk products (e.g., vegetables, alcohol, construction).
• January 2024: Mandatory B2B e-invoicing for all domestic transactions between established taxable persons (reporting phase).
• July 2024: Full B2B e-invoicing clearance model operational, meaning invoices must be cleared via the platform before being legally valid. Paper and PDF invoices are no longer legally valid for in-scope B2B transactions.
• January 2025: Mandatory B2C e-invoicing via RO e-Factura.
• January 2026: Scope expanded to individuals with CNP, non-established VAT-registered buyers, and a unified transmission deadline of 5 working days.

In parallel, Romania implemented other key digital tax measures:

• SAF-T (D406) mandatory reporting: Phased from January 2022 for large taxpayers.
• RO e-Transport: For monitoring road transport of high fiscal risk goods.
• RO e-TVA: Pre-filled VAT returns, launched August 2024.

3. Rationale Behind the Mandate

The primary objectives driving Romania’s e-invoicing and e-reporting mandates are:

• VAT Gap Reduction: Romania’s historically high VAT gap (35.7% in 2020, 30% in 2023) is the foremost motivator. The NRRP commits Romania to a 5-percentage-point reduction by 2026, targeting around 29%.
• Fraud Prevention: The centralized clearance model enables “real-time transaction-level monitoring [that] enables immediate identification and disruption of VAT fraud chains.”
• Administrative Modernization: Digitalization aims to “reduce the administrative burden on both taxpayers and the tax administration, improves competitiveness, and lowers costs.”
• Alignment with EU Trends: The mandate aligns with the EU’s ViDA (VAT in the Digital Age) trajectory and the broader European push toward Continuous Transaction Controls (CTC).

As ANAF President Adrian Nica stated, “Our strategy is to move the fight against tax evasion into the digital area… Digitalization eliminates unfair competition and protects the honest business environment.”

Romania is notable for being an early adopter of a mandatory centralized clearance CTC model, similar to Italy, and is positioned ahead of many other EU countries and the EU ViDA timeline. The country’s approach is consistent with the OECD CTC model, forming one of Europe’s most comprehensive digital tax control ecosystems.

To implement its ambitious CTC model, Romania secured a Council Implementing Decision (EU) 2023/1553 on July 25, 2023, granting a derogation from Articles 218 and 232 of the VAT Directive 2006/112/EC. This allows Romania to:

• “Accept only invoices issued by taxable persons established in Romania in electronic format” (derogation from Art. 218).
• “Provide that the use of electronic invoices is not subject to acceptance by the recipient” (derogation from Art. 232). This derogation is valid from January 1, 2024, until December 31, 2026, or the date ViDA amendments apply.

4. Scope of the Mandate

4.1. Transactions In-Scope

• Domestic B2B: Mandatory since January 1, 2024 (reporting) and July 1, 2024 (full clearance). “All domestic B2B transactions with a place of supply in Romania between established taxable persons…must be issued and received through RO e-Factura.” Paper and PDF invoices are no longer legally valid for these transactions.
• Domestic B2G: Mandatory since July 1, 2022, for all suppliers to public authorities. Payment is contingent on e-Factura submission.
• Domestic B2C: Mandatory since January 1, 2025, for all regular B2C invoices. Suppliers must transmit invoices through RO e-Factura in XML RO_CIUS format within 5 working days. Exemptions apply for point-of-sale fiscal cash register receipts.
• Invoices to Non-Established VAT-Registered Buyers: From January 1, 2026, invoices issued by Romanian taxable persons to non-established VAT-registered buyers (without a fixed establishment in Romania) must also be transmitted through RO e-Factura as an e-reporting obligation. The supplier must still deliver the invoice via traditional methods to the buyer.
• Self-billing: In-scope and must be processed through RO e-Factura.

4.2. Transactions Excluded

• Cross-border B2B: Intra-Community supplies of goods and services where a foreign VAT number is communicated, and exports of goods, are explicitly excluded.
• Intra-Community Acquisitions: Invoices received from foreign suppliers are not in scope.
• Supplies to non-VAT-registered non-established entities: Excluded.
• Simplified invoices: Those issued via electronic fiscal cash registers that qualify as simplified invoices are excluded from the e-Factura mandate.

4.3. Taxable Persons In-Scope

• Established Domestic Entities: All taxable persons established in Romania (registered office or fixed establishment), regardless of VAT registration status, are subject to the obligation for in-scope B2B, B2C, and B2G transactions.
• Individuals with CNP: From January 1, 2026, individuals carrying out economic activities (e.g., photographers, influencers) must register and submit invoices via RO e-Factura.
• Foreign Entities with Fixed Establishment: Mandatory, treated as established.
• Foreign Entities VAT-Registered but without Fixed Establishment: Romanian suppliers issuing invoices to these buyers must transmit via RO e-Factura from January 2026 (e-reporting obligation).

4.4. Sector-Specific Rules & Exemptions

• High Fiscal Risk Sectors: Mandatory e-invoicing from July 2022 (e.g., specific food products, construction, clothing).
• SMEs with Annual Turnover below EUR 500,000: Full enforcement is deferred until July 1, 2026. This is a deferral of penalty enforcement, not an opt-out.

5. Implementation Timeline

Romania’s e-invoicing framework has seen a rapid, phased rollout with several key milestones and transitional provisions:

• Sept 2020: Law 199/2020 transposes EU Directive 2014/55/EU (B2G e-invoicing).
• Oct 2021: OUG 120/2021 establishes RO e-Factura system.
• Nov 2021: RO e-Factura launched for voluntary B2G and B2B use.
• Jan 2022: Romania submits derogation request to European Commission.
• July 1, 2022: B2G mandatory; B2B mandatory for high fiscal risk goods.
• July 25, 2023: EU Council Implementing Decision (EU) 2023/1553 granted, authorizing derogations.
• Jan 1, 2024: Mandatory B2B e-reporting for all domestic transactions (all established taxable persons).
• Grace Period: Jan 1 – May 31, 2024, for B2B e-reporting non-compliance.
• July 1, 2024: Full B2B e-invoicing clearance mandatory. Paper/PDF invoices no longer legally valid for in-scope B2B.
• Aug 2024: RO e-TVA pre-filled VAT returns system launched.
• Jan 1, 2025: Mandatory B2C e-invoicing. SAF-T (D406) mandatory for all remaining VAT-registered taxpayers.
• Grace Period: July 2024 – Mar 31, 2025, for B2C e-invoicing penalties.
• July 1, 2025: B2C compliance for associations/foundations/special-regime farmers.
• Jan 1, 2026: Scope expansion (non-established VAT-registered buyers, CNP individuals). Unified 5-working-day transmission deadline applies.
• July 1, 2026: Full enforcement for SMEs with turnover < EUR 500,000.

6. How E-Invoicing & E-Reporting Really Work — The Operating Model

Romania employs a Centralized Clearance (CTC) model for B2B and B2G transactions, and a post-issuance reporting model for B2C. The tax authority, ANAF, plays a central role in validating, sealing, and delivering invoices.

6.1. Step-by-Step Invoice Lifecycle

1. Invoice Creation: The seller generates an e-invoice in XML format compliant with the RO_CIUS specification (a national customization of UBL 2.1 or CII, EN 16931-compliant).
2. Submission: The XML invoice is transmitted to the RO e-Factura platform via ANAF’s Virtual Private Space (SPV) portal, API, or web interface.
3. Validation: ANAF performs schema validation, over 50 business rule checks, and calculation verification against the CIUS_RO schematron rules. Rejected invoices must be corrected and resubmitted within the deadline.
4. Clearance / Acceptance: Upon successful validation, ANAF applies a Ministry of Finance digital seal (MFP seal), an upload index number, and a timestamp. The sealed XML becomes the legally valid original invoice.
5. Delivery to Buyer: The validated and sealed invoice is made available for the buyer to download from the SPV platform. For B2B, this is the legally valid document. For non-established VAT-registered buyers (from Jan 2026), the supplier must also deliver the invoice via traditional methods.
6. Retrieval by Buyer: Buyers retrieve invoices from SPV via API or web portal.
7. Archiving: Both parties must archive the XML invoice with the MFP seal for a minimum of 10 years (25 years for capital goods).

6.2. Authentication & Access

• Access to the SPV and invoice transmission requires a qualified electronic signature / digital certificate.
• API access uses OAuth 2.0 authorization.
• Third-party service providers and accountants can be authorized to act on behalf of taxpayers.

6.3. Offline / Contingency Mode

ANAF has not published detailed offline procedures. In case of platform unavailability, deadline extensions correspond to the technical interruption duration. There is no formal “offline mode” with QR codes.

6.4. Buyer-Side Workflow

Buyers must retrieve invoices from the SPV. Buyer acceptance is NOT required for the invoice to be legally valid (due to the EU derogation). Crucially, “buyers receiving and recording an invoice outside the RO e-Factura system face a 15% penalty of the invoice value in B2B transactions.”

6.5. QR Code or Verification Code

Romania’s framework does not require QR codes on e-invoices; the MFP digital seal ensures legal validity.

7. Acceptable E-Invoice Formats

The legally required format is XML compliant with the RO_CIUS (Core Invoice Usage Specification — Romania). This is a national customization based on:

• UBL 2.1 (Invoice-2 and CreditNote-2 schemas), or
• UN/CEFACT CII syntax. Both are aligned with the EN 16931 European e-invoicing standard. The RO_CIUS specifies over 100 data fields with strict ANAF validation rules.

8. Technical & Functional Requirements

8.1. E-Invoice Specifications

• Mandatory Data Fields: Include validated seller/buyer CUI/CIF, legal name, full address (including county code), VAT breakdown (with new 21% standard from Aug 2025), line items, and payment information.
• Data Validation Rules: Strict schema validation against CIUS-RO XSD, 50+ business rules via schematron, CUI/CIF checksum validation, VAT calculation checks, and duplicate invoice number detection.

8.2. E-Reporting Specifications (SAF-T / D406)

Romania mandates SAF-T reporting via Form D406, based on the OECD SAF-T v2.0 schema.

• Components: D406 General (monthly/quarterly), D406 Assets (annually), D406 Inventory/Banking/Insurance (on request).
• Filing Deadline: Last calendar day of the month following the reporting period.
• Full SAF-T Rollout: Phased through 2026, starting with large taxpayers (Q1 2026), medium (Q2 2026), small/micro (Q3 2026), and public institutions (Q4 2026).

8.3. Digital Signature & Integrity

The taxpayer is not required to digitally sign each invoice; the MFP digital seal applied by ANAF guarantees integrity and authenticity. SAF-T submissions, however, require a qualified electronic signature on the attached PDF form.

8.4. Real-Time or Near-Real-Time Processing

The system operates as a near-real-time clearance model for B2B/B2G transactions. B2C is post-issuance reporting within 5 working days.

9. Correction of Errors

9.1. E-Invoice Corrections

ANAF guidance (Dec 2024) clarifies:

• Reversal (storno) invoice: Used for full or partial corrections of previous errors, using code 380 with negative values. It must reference the original invoice.
• Credit note: Uses code 381, having the same legal status as an invoice with a negative sign, used for adjustments. All corrective documents must be submitted through RO e-Factura.

9.2. E-Reporting Corrections

• SAF-T: Rejected D406 files must be resubmitted within 5 days.
• e-TVA: Amended VAT returns (D300) can be submitted. Discrepancies exceeding 20% or RON 5,000 between the pre-filled and submitted returns trigger a compliance notice, requiring a response within 20 days.

10. Transmission & Workflow

The central platform is RO e-Factura, operated by ANAF under the Ministry of Finance.

• Transmission Channels: Government API, free SPV web portal, third-party service providers, and ERP integration.
• Peppol: Not supported. Romania does not currently use the Peppol network for RO e-Factura transmission.
• Deadlines: 5 working days from invoice issue date for B2B and B2C. SAF-T is monthly/quarterly.

11. Self-Billing

Self-billing is permitted and supported by the RO e-Factura mandate. Self-billed invoices for in-scope transactions must be transmitted through the platform and adhere to RO_CIUS content rules, including self-billing notation.

12. Triangulation & Special Scenarios

While specific detailed guidance is limited, the general principle is that if the supply has a place of supply in Romania and is between established taxable persons, the invoice must go through RO e-Factura. Intra-Community supplies with a foreign VAT number communicated are excluded. The updated EN 16931-1:2026 includes fields for triangulation simplification, which may facilitate future standardization.

13. Archiving & Retention

• Central Archiving: ANAF stores invoices on the RO e-Factura platform, available for download for 60 days. This does not relieve taxpayers of their own archiving obligations.
• Mandatory Format: Invoices must be archived in their original XML format with the MFP digital seal intact, ensuring authenticity and integrity.
• Retention Period: 10 years for general e-invoices, 25 years for capital goods.
• Storage Location: Storage abroad is permitted provided accessibility for Romanian tax authorities is guaranteed. The MFP digital seal ensures integrity and authenticity, verifiable with an ANAF tool.

14. Penalties & Enforcement

Romania enforces its e-invoicing and e-reporting mandates with significant penalties.

14.1. Grace Periods

• B2B e-reporting: Penalty-free period from January 1 – May 31, 2024.
• B2C: Penalty grace period extended to March 31, 2025.
• SMEs (< EUR 500,000 turnover): Enforcement deferred until July 1, 2026.

14.2. Penalties for Non-Compliance (Post-Grace Period)

• Late Transmission (B2B and B2C – failure to transmit within 5 working days):Large taxpayers: RON 5,000–10,000 (≈ EUR 1,000–2,000)
• Medium taxpayers: RON 2,500–5,000 (≈ EUR 500–1,000)
• Small taxpayers & individuals: RON 1,000–2,500 (≈ EUR 200–500)
• Failure to Issue E-Invoices through RO e-Factura (B2B): 15% of the total invoice value (applies to the issuer).
• Receipt and Recording of Non-E-Invoice (B2B): 15% of the total invoice value (applies to the recipient).
• B2G Non-Compliance: Public authority paying without an e-Factura incurs RON 500–1,000 fine.
• SAF-T Non-Compliance: Failure to submit: RON 1,000–5,000; incomplete submission: RON 500–1,500.
• e-TVA Non-Compliance: Failure to respond to compliance notice within 20 days: RON 1,000–10,000 (tiered).

15. Pre-Filled VAT Returns (RO e-TVA)

Romania launched its RO e-TVA pre-filled VAT return system on August 1, 2024.

• How it works: ANAF generates a pre-filled VAT return using data from RO e-Factura, RO e-Transport, SAF-T, e-Cash registers, and other databases. Taxpayers verify and reconcile this against their records.
• Discrepancy Notifications: If discrepancies exceed 20% AND RON 5,000, ANAF issues an “RO e-TVA compliance notice,” requiring a response within 20 days.
• Future Plans: ANAF aims to automate pre-filling using SAF-T data, potentially eliminating separate VAT return (D300) submissions.
• Dependency: The accuracy of pre-filled returns heavily relies on the quality and completeness of RO e-Factura and SAF-T data submissions.

16. Readiness for VAT in the Digital Age (ViDA)

Romania is significantly ahead of the EU ViDA timeline for domestic e-invoicing.

• ViDA Mandates: Structured e-invoicing for intra-EU B2B from July 1, 2030, and domestic alignment by December 31, 2034.
• Romania’s Position: Already has a fully operational mandatory domestic B2B, B2C, and B2G e-invoicing system since 2024. Its Council derogation expires December 31, 2026.
• Alignment: RO_CIUS is based on EN 16931, and SAF-T is based on OECD SAF-T v2.0.
• Gaps/Adjustments Needed:Cross-border e-invoicing capability via an interoperable network (e.g., Peppol). Romania does not currently use Peppol.
• Potential adjustments to the CIUS_RO to align with the revised EN 16931-1:2026 standard.
• Integration of national platform data with a supranational VAT information exchange system (VIES replacement).
• Implications for Businesses: Companies already compliant with RO e-Factura have a strong foundation for ViDA, requiring incremental adjustments rather than a complete overhaul. The main risk is the need for architectural changes to accommodate cross-border exchange networks (e.g., Peppol) mandated by ViDA.

17. Impact on SMEs and Startups

• Phased Onboarding: SMEs with turnover below EUR 500,000 have an enforcement deferral until July 1, 2026, acknowledging the initial burden. Other phased rollouts apply to small taxpayers for SAF-T and B2C.
• Government Support: ANAF provides free tools, including the SPV web portal for manual uploads/downloads, a DUK Validator for XML invoices, an XML-to-PDF conversion tool, and a test environment.
• Compliance Costs: Initial costs involve software upgrades/acquisition, ERP integration, employee training, and digital certificates. While free tools exist, complex ERP integrations can be costly. Popular Romanian ERP solutions have integrated RO e-Factura modules.
• Benefits: Faster processing, pre-filled VAT returns, elimination of paper-related costs, and early error detection contribute to long-term operational benefits.
• Administrative Burden vs. Simplification: The initial burden is significant, requiring IT investment and process changes. However, the long-term effects promise reduced manual data entry, automated reconciliation, and better fiscal control. The deferral for SMEs indicates government recognition of this transition period.

18. Summary & Key Takeaways

Scope:

• Mandatory: Domestic B2B (clearance from July 2024), B2G (from July 2022), B2C (from Jan 2025), and certain non-established VAT-registered buyers (e-reporting + traditional delivery from Jan 2026).
• Excluded: Cross-border (intra-Community, exports), supplies to non-VAT-registered non-established entities, point-of-sale fiscal cash register receipts.

Format:

• Mandatory XML in RO_CIUS (UBL 2.1 or CII), compliant with EN 16931.
• Paper/PDF are no longer legally valid for in-scope B2B since July 2024.

Timeline:

• Full B2B clearance: July 1, 2024.
• Mandatory B2C: January 1, 2025.
• SME enforcement (< EUR 500k turnover): July 1, 2026.
• Unified transmission deadline: 5 working days (from Jan 2026).

Operating Model:

• Centralized Clearance (CTC) for B2B/B2G: Invoices validated and digitally sealed by ANAF (MFP seal) before legal validity.
• Post-issuance reporting for B2C (within 5 working days).
• Platform: RO e-Factura via SPV (Virtual Private Space).
• Dual digital reporting: RO e-Factura + SAF-T (D406).

Key Obligations:

• Issue: All in-scope invoices via RO e-Factura within 5 working days.
• Receive: Download and process from SPV; recording non-e-Factura invoice incurs 15% penalty.
• Report: SAF-T monthly/quarterly; e-TVA reconciliation monthly.
• Correct: Credit notes (381) and reversal invoices (380) via the platform.
• Archive: 10 years (25 for capital goods) in original XML with MFP seal.

Main Risks:

• 15% of invoice value penalty for B2B transactions not processed via the platform (issuer and recipient).
• RON 1,000–10,000 fines for late transmission.
• SAF-T and e-TVA non-compliance fines.
• Operational disruption from invoice rejections due to validation failures.

SME Implications:

• Enforcement deferred to July 1, 2026, for SMEs with turnover < EUR 500,000.
• Free tools are available (SPV portal, validator, conversion tools).
• Initial compliance burden is significant but promises long-term simplification.

ViDA / International Readiness:

• Romania is significantly ahead of the ViDA timeline for domestic CTC.
• Key gaps: Peppol connectivity is lacking, future EN 16931-1:2026 alignment, and cross-border exchange network integration will be required.

Critical Dates & Next Steps:

Date Milestone

• July 1, 2026 Full enforcement for SMEs (turnover < EUR 500,000)
• Dec 31, 2026 Expiry of EU Council derogation (unless ViDA applies earlier)
• July 1, 2030 ViDA: Cross-border B2B Digital Reporting Requirements
• Dec 31, 2034 ViDA: Domestic system alignment with EU standards

Recommended Preparation:

• Ensure all domestic B2B/B2C/B2G invoices flow through RO e-Factura.
• Validate XML against the latest CIUS-RO schematron.
• Ensure SAF-T (D406) is filed accurately and on time (full format from 2026).
• Monitor e-TVA compliance notices and respond promptly.
• Begin planning for future EN 16931-1:2026 format updates and ViDA integration.
• SMEs: Utilize the remaining time before July 2026 to test systems, clean data, and integrate processes.

Disclaimer: This briefing is compiled as of June 7, 2026, based on the provided sources. Given Romania’s dynamic legislative environment, frequent amendments via Government Emergency Ordinances are possible. Readers are strongly advised to monitor official ANAF and Ministry of Finance publications for the most current updates.

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INDEPTH ANALYSIS

1. Introduction & Country Context

1.1. Overview of Romania’s Tax Digitalization Journey

Romania has pursued an ambitious and accelerating tax digitalization strategy over the past five years, driven by one of the highest VAT gaps in the European Union. The journey began with the transposition of EU Directive 2014/55/EU on B2G e-invoicing through Law 199/2020 (effective September 2020), which required all public contracting authorities to accept and process EN 16931-compliant structured e-invoices. [ec.europa.eu]

The operational backbone of Romania’s e-invoicing system — the RO e-Factura platform — was established under Government Emergency Ordinance (GEO/OUG) No. 120/2021, published in the Official Gazette (Monitorul Oficial) No. 960 on 7 October 2021. This legislation created the national electronic invoice system, its administration, and the framework for phased rollout across B2G, B2B, and eventually B2C transactions. [legislatie.just.ro]

The rollout has been staged:

• November 2021: RO e-Factura launched for voluntary B2G and B2B use. [ecosio.com]
• July 2022: B2G e-invoicing became mandatory; B2B mandatory for high fiscal risk product categories (vegetables, fruits, alcohol, mineral products, construction, clothing/footwear). [vatcalc.com]
• January 2024: Mandatory B2B e-invoicing for all domestic transactions between established taxable persons. [ec.europa.eu]
• July 2024: Full B2B e-invoicing clearance model operational (invoices must be cleared via the platform before being legally valid). [vatcalc.com]
• January 2025: B2C e-invoicing mandatory via RO e-Factura. [edicomgroup.com]
• January 2026: Scope expanded to individuals with CNP, non-established VAT-registered buyers; transmission deadline unified to 5 working days. [sovos.com]

In parallel, Romania implemented:

• SAF-T (D406) mandatory reporting (phased from January 2022 for large taxpayers). [rtcsuite.com]
• RO e-Transport for monitoring road transport of high fiscal risk goods. [vatupdate.com]
• RO e-TVA pre-filled VAT returns (launched August 2024). [vatcalc.com]

1.2. Rationale Behind the Mandate

The primary drivers behind Romania’s e-invoicing mandate include:

• VAT gap reduction: Romania has consistently recorded one of the highest VAT gaps in the EU — 35.7% in 2020, 30.6% in 2022, and 30% in 2023. The NRRP (National Recovery and Resilience Plan) commits Romania to reducing the VAT gap by 5 percentage points by 2026 compared to 2019 (34.7%), targeting approximately 29%. [thediplomat.ro], [eur-lex.europa.eu]
• Fraud prevention: Real-time transaction-level monitoring enables immediate identification and disruption of VAT fraud chains. [eur-lex.europa.eu]
• Administrative modernization: Digitalization of invoicing reduces the administrative burden on both taxpayers and the tax administration, improves competitiveness, and lowers costs. [eur-lex.europa.eu]
• Alignment with EU trends: Romania’s mandate aligns with the EU’s ViDA (VAT in the Digital Age) trajectory and the broader European push toward Continuous Transaction Controls (CTC). [dddinvoices.com]

ANAF President Adrian Nica stated:“Our strategy is to move the fight against tax evasion into the digital area… Digitalization eliminates unfair competition and protects the honest business environment.” [static.anaf.ro]

1.3. Position Within the Broader Landscape

Romania is an early mover among EU Member States in implementing a mandatory centralized clearance (CTC) e-invoicing model for B2B transactions, alongside Italy (SDI, since 2019) and ahead of countries like Poland (KSeF, delayed), France (PPF/PDP, phased from 2026–2027), and Germany (planned 2025–2028). [sensetask.com]

Romania’s system is a centralized clearance model, meaning invoices are validated and digitally sealed by the government platform before being considered legally issued for B2B/B2G flows. This positions Romania ahead of the EU ViDA timeline, which mandates structured e-invoicing for intra-community B2B transactions only from 1 July 2030 and domestic alignment by 31 December 2034. [e-invoice.app]

Romania’s approach is consistent with the OECD CTC model and represents one of the most comprehensive digital tax control ecosystems in Europe, combining e-invoicing (RO e-Factura), e-transport (RO e-Transport), e-reporting (SAF-T/D406), and pre-filled VAT returns (RO e-TVA). [vatcalc.com]

1.4. Supranational Authorization / Derogation

Romania obtained a Council Implementing Decision (EU) 2023/1553 of 25 July 2023, authorizing a derogation from Articles 218 and 232 of VAT Directive 2006/112/EC. [eur-lex.europa.eu]

Key provisions:

• Article 1: Romania is authorized to accept only invoices issued by taxable persons established in Romania in electronic format (derogation from Art. 218). [eur-lex.europa.eu]
• Article 2: Romania is authorized to provide that the use of electronic invoices is not subject to acceptance by the recipient (derogation from Art. 232). [eur-lex.europa.eu]
• Validity: 1 January 2024 until the earlier of: (a) 31 December 2026, or (b) the date from which Member States must apply national provisions transposing ViDA amendments to Articles 218 and 232. [eur-lex.europa.eu]

Romania’s original request also sought derogation from Article 178 (VAT deduction only on the basis of the original e-invoice), but this was not granted by the Council. [cabot-tp.ro]

2. Regulatory Framework

2.1. Primary Legislation

• Government Emergency Ordinance (OUG) No. 120/2021 — the foundational act governing the administration, operation, and implementation of the RO e-Factura system. Published in Monitorul Oficial No. 960 of 7 October 2021. [legislatie.just.ro]
• Law No. 139/2022 — approved OUG 120/2021, incorporating amendments. [vatupdate.com]
• Law No. 296/2023 — fiscal-budgetary measures for Romania’s long-term financial sustainability. Introduced mandatory B2B e-invoicing from 1 January 2024, amended Art. 5, Art. 7, and introduced Art. 9¹ of OUG 120/2021. Published in Monitorul Oficial, effective 11 November 2023. [static.anaf.ro], [ec.europa.eu]
• Law No. 199/2020 — transposition of EU Directive 2014/55/EU on B2G e-invoicing in public procurement. [ec.europa.eu]
• Law No. 227/2015 — the Romanian Fiscal Code (Codul Fiscal), governing VAT rules including invoicing requirements (Art. 319), place of supply (Art. 275, 278–279), and establishment (Art. 266). [static.anaf.ro]

2.2. Implementing Regulations, Decrees & Orders

• GEO No. 130/2021 — introduced mandatory e-invoicing from July 2022 for high fiscal risk product categories. [edicomgroup.com]
• GEO No. 115/2023 — clarified scope, introduced the 5-calendar-day transmission deadline (from July 2024), defined exemptions, and introduced the 15% penalty for non-compliance. [fonoa.com]
• GEO No. 138/2024 — effective 1 January 2025: introduced mandatory B2C e-invoicing, place-of-supply criteria for B2B scope, addressed data protection for B2C (CNP field), and extended penalty grace period to 31 March 2025. [marosavat.com], [dddinvoices.com]
• GEO No. 89/2025 — published 23 December 2025, effective 1 January 2026: unified B2B and B2C transmission deadline to 5 working days (previously 5 calendar days for B2B); clarified obligations for invoices to non-established VAT-registered buyers; introduced CNP registration requirement for individual entrepreneurs; suspended the e-TVA system’s certain communication obligations. [sovos.com], [marosavat.com]
• GEO No. 13/2026 — suspended ANAF’s obligation to communicate taxpayer risk classifications until 31 December 2026. [vatcalc.com]
• ANAF Order No. 12/2022 — defined the high fiscal risk product categories subject to mandatory B2B e-invoicing from July 2022. [edicomgroup.com]
• Minister of Finance Order No. 1.366/2021 — approved the RO_CIUS technical specifications and operational rules for e-invoices. [dddinvoices.com]
• ANAF Order No. 1783/2021 — established the SAF-T (D406) mandatory reporting obligation. [tpa-group.ro]
• ANAF Orders No. 3.788/2024 and 3.789/2024 — approved procedures for mandatory and optional enrollment in the RO e-Factura registry (Forms 081 and 082). [dddinvoices.com]
• ANAF Presidential Order No. 2131/2025 — updated VAT return Form 300 to reflect the August 2025 VAT rate changes (19% → 21%, new 11% reduced rate). [regfollower.com]
• GEO No. 70/2024 — approved the RO e-TVA pre-filled VAT return system. [pwc.ro]
• GEO No. 87/2024 — amended the e-TVA system with significance thresholds and penalty provisions. [pwc.ro]

2.3. Circulars, Official Guidance, Administrative Rulings & FAQs

• ANAF SAF-T FAQ — published 7 October 2021, updated periodically, containing frequently asked questions and answers specific to the SAF-T schema. [anaf.ro]
• ANAF e-Factura assistance documents — including the DUK validator (updated 19 November 2024), XSD schemas, schematron validation artefacts (version 1.0.9, valid from 5 June 2024), XML-to-PDF conversion tools, and example invoices in UBL and CII syntax. [mfinante.gov.ro]
• ANAF e-Factura Web Services Presentation — updated 13 February 2025, describing API services including new B2C upload endpoints. [mfinante.gov.ro]
• ANAF guidance on invoice type codes — December 2024 guidance clarifying use of code 380 for storno/reversal invoices and code 381 for credit notes. [teaha.ro]
• ANAF SAF-T clarification on D406 Assets — published 14 November 2022, updated 26 May 2023. [anaf.ro]
• Government Ordinance 22/28.08.2025 — extended the e-TVA grace period until 31 December 2025. [fintua.com]
• Law No. 141/2025 — fiscal-budgetary measures, including VAT rate changes from 1 August 2025 (standard rate from 19% to 21%, new 11% reduced rate). [regfollower.com]

2.4. Supranational / International Legal Basis

• Council Implementing Decision (EU) 2023/1553 — derogation from Articles 218 and 232 of VAT Directive 2006/112/EC, valid 1 January 2024 – 31 December 2026 (or ViDA application date, whichever is earlier). [eur-lex.europa.eu]
• EU Directive 2014/55/EU — on e-invoicing in public procurement, transposed by Law 199/2020. [ec.europa.eu]
• ViDA Directive 2025/516 — adopted March 2025, published in Official Journal. Romania will need to align its domestic CTC model with ViDA’s Digital Reporting Requirements by 31 December 2034. Cross-border B2B DRR from 1 July 2030. [e-invoice.app], [vatcalc.com]

3. Scope of the Mandate

3.1. Transactions in Scope

Domestic B2B — Mandatory since 1 January 2024 (reporting phase), with full clearance e-invoicing from 1 July 2024. All domestic B2B transactions with a place of supply in Romania between taxable persons established in Romania must be issued and received through RO e-Factura. Since January 2025, the place-of-supply criterion applies — only B2B transactions taking place in Romania are in scope. Paper and PDF invoices are no longer legally valid for in-scope B2B transactions from 1 July 2024. [marosavat.com], [ecosio.com]

As of 1 January 2026, invoices issued by Romanian taxable persons to non-established VAT-registered buyers (without a fixed establishment in Romania) must also be transmitted through RO e-Factura (e-reporting obligation), though the supplier must additionally deliver the invoice via traditional methods to the buyer. [sovos.com], [marosavat.com]

Domestic B2G — Mandatory since 1 July 2022 for all suppliers to public authorities. Invoices must be sent through RO e-Factura. A public authority may only pay an invoice if it was submitted via e-Factura. [fiscal-req…ements.com], [theinvoicinghub.com]

Domestic B2C — Mandatory since 1 January 2025 for all regular B2C invoices. Suppliers must transmit B2C invoices through RO e-Factura in XML RO_CIUS format within 5 working days. Exemptions apply to point-of-sale fiscal cash register receipts (which remain subject to separate fiscalization rules). Certain entities (small taxpayers, non-profits, farmers under special tax regimes) had until 1 July 2025 to comply fully. Data protection is addressed by allowing all zeros in the 13-digit CNP field for consumer identification. [theinvoicinghub.com], [dddinvoices.com], [marosavat.com]

Cross-border B2B (Intra-Community supplies) — Excluded. Intra-Community supplies of goods (Art. 294(2) of the Fiscal Code) and intra-Community supplies where a foreign VAT number is communicated are out of scope of the RO e-Factura mandate. [fiscal-req…ements.com], [marosavat.com]

Cross-border B2B (Exports outside the EU) — Excluded. Exports of goods under Art. 294(1)(a)–(b) of the Fiscal Code are explicitly excluded from the e-invoicing obligation. [fonoa.com], [fiscal-req…ements.com]

Intra-Community acquisitions — Invoices received from foreign suppliers for intra-Community acquisitions are not in scope of the RO e-Factura platform. The buyer’s obligations are governed by standard Romanian VAT rules. [fiscal-req…ements.com]

3.2. Special Transactions in Scope

Self-billing — Self-billing invoices are in scope and must be processed through the RO e-Factura platform. The platform supports self-billing invoices as a document type. [fonoa.com]

Triangulation and chain transactions — No specific exemption exists for invoices issued by domestically established entities as part of triangular transactions where the supply has a place of supply in Romania. The general rule applies: if the supply takes place in Romania between established taxable persons, the invoice must go through RO e-Factura. Specific guidance on triangulation simplification handling in the CIUS_RO format is limited but the updated EN 16931-1:2026 includes fields for mentioning the use of the triangulation simplification. [vatcalc.com]

Special VAT regimes — Romania has not published comprehensive guidance on whether margin schemes, travel agents, second-hand goods, or flat-rate farmer regimes are fully in scope. However, the B2C mandate applies broadly, and certain entities under special regimes (e.g., flat-rate farmers) had a deferred compliance deadline of 1 July 2025. [dddinvoices.com]

3.3. Excluded or Exempt Transactions

The following are explicitly excluded from the RO e-Factura mandate:

• Supplies to persons not established and not VAT-registered in Romania (though from January 2026, supplies to non-established but VAT-registered buyers are in scope as e-reporting). [fonoa.com], [sovos.com]
• Intra-Community supplies where a foreign VAT number is communicated. [marosavat.com]
• Exports under Art. 294(1)(a)–(b) and (2) of the Fiscal Code. [fonoa.com]
• Supplies of services not subject to Romanian invoicing rules (i.e., where place of supply is outside Romania). [fiscal-req…ements.com]
• Simplified invoices meeting specific conditions (e.g., those issued via electronic fiscal cash registers that qualify as simplified invoices). [marosavat.com]
• Point-of-sale fiscal cash register receipts — exempt from the B2C e-invoicing mandate but subject to separate fiscalization. [theinvoicinghub.com]

4. Taxable Persons in Scope

4.1. Established Domestic Entities

All taxable persons established in Romania (as defined under Art. 266(2) of the Fiscal Code — having a registered office or fixed establishment), regardless of whether they are VAT-registered under Art. 316, are subject to the e-invoicing obligation for B2B, B2C, and B2G transactions. [static.anaf.ro], [dddinvoices.com]

From 1 January 2026, individuals carrying out economic activities under their CNP (personal identification number) — such as photographers, influencers, and independent service providers — must register in the RO e-Factura registry before starting their activity and submit all invoices through the system. [marosavat.com], [sovos.com]

4.2. Non-Established Entities

• Foreign entities with a fixed establishment in Romania — Mandatory. Treated as established taxable persons. [fonoa.com]
• Foreign entities VAT-registered but without a fixed establishment — From January 2024, these entities were subject to the e-reporting obligation. From January 2026, the obligation is clarified: Romanian suppliers issuing invoices to these buyers must transmit via RO e-Factura (e-reporting), but must also deliver the invoice via traditional methods. The non-established buyer’s own obligation to use the system remains limited to e-reporting rather than full clearance. [sovos.com], [europe.tho…euters.com]
• Foreign entities without domestic VAT registration — Excluded from the RO e-Factura mandate. [fonoa.com]

4.3. Voluntary Participation

Voluntary participation in RO e-Factura has been available since the platform’s launch in November 2021. Entities not yet subject to the mandate could opt in by registering in the RO e-Factura Register. Since July 2024, when full B2B clearance became mandatory for established entities, voluntary participation is primarily relevant for entities in transitional categories (e.g., SMEs during the enforcement deferral period). [ecosio.com]

4.4. Sector-Specific Rules & Exemptions

• High fiscal risk sectors (vegetables, fruits, alcohol, mineral products, construction, clothing/footwear) were subject to mandatory e-invoicing from July 2022, ahead of the general B2B mandate. [edicomgroup.com]
• Cultural and related state organizations — mandatory e-invoice reporting from July 2025. [vatcalc.com]
• SMEs with annual turnover below EUR 500,000 — full enforcement deferred until 1 July 2026. This is not an opt-out; these businesses must still prepare but face no penalties until that date. [vatupdate.com], [vatcalc.com]
• Associations, foundations, farmers under special regimes — had until 1 July 2025 to comply with B2C e-invoicing requirements. [theinvoicinghub.com]
• No blanket sector-specific exemptions for financial services, healthcare, or utilities have been legislated beyond the general exclusions described in Section 3.3.

5. Implementation Timeline

5.1. Legislative History

• September 2020: Law 199/2020 transposes Directive 2014/55/EU (B2G). [ec.europa.eu]
• October 2021: OUG 120/2021 published (Monitorul Oficial No. 960, 7 October 2021) — establishes the RO e-Factura system. [legislatie.just.ro]
• December 2021: GEO 130/2021 mandates B2B e-invoicing for high-risk goods from July 2022. [edicomgroup.com]
• May 2022: Law 139/2022 approves OUG 120/2021. [vatupdate.com]
• January 2022: Romania submits derogation request to European Commission. [eur-lex.europa.eu]
• June 2023: European Commission publishes proposal for Council Implementing Decision. [eur-lex.europa.eu]
• July 2023: Council Implementing Decision (EU) 2023/1553 adopted (25 July 2023), published in OJ L 188/48. [eur-lex.europa.eu]
• October 2023: Law 296/2023 adopted — mandatory B2B e-invoicing from 1 January 2024. [static.anaf.ro]
• December 2023: GEO 115/2023 — penalties, 5-day deadline, scope clarifications. [fonoa.com]
• December 2024: GEO 138/2024 — B2C mandate, place-of-supply criteria, penalty grace period extension. [marosavat.com]
• December 2025: GEO 89/2025 — 5 working days deadline, CNP registration, non-established buyer clarifications. [sovos.com]

5.2. Voluntary / Pilot Phases

• November 2021 – June 2022: Voluntary B2G and B2B e-invoicing via RO e-Factura. [ecosio.com]
• July 2024 – December 2024: Voluntary B2C e-invoicing. [edicomgroup.com]
• October 2025: RO e-TVA SAF-T pilot programme launched with 34 businesses from banking, energy, insurance, construction, and retail sectors. [vatcalc.com]

No specific financial incentives (e.g., faster VAT refunds, reduced audit risk) have been formally legislated for voluntary early adopters, though ANAF has indicated that e-TVA compliance reduces the risk profile of taxpayers.

5.3. Mandatory Go-Live Dates (Phased Rollout)

• 1 July 2022: B2G mandatory; B2B mandatory for high fiscal risk goods. [ecosio.com]
• 1 January 2024: B2B e-reporting mandatory for all domestic transactions (all established taxable persons). [ec.europa.eu]
• 1 June 2024: End of penalty grace period for B2B e-reporting. [en.paycode.ro]
• 1 July 2024: Full B2B e-invoicing clearance mandatory — paper/PDF invoices no longer legally valid for in-scope B2B. [vatcalc.com], [edicomgroup.com]
• 1 January 2025: B2C e-invoicing mandatory; SAF-T (D406) mandatory for all remaining VAT-registered taxpayers including small businesses and non-established entities. [rtcsuite.com], [theinvoicinghub.com]
• 1 July 2025: B2C compliance deadline for associations, foundations, and special-regime farmers. Cultural/state organizations B2G mandatory. [vatcalc.com], [theinvoicinghub.com]
• 1 January 2026: Scope expansion (non-established VAT-registered buyers, CNP individuals). 5-working-day deadline applies. [sovos.com]
• 1 July 2026: Full enforcement for SMEs with turnover < EUR 500,000. [vatupdate.com]

5.4. Grace Periods & Transitional Provisions

• 1 January – 31 May 2024: Penalty-free period for B2B e-reporting non-compliance. [en.paycode.ro]
• 1 July 2024 – 31 March 2025: Extended penalty grace period for B2C e-invoicing. [dddinvoices.com]
• August 2024 – 31 December 2025: e-TVA pre-filled return grace period (extended by GO 22/2025). [fintua.com]
• Until 1 July 2026: Enforcement deferral for SMEs with turnover below EUR 500,000. [vatupdate.com]

5.5. Pre-Mandate Milestones

• November 2021: RO e-Factura platform launched. [ecosio.com]
• ANAF test environment: Available continuously; B2C-specific test endpoints implemented from late 2024. [mfinante.gov.ro]
• DUK Validator: Regularly updated (latest: 19 February 2026). [anaf.ro]
• Schematron validation artefacts: Version 1.0.9, valid from 5 June 2024. [mfinante.gov.ro]

5.6. Known or Anticipated Postponements

• The B2B penalty enforcement start was postponed from 1 April 2024 to 1 July 2024 (via GEO 115/2023). [fiscal-req…ements.com]
• The B2C penalty grace period was extended from 1 January 2025 to 31 March 2025 (via GEO 138/2024). [dddinvoices.com]
• The e-TVA grace period was extended multiple times, most recently to 31 December 2025 (via GO 22/2025). [fintua.com]
• SME enforcement was deferred to 1 July 2026. [vatupdate.com]
• No further postponements have been publicly announced as of June 2026, but the pace of legislative amendments suggests continued iterative adjustments are possible.

6. How E-Invoicing & E-Reporting Really Work — The Operating Model

6.1. Overview of the Operating Model

Romania operates a Centralized Clearance (CTC) model for B2B and B2G transactions. The government platform (RO e-Factura) validates and digitally seals every invoice before it is considered legally issued. [ecosio.com], [complyance.io]

For B2C transactions, the model is a post-issuance reporting model: invoices can be exchanged with the consumer first and then reported to RO e-Factura within 5 working days. [ecosio.com]

The tax authority (ANAF) plays a central role in the invoice lifecycle: receiving, validating, sealing, storing, and making invoices available to recipients. [e-invoice.app]

6.2. Step-by-Step Invoice Lifecycle

Step 1 — Invoice Creation: The seller’s ERP or accounting system generates an e-invoice in XML format compliant with the RO_CIUS specification (based on UBL 2.1 or CII, EN 16931-compliant). [theinvoicinghub.com]

Step 2 — Submission: The XML invoice is transmitted to the RO e-Factura platform via the Spațiul Privat Virtual (SPV) — the Virtual Private Space portal, using ANAF’s API or the web interface. [e-invoice.app]

Step 3 — Validation: ANAF performs schema validation, business rule checks (50+ rules), and calculation verification against the CIUS_RO schematron rules. If validation fails, the invoice is rejected with specific error codes, and the issuer must correct and resubmit within the 5-working-day deadline. [invoicemonk.com]

Step 4 — Clearance / Acceptance: Upon successful validation, ANAF applies a Ministry of Finance digital seal (MFP seal) and assigns an upload index number and timestamp. The sealed XML becomes the legally valid original invoice. [ecosio.com], [complyance.io]

Step 5 — Delivery to Buyer: The validated and sealed invoice is made available for the buyer to download from the SPV platform. For B2B transactions between established entities, the invoice delivered via RO e-Factura is the legally valid document. For invoices to non-established VAT-registered buyers, the supplier must also deliver the invoice via traditional methods. [sovos.com], [e-invoice.app]

Step 6 — Retrieval by Buyer: The buyer retrieves invoices from the SPV platform via API or web portal. ANAF stores invoices for 60 days for download; after that period, invoices remain in the system but may require alternative retrieval. Third-party service providers can also retrieve invoices on behalf of the buyer via API. [docs.socrate.io]

Step 7 — Archiving: Both parties must archive the XML invoice with the MFP seal for a minimum of 10 years (25 years for capital goods). The sealed XML must maintain authenticity and integrity throughout the retention period. [e-invoice.app], [vatupdate.com]

6.3. Authentication & Access Methods

• Qualified electronic signature / digital certificate: Required for accessing the SPV and transmitting invoices. Users must authenticate using a qualified electronic certificate recognized by the ANAF system. [cabot-tp.ro]
• OAuth 2.0 authorization: For API-based access, applications must implement OAuth 2.0 authorization with ANAF. [docs.socrate.io]
• Third-party authorization: Accountants, fiscal representatives, and service providers can be authorized to act on behalf of the taxpayer through the SPV platform. [docs.socrate.io]

6.4. Offline / Contingency Mode

ANAF has not published detailed offline invoicing procedures. If the platform is unavailable, the e-TVA/e-Factura system provides for deadline extensions corresponding to the duration of the technical interruption. ANAF commits to notifying businesses of service interruptions. [piroi.com]

There is no formal “offline mode” with QR codes or special markings as seen in some other CTC systems (e.g., Mexico’s CFDI). Businesses are expected to submit invoices once connectivity is restored, within the applicable deadline.

6.5. Buyer-Side Workflow

Buyers must:

• Retrieve invoices from the SPV platform (via web portal or API). [e-invoice.app]
• Process the received e-invoice electronically.
• For B2G: public institutions must verify legality, accuracy, and compliance. [fiscal-req…ements.com]
• Buyer acceptance is not required for the invoice to be legally valid (per the Council derogation from Art. 232). [eur-lex.europa.eu]
• Buyers receiving and recording an invoice outside the RO e-Factura system face a 15% penalty of the invoice value in B2B transactions. [fiscal-req…ements.com]

6.6. QR Code or Verification Code Requirements

Romania’s current e-invoicing framework does not require a QR code or verification code on invoices. The legal validity is ensured by the MFP digital seal applied by the platform to the XML document. [complyance.io]

For B2C fiscal cash register receipts (which are separate from the e-invoicing mandate), QR codes may be required under separate fiscalization rules. [dddinvoices.com]

7. Acceptable E-Invoice Formats — Mandatory & Voluntary

7.1. Mandatory Format(s)

The legally required format is XML compliant with the RO_CIUS (Core Invoice Usage Specification — Romania), which is a national customization of:

• UBL 2.1 (Invoice-2 and CreditNote-2 schemas), or
• UN/CEFACT CII syntax

Both aligned with the EN 16931 European e-invoicing standard. [theinvoicinghub.com], [developer….texinc.com]

The RO_CIUS specification defines over 100 data fields with strict ANAF validation rules. The structure includes: header information, seller/buyer identification sections, line items with descriptions/quantities/prices/VAT, summaries, and payment information. [invoicemonk.com]

Unstructured formats (PDF, paper, Word, Excel) are no longer legally valid for in-scope B2B transactions from 1 July 2024. [vatcalc.com]

7.2. Relationship to International / Regional Standards

• EN 16931: RO_CIUS is fully based on and compliant with EN 16931. [theinvoicinghub.com]
• Peppol BIS 3.0: Romania does not currently use the Peppol network for RO e-Factura transmission. Peppol connectivity is not available. [fonoa.com]
• UBL 2.1 / CII: Both syntaxes are accepted. UBL 2.1 is the primary syntax used in practice. [developer….texinc.com]
• National extensions: Romania uses CIUS-RO-specific business rules (schematron validation artefacts), including Romanian tax ID (CUI/CIF) validation against the ANAF registry, county (județ) codes, and Romanian-specific VAT category rules. [invoicemonk.com]

7.3. Voluntary / Legacy / Transitional Formats

• During the January – June 2024 transitional period (e-reporting phase), invoices could still be delivered to recipients in traditional format alongside the e-reporting submission. [en.paycode.ro]
• For B2C transactions, the B2C e-invoicing format is the same RO_CIUS XML, but delivery to the consumer may also be made via traditional methods alongside the mandatory platform reporting. [theinvoicinghub.com]
• No dual-format or hybrid format options (like Factur-X/ZUGFeRD) are formally recognized within the RO e-Factura system. [theinvoicinghub.com]

7.4. Attachments

ANAF’s API and the RO e-Factura platform support the transmission of invoices with attachments. The XML format allows for embedded attachments. The updated EN 16931-1:2026 standard also adds support for XML attachments. [docs.socrate.io] [vatcalc.com]

Attachments are generally considered supplementary documentation rather than formal invoice components. The legally valid document is the XML with the MFP seal.

8. Technical & Functional Requirements

8.1. E-Invoice Specifications

Mandatory Data Fields (per RO_CIUS based on EN 16931):

• Seller data: CUI/CIF (validated against ANAF registry), legal name (must match ONRC trade registry), full address including county (județ), bank account (IBAN). [invoicemonk.com]
• Buyer data: CUI/CIF (validated against ANAF), legal name, address including county code. For B2C: CNP field (may use 13 zeros for privacy). [marosavat.com], [invoicemonk.com]
• Invoice data: invoice number (sequential within seller’s numbering), issue date, delivery date, currency (RON for domestic; EUR or other for cross-border). [invoicemonk.com]
• VAT breakdown: per rate (21% standard from August 2025, 11% reduced, 9% reduced, 5% reduced). [regfollower.com]
• Line items: description, quantity, unit price, VAT rate, amounts. [invoicemonk.com]
• Payment terms and information.

Data Validation Rules:

• Schema validation against the CIUS-RO XSD.
• 50+ business rules via schematron (version 1.0.9). [invoicemonk.com]
• CUI/CIF checksum validation against ANAF registry.
• VAT amount calculation alignment checks.
• Duplicate invoice number detection (per seller per year). [invoicemonk.com]

8.2. E-Reporting Specifications (SAF-T / D406)

Romania mandates SAF-T reporting via Form D406, based on the OECD SAF-T v2.0 schema adapted for Romania. [code10it.com]

Components:

• D406 General: General ledger, invoices, accounts receivable/payable, payments, master data — submitted monthly or quarterly (aligned with VAT reporting frequency). [rtcsuite.com]
• D406 Assets: Fixed assets — submitted annually with financial statements. [rtcsuite.com]
• D406 Inventory: Stock movements — submitted on request by ANAF (minimum 30 calendar days). [rtcsuite.com]
• D406 Banking: Banking-specific data — on request for financial institutions. [rtcsuite.com]
• D406 Insurance: Insurance-specific data — on request. [rtcsuite.com]

Filing deadline: Last calendar day of the month following the reporting period. [rtcsuite.com]

Full SAF-T from 2026 (expanded sections): [geseidl.ro]

• Large taxpayers (turnover > EUR 50M): full reporting from Q1 2026.
• Medium taxpayers (EUR 1–50M): from Q2 2026.
• Small/micro taxpayers: from Q3 2026.
• Public institutions: from Q4 2026.

Penalties for SAF-T non-compliance: Fines of RON 1,000–5,000 for failure to submit; RON 500–1,500 for incomplete submissions. Resubmission required within 5 days of rejection. [tpa-group.ro], [geseidl.ro]

8.3. Digital Signature & Integrity Requirements

Per-invoice digital signature is not required from the taxpayer. The platform applies the Ministry of Finance (MFP) digital seal upon successful validation, which guarantees integrity and authenticity. [complyance.io]

For SAF-T submission, the XML file must be attached to a digitally signed PDF form using a qualified electronic signature, submitted via the e-Guvernare platform or ANAF portal. [code10it.com]

8.4. Real-Time or Near-Real-Time Processing

The system operates as a near-real-time clearance model:

• B2B/B2G: Invoices are validated within seconds/minutes of submission. The invoice is not legally valid until ANAF validates it. [ecosio.com]
• B2C: Post-issuance reporting within T+5 working days. [sovos.com]
• SAF-T: Monthly/quarterly batch reporting. [rtcsuite.com]

ANAF has published API rate limits but has not publicly disclosed specific uptime targets or SLAs for the platform. [mfinante.gov.ro]

9. Correction of Errors in E-Invoices and E-Reporting

9.1. E-Invoice Corrections

ANAF guidance (December 2024) clarifies the correction framework: [teaha.ro]

• Reversal (storno) invoice: If errors exist in a previously issued invoice, a full or partial reversal invoice is issued using code 380 with negative values (except BT-146 net price, which remains positive). The original invoice must be referenced via BT-25 (Previous Invoice Reference) and BT-26 (Previous Invoice Issue Date).
• Credit note: Uses code 381. Has the same legal status as an invoice with negative sign. Used for adjustments (invoicing errors, returns, discounts). At line level, credit notes always use positive values. To correct a previously issued credit note, an invoice with code 380 and positive values is issued.
• All corrective documents must be submitted through RO e-Factura following the same validation and clearance process as original invoices. [teaha.ro]

9.2. E-Reporting Corrections

• SAF-T corrections: If a D406 file is rejected by ANAF, the taxpayer must resubmit within 5 days. [geseidl.ro]
• VAT return corrections: Amended VAT returns (D300) can be submitted. The e-TVA system flags discrepancies exceeding 20% or RON 5,000 between the pre-filled return and the submitted return, requiring a response within 20 days. [pwc.ro]
• Penalties for late or incorrect corrections follow the general penalty framework (see Section 14).

10. Transmission & Workflow

10.1. Central Platform

Name: RO e-Factura (Sistemul Național privind Factura Electronică) URL: https://efactura.mfinante.gov.ro/ Operating authority: ANAF (Agenția Națională de Administrare Fiscală / National Agency for Fiscal Administration), under the Ministry of Finance (Ministerul Finanțelor). [efactura.m…nte.gov.ro] [ec.europa.eu]

10.2. Transmission Channels

• Government API: REST API with OAuth 2.0 authentication, accessible via the SPV (Spațiul Privat Virtual). Separate endpoints for B2B/B2G and B2C uploads. [mfinante.gov.ro], [emite-facturi.ro]
• Web portal (SPV): Free government-provided web interface for manual invoice upload, download, and management. [e-invoice.app]
• Third-party service providers: Commercial API intermediaries (e.g., apiefactura.ro, Contazen, ecosio, DocProcess, Infinite IT Solutions, Socrate Business Services) provide connectivity services. [apiefactura.ro], [contazen.ro], [docs.socrate.io]
• ERP integration: Direct API integration from ERP/accounting software (Saga, WinMentor, Nexus, SmartBill, SAP, etc.). [geseidl.ro]
• Peppol Access Points: Not supported. Romania does not currently use the Peppol network for RO e-Factura. [fonoa.com]

10.3. Accredited Service Providers / Certified Intermediaries

Romania does not operate a formal accreditation/certification regime for e-invoicing service providers. Any service provider can offer connectivity services to the RO e-Factura platform via the public API. There is no official registry of accredited providers. Taxpayers remain responsible for compliance regardless of which provider they use. [fonoa.com]

10.4. Interoperability

• The RO e-Factura platform currently operates as a standalone national system without direct interoperability with Peppol or other cross-border exchange networks. [fonoa.com]
• B2G e-invoicing uses the same RO e-Factura platform (not a separate B2G platform). [theinvoicinghub.com]
• Future interoperability with the EU ViDA Digital Reporting Requirements framework will be required by 2030 (cross-border) and 2034 (domestic alignment). [e-invoice.app]

10.5. Deadlines & Timing

• Transmission deadline (B2B and B2C): 5 working days from the invoice issue date, or 5 working days from the legal invoicing deadline (15th of the month following the chargeable event / delivery / advance collection). [fiscal-req…ements.com], [sovos.com]
• B2G: No explicit transmission deadline, but payment is conditional on e-Factura submission. [fiscal-req…ements.com]
• SAF-T (D406): Last calendar day of the month following the reporting period. [rtcsuite.com]
• VAT return (D300): By the 25th of the month following the reporting period.
• e-TVA reconciliation: By the 20th of the month following the reporting period. [piroi.com]

11. Self-Billing

11.1. Is self-billing permitted?

Yes. Self-billing invoices are supported within the RO e-Factura mandate. [fonoa.com]

11.2. Must self-billed invoices be processed through the platform?

Yes. Self-billing invoices for in-scope transactions must be transmitted through RO e-Factura. [fonoa.com]

11.3. Authorization process

Self-billing arrangements must comply with the general requirements under Art. 319 of the Fiscal Code, which requires a prior agreement between the parties. No specific RO e-Factura platform registration form for self-billing has been published beyond the standard invoice submission process.

11.4. Mandatory content rules

Self-billed invoices must contain the same mandatory data elements as regular invoices under the RO_CIUS specification, with the addition of the self-billing notation as required by Art. 319 of the Fiscal Code.

11.5. Specific notation/code/flag

The RO_CIUS format supports the indication of self-billing through the appropriate invoice type code and reference fields in the XML structure.

11.6. Restrictions for foreign buyers

For non-established buyers without a domestic VAT number, the e-invoicing obligation does not apply (the transaction is out of scope). [fonoa.com]

11.7. Buyer-side validation

Buyer acceptance is not required for legal validity under the Council derogation. [eur-lex.europa.eu]

12. Triangulation & Special Scenarios

12.1. Triangulation Transactions

Romania has not published specific detailed guidance on the treatment of triangulation invoices under RO e-Factura. The general principle applies: if the invoice is issued by a taxable person established in Romania for a domestic supply (place of supply in Romania), it must be transmitted via the platform. Intra-Community supplies with a foreign VAT number communicated are excluded. [marosavat.com]

The updated EN 16931-1:2026 includes a field for mentioning the use of the triangulation simplification, which may facilitate future standardization. [vatcalc.com]

12.2. Chain Transactions

No specific RO e-Factura rules for multi-party chain transactions have been published beyond the general place-of-supply criterion.

12.3. Cross-Border Reverse Charge

• Outbound invoices with reverse-charge notation: If the supply has a place of supply outside Romania or is an intra-Community supply, the invoice is out of scope of RO e-Factura. [fiscal-req…ements.com]
• Inbound reverse-charge invoices: Invoices received from foreign suppliers are not processed through RO e-Factura. The Romanian buyer self-assesses VAT per standard rules and reports via the VAT return and SAF-T.

12.4. Zero-Rated and Exempt Supplies

• Zero-rated supplies (exports, intra-Community supplies) are excluded from the RO e-Factura mandate. [fonoa.com]
• Exempt supplies: Domestic exempt supplies (if an invoice is required) would need to follow the general e-invoicing rules if issued between established taxable persons. The CIUS_RO format includes VAT category codes for exempt supplies (e.g., VAT category E).

12.5. Local Nuances & Special Cases

• Construction reverse charge: Domestic reverse charge for construction services applies in Romania. Invoices for these supplies between established entities must be issued through RO e-Factura with the appropriate reverse-charge notation.
• Fiscal representatives: Foreign entities using fiscal representatives in Romania — the fiscal representative can access the SPV and submit invoices on behalf of the represented entity.
• Call-off stock: No specific RO e-Factura rules beyond standard invoicing requirements.
• RO e-Transport: Mandatory alongside e-invoicing for road transport of high fiscal risk goods. Transport data may be cross-referenced with e-invoice data. [ecosio.com]

13. Archiving & Retention

13.1. Central Archiving by the Platform

ANAF stores invoices on the RO e-Factura platform. Invoices are available for download for 60 days after upload, though they remain in the system’s records beyond that period. [docs.socrate.io]

Central platform storage does not relieve taxpayers of their separate archiving obligations. [e-invoice.app]

13.2. Mandatory Archiving Format

Invoices must be archived in their original XML format with the MFP digital seal intact, ensuring authenticity and integrity. [e-invoice.app]

13.3. Retention Period

• General: 10 years for e-invoices and related documents, per Art. 319 of the Fiscal Code. [e-invoice.app], [vatupdate.com]
• Capital goods: 25 years for invoices related to capital goods. [vatupdate.com]
• SAF-T data: Follows the general 10-year retention requirement.

13.4. Storage Location Requirements

Storage abroad is permitted under conditions — consistent with Art. 247 of the VAT Directive, the taxpayer must ensure that archived invoices are accessible on demand by the Romanian tax authorities. [tungstenau…mation.com]

13.5. Integrity, Authenticity & Readability

The MFP digital seal applied by the platform serves as the primary integrity and authenticity guarantee. Throughout the retention period, the XML file with the seal must remain unaltered, readable, and verifiable. [complyance.io]

ANAF provides a signature verification application (updated 13 March 2026) for verifying the MFP seal on archived invoices. [mfinante.gov.ro]

13.6. Audit Accessibility

Tax authorities have real-time access to invoice data through the RO e-Factura platform. Additionally, SAF-T data provides ANAF with comprehensive financial and accounting data for audit purposes. Taxpayers must make archived invoices accessible upon request. [code10it.com]

14. Penalties & Enforcement

14.1. Grace Period / Transitional Enforcement

• B2B e-reporting: Penalty-free period 1 January – 31 May 2024. [en.paycode.ro]
• B2B full e-invoicing: Penalties applied from 1 July 2024. [fonoa.com]
• B2C: Penalty grace period extended to 31 March 2025. [dddinvoices.com]
• SMEs (turnover < EUR 500,000): Enforcement deferred to 1 July 2026. [vatupdate.com]

14.2. Penalties for Non-Compliance (Post-Grace Period)

Late transmission (B2B and B2C — failure to transmit within 5 working days): [fiscal-req…ements.com]

• Large taxpayers: RON 5,000–10,000 (≈ EUR 1,000–2,000)
• Medium taxpayers: RON 2,500–5,000 (≈ EUR 500–1,000)
• Small taxpayers & individuals: RON 1,000–2,500 (≈ EUR 200–500)

Failure to issue e-invoices through RO e-Factura (B2B): [fiscal-req…ements.com]

• 15% of the total invoice value — applies to the issuer.

Receipt and recording of non-e-invoice (B2B): [fiscal-req…ements.com]

• 15% of the total invoice value — applies to the recipient who receives and records an invoice not transmitted via e-Factura.

B2G non-compliance: [fiscal-req…ements.com]

• Public authority paying without an e-Factura: RON 500–1,000 (≈ EUR 100–200).
• Illegal payment must be recovered with interest and late-payment penalties.

SAF-T non-compliance: [tpa-group.ro]

• Failure to submit: RON 1,000–5,000.
• Incomplete submission: RON 500–1,500.

e-TVA non-compliance: [pwc.ro]

• Failure to respond to compliance notice within 20 days: RON 5,000–10,000 (large), RON 2,500–5,000 (medium), RON 1,000–2,500 (others).

14.3. Penalty Amounts & Calculation Methods

Penalties are differentiated by taxpayer size (large, medium, small/individual) for procedural violations, and by a percentage of invoice value (15%) for substantive non-compliance (failure to use the platform entirely). [fiscal-req…ements.com]

No specific escalation mechanisms for repeat offenders have been publicly legislated, though the 15% penalty per invoice creates a proportional deterrent.

14.4. Article References

• Art. 10, Art. 13² of OUG 120/2021 (as amended) — penalty provisions. [en.paycode.ro]
• Art. LIX (1), (5)–(8) of Law 296/2023 — tiered fines for late transmission. [en.paycode.ro]
• Art. 319 of the Fiscal Code (Law 227/2015) — invoicing and archiving requirements. [e-invoice.app]

15. Pre-Filled VAT Returns

15.1. Does Romania offer pre-filled VAT returns?

Yes. Romania launched the RO e-TVA pre-filled VAT return system on 1 August 2024. [vatcalc.com]

15.2. How it works

• ANAF generates a pre-filled VAT return for each reporting period using data from RO e-Factura, RO e-Transport, RO e-Sigiliu (e-Seal), SAF-T, RO e-Cash registers, customs integrated IT system, and other ANAF databases. [pwc.ro]
• The pre-filled return is sent to taxpayers by the 5th of the month following the legal deadline for submitting D300. [pwc.ro]
• Taxpayers must verify and reconcile the pre-filled return against their accounting records.
• If discrepancies exceed 20% AND RON 5,000, ANAF issues an”RO e-TVA compliance notice”, to which the taxpayer must respond within 20 days. [pwc.ro]

15.3. Future plans

ANAF’s long-term objective is to:

• Automatically pre-fill VAT returns using SAF-T data.
• Allow taxpayers to validate and reconcile figures before filing.
• Ultimately eliminate the need for separate VAT return (D300) submissions altogether. [vatcalc.com]

A pilot programme launched in October 2025 with 34 businesses is testing SAF-T-to-VAT-return consistency at a transaction level (not just totals). [vatcalc.com]

15.4. Dependency on e-invoicing/e-reporting data

The pre-filled return is heavily dependent on RO e-Factura and SAF-T data. The quality and completeness of e-invoicing submissions directly affect the accuracy of the pre-filled return and the likelihood of compliance notifications. [vatcalc.com]

15.5. Alignment with ViDA

Romania’s pre-filled VAT return system is conceptually aligned with the ViDA proposal’s vision for pre-filled returns based on transaction-level data. Romania is arguably ahead of many EU Member States in implementing this feature. [vatcalc.com]

16. Readiness for VAT in the Digital Age (ViDA)

16.1. Country Position Relative to ViDA

Romania is significantly ahead of the ViDA timeline:

• ViDA mandates structured e-invoicing for intra-EU B2B from 1 July 2030 and domestic alignment by 31 December 2034. [e-invoice.app]
• Romania already has a fully operational mandatory domestic B2B, B2C, and B2G e-invoicing system with centralized clearance since 2024.
• Romania’s Council derogation expires 31 December 2026 or upon ViDA’s application date (whichever is earlier). [eur-lex.europa.eu]
• By 2035, Romania will need to harmonize its centralized clearance model with the ViDA Digital Reporting Requirements framework. [vatcalc.com]

16.2. Alignment with ViDA / International Requirements

• EN 16931: Romania’s RO_CIUS is based on EN 16931. CEN approved EN 16931-1:2026 on 13 February 2026, updating the standard for B2B and ViDA readiness. Romania will need to update its CIUS-RO schematron rules to align with the revised standard. [vatupdate.com], [vatcalc.com]
• Peppol: Romania does not currently use Peppol. ViDA may drive future adoption of Peppol or equivalent interoperable networks for cross-border exchange. [fonoa.com]
• OECD SAF-T: Romania’s D406 is based on the OECD SAF-T v2.0 schema, well-aligned with international standards. [code10it.com]

Gaps/adjustments needed:

• Cross-border e-invoicing capability via an interoperable network (Peppol or equivalent).
• Potential adjustments to the CIUS_RO to incorporate new mandatory fields from EN 16931-1:2026 (e.g., IBAN, early-payment discounts, triangulation simplification fields, corrective invoice numbering, FX handling). [vatcalc.com]
• Integration of national platform data with a supranational VAT information exchange system (VIES replacement). [e-invoice.app]

16.3. Cross-Border Digital Reporting

From 1 July 2030, Romania’s system will need to interact with the EU-wide Digital Reporting Requirements for intra-community B2B transactions. This will likely require:

• Reporting of intra-community supplies/acquisitions to a central EU system (replacing EC Sales Lists).
• Ability to issue and receive structured e-invoices for intra-EU transactions within 10 days (ViDA timeline). [vatcalc.com]
• National platform data feeding into the supranational VIES database. [e-invoice.app]

16.4. Implications for Businesses

• Businesses already compliant with RO e-Factura have a strong foundation for ViDA compliance — they are already using EN 16931-based structured invoicing, XML formats, and digital clearance processes. [dddinvoices.com]
• Additional adjustments will be needed for cross-border transaction reporting, possible format updates (EN 16931-1:2026), and Peppol connectivity.
• Early adopters benefit from established processes, trained staff, and tested IT infrastructure that can be extended to ViDA requirements with incremental effort.
• The main risk is that Romania’s current national-only clearance model may need architectural changes to accommodate decentralized cross-border exchange networks mandated by ViDA. [arratech.com]

17. Impact on SMEs and Startups

17.1. Phased Onboarding

SMEs with annual turnover below EUR 500,000 have been granted an enforcement extension until 1 July 2026. [vatupdate.com]

Other staggered timelines:

• Small taxpayers for SAF-T: mandatory from January 2025. [rtcsuite.com]
• Full SAF-T (expanded sections): small/micro taxpayers from Q3 2026. [geseidl.ro]
• B2C for associations, foundations, special-regime farmers: from 1 July 2025. [theinvoicinghub.com]

17.2. Government Support & Free Tools

• SPV (Spațiul Privat Virtual): Free government web portal for uploading, downloading, and managing e-invoices. [e-invoice.app]
• ANAF DUK Validator: Free Java-based tool for validating XML invoices against the CIUS-RO schema before submission. [anaf.ro]
• XML-to-PDF conversion tool: Free ANAF tool for converting XML invoices to human-readable PDF format (updated February 2025). [mfinante.gov.ro]
• Signature verification tool: Free tool for verifying MFP seal on invoices (updated March 2026). [mfinante.gov.ro]
• Test environment: Available for testing API integration and invoice validation. [mfinante.gov.ro]
• ANAF website: Technical documentation, XSD schemas, schematron rules, example invoices. [mfinante.gov.ro]

17.3. Simplified Regimes & Threshold-Based Exemptions

• The EUR 500,000 turnover threshold provides an enforcement deferral (not exemption) for SMEs until July 2026. [vatupdate.com]
• Simplified invoices issued via fiscal cash registers meeting specific conditions are excluded from the e-Factura mandate. [marosavat.com]
• No permanent threshold-based exemption from the e-invoicing obligation has been legislated.

17.4. Subsidies or Financial Support Programs

No specific government grants, tax credits, or subsidies for e-invoicing compliance costs have been publicly announced. Romania’s NRRP includes digitalization measures, but these are primarily focused on the government’s own infrastructure. [thediplomat.ro]

17.5. Compliance Costs

• One-time costs: Software upgrades or acquisition, ERP integration/API development, employee training, digital certificate acquisition. Costs vary significantly — from near-zero for businesses using the free SPV portal to tens of thousands of EUR for complex ERP integrations.
• Ongoing costs: Commercial API service provider fees (variable), digital certificate renewal, maintenance and monitoring.
• Popular Romanian ERP solutions (Saga, WinMentor, Nexus, SmartBill) have released updated RO e-Factura modules, generally included in subscription pricing. [geseidl.ro]

17.6. Cash Flow & Operational Benefits

• Faster processing: Automated validation and digital delivery reduce invoice processing time.
• Pre-filled VAT returns: Reduce the effort required for VAT compliance.
• Elimination of paper: Reduced printing, mailing, and physical archiving costs.
• Earlier error detection: ANAF’s real-time validation catches errors at the point of issuance rather than during audits.
• Potential for faster VAT refunds: Though not formally legislated as an incentive, digital compliance reduces the risk profile and may facilitate refund processing.

17.7. Administrative Burden vs. Simplification

The initial burden on SMEs is significant — requiring IT investment, process changes, and staff training. However, the long-term simplification effects include reduced manual data entry, automated reconciliation, and elimination of paper-based processes. The government’s enforcement deferral for SMEs until July 2026 acknowledges this transitional burden. [vatcalc.com]

17.8. Market Impact

• Increased digitalization requirements create a level playing field — reducing opportunities for informal economy and tax evasion.
• Early adopters among SMEs gain competitive advantages through better process efficiency and data quality.
• Interoperability challenges exist for businesses dealing with non-Romanian partners, as the system is currently national-only without Peppol connectivity. [fonoa.com]

17.9. Official Assessments of SME Readiness

The EU Commission’s 2025 eInvoicing Country Sheet for Romania acknowledges the comprehensive mandate but does not provide a specific SME readiness assessment. Forvis Mazars noted that Romania is “on a downward trend” in VAT gap reduction, partly attributed to digitalization measures, though challenges remain for smaller businesses. [ec.europa.eu] [thediplomat.ro]

18. Official References & Sources

18.1. Government Portals

• RO e-Factura platform: https://efactura.mfinante.gov.ro/ [efactura.m…nte.gov.ro]
• ANAF website: https://www.anaf.ro/ [anaf.ro]
• Ministry of Finance (eFactura technical info): https://mfinante.gov.ro/web/efactura/informatii-tehnice [mfinante.gov.ro]
• ANAF SAF-T page: https://www.anaf.ro/anaf/internet/ANAF/despre_anaf/strategii_anaf/proiecte_digitalizare/saf_t/ [anaf.ro]

18.2. Legislative Texts

• OUG 120/2021: https://legislatie.just.ro/Public/DetaliiDocument/247243 [legislatie.just.ro]
• Council Implementing Decision (EU) 2023/1553: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023D1553 [eur-lex.europa.eu]
• Commission Proposal COM(2023) 329: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=COM:2023:329:FIN [eur-lex.europa.eu]

18.3. Technical Specifications

• CIUS-RO schematron artefacts, XSD, validators, examples: https://mfinante.gov.ro/web/efactura/informatii-tehnice [mfinante.gov.ro]
• SAF-T validator and documentation: https://www.anaf.ro/…/saf_t/ [anaf.ro]

18.4. Tax Authority Publications

• ANAF modifications to OUG 120/2021 by Law 296/2023: https://static.anaf.ro/static/10/Brasov/Brasov/factura_electronica.pdf [static.anaf.ro]
• ANAF Strategic Plan 2025–2028: https://www.anaf.ro/…/strategii_anaf [anaf.ro]

18.5. Advisory Firm Newsletters & Analysis

• Sovos: Romania B2B and B2C e-Invoicing Clarifications for 2026 [sovos.com]
• EY Romania: Proposal for Council implementing decision [ey.com]
• PwC Romania: RO e-TVA pre-filled statement adopted by GEO 70/2024 [pwc.ro]
• Forvis Mazars Romania: The VAT gap in the EU — Romania analysis [thediplomat.ro]
• DLA Piper: E-invoicing mandatory in Romania from 1 January 2024 [dlapiper.com]
• Fonoa: Romania E-invoicing Guide [fonoa.com]
• Marosa VAT: E-Invoicing in Romania: Complete Guide [marosavat.com]
• VATCalc: Romania B2B e-invoicing eFactură update [vatcalc.com]
• VATCalc: Romania e-VAT pre-filled returns update [vatcalc.com]
• VATupdate.com: https://www.vatupdate.com/ — multiple briefings referenced throughout. [vatupdate.com], [vatupdate.com]
• Tungsten Automation: Romania e-Invoicing Compliance Updates [tungstenau…mation.com]
• Thomson Reuters: Romania Regulatory Updates [europe.tho…euters.com]
• ecosio: ANAF RO e-Factura and e-invoicing in Romania [ecosio.com]
• EDICOM: Romania: Mandatory B2B and B2C e-Invoicing [edicomgroup.com]
• The Invoicing Hub: E-Invoicing in Romania [theinvoicinghub.com]
• European Commission eInvoicing Country Factsheet: 2025 Romania [ec.europa.eu]
• TPA Romania: SAF-T – What is it and who will be required to file from 2025? [tpa-group.ro]
• Fiscal Solutions: Romania e-Invoice Rules in 2026 [fiscal-req…ements.com]

18.6. Link Status

All links referenced above were verified as accessible based on web search results dated May–June 2026. Users should verify link accessibility at the time of access, as government portals may restructure content periodically.

19. Summary & Key Takeaways

19.1. Scope

• B2B, B2G, and B2C domestic transactions are all covered by the mandatory RO e-Factura mandate.
• Excluded: Intra-Community supplies, exports, supplies to non-VAT-registered non-established entities, simplified fiscal cash register receipts.
• From January 2026: supplies to non-established VAT-registered buyers are in scope (e-reporting + traditional delivery). [sovos.com]

19.2. Format

• Mandatory: XML in RO_CIUS format (UBL 2.1 or CII), compliant with EN 16931.
• Paper/PDF are no longer valid for in-scope B2B transactions since July 2024. [vatcalc.com]

19.3. Timeline

• B2G: Mandatory since July 2022.
• B2B: Mandatory since January 2024 (reporting), July 2024 (clearance).
• B2C: Mandatory since January 2025.
• SMEs (< EUR 500K): Enforcement from 1 July 2026. [vatupdate.com]
• Transmission deadline: 5 working days (from January 2026). [sovos.com]

19.4. How It Works

• Centralized clearance (CTC) model for B2B/B2G: invoice validated and sealed by ANAF before being legally valid.
• Post-issuance reporting for B2C (within 5 working days).
• Platform: RO e-Factura via SPV (Spațiul Privat Virtual).
• Dual digital reporting: RO e-Factura + SAF-T (D406). [ecosio.com]

19.5. Key Obligations

• Issue: All in-scope invoices via RO e-Factura within 5 working days.
• Receive: Download and process from SPV; recording a non-e-Factura invoice incurs 15% penalty.
• Report: SAF-T monthly/quarterly; e-TVA reconciliation monthly.
• Correct: Credit notes (381) and reversal invoices (380) via the platform.
• Archive: 10 years (25 for capital goods) in original XML with MFP seal. [fiscal-req…ements.com], [e-invoice.app]

19.6. Main Risks

• 15% of invoice value penalty for issuing/receiving invoices outside the platform (B2B). [fiscal-req…ements.com]
• RON 1,000–10,000 fines for late transmission (tiered by taxpayer size).
• SAF-T non-compliance fines (RON 1,000–5,000).
• e-TVA compliance notice non-response fines (RON 1,000–10,000).
• Operational disruption from invoice rejections (schema/validation failures).
• Potential loss of tax deduction rights if invoices are not properly processed through the system.

19.7. SME Implications

• Enforcement deferred to 1 July 2026 for SMEs with turnover < EUR 500,000. [vatupdate.com]
• Free tools available (SPV portal, validator, conversion tools). [mfinante.gov.ro]
• No specific subsidies or financial support programmes.
• Initial compliance burden is significant but yields long-term simplification.

19.8. ViDA / International Readiness

• Romania is well ahead of the ViDA timeline, having implemented CTC e-invoicing domestically since 2024.
• Will need to adapt for cross-border DRR by July 2030 and domestic alignment by December 2034.
• Key gaps: Peppol connectivity, EN 16931-1:2026 alignment, cross-border exchange network integration. [e-invoice.app], [vatupdate.com]

19.9. Critical Dates & Next Steps

Date	Milestone
1 July 2026	Full enforcement for SMEs (turnover < EUR 500,000)
31 December 2026	Expiry of EU Council derogation (unless ViDA applies earlier)
1 July 2030	ViDA: Cross-border B2B Digital Reporting Requirements
31 December 2034	ViDA: Domestic system alignment with EU standards

Recommended preparation steps:

• Ensure all domestic B2B/B2C/B2G invoices flow through RO e-Factura.
• Validate XML against the latest CIUS-RO schematron (v1.0.9+).
• Ensure SAF-T (D406) is filed accurately and on time (full format from 2026).
• Monitor e-TVA compliance notices and respond within 20 days.
• Begin planning for EN 16931-1:2026 format updates and future Peppol/ViDA connectivity.
• SMEs: use the remaining time before July 2026 to test, clean data, and integrate.

This analysis was compiled on 7 June 2026 based on the most recent publicly available sources. Given Romania’s frequent legislative amendments via Government Emergency Ordinances, readers are strongly advised to monitor official ANAF and Ministry of Finance publications for updates.

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• See also
  • E-Invoicing/Real Time Reporting – What can you find on VATupdate.com
  • Worldwide Upcoming E-Invoicing mandates, implementations and changes – Chronological
  • Country Profiles on E-Invoicing, E-Reporting, E-Transport, SAF-T Mandates, and ViDA Initiatives

• Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
• Join the LinkedIn Group on ”VAT in the Digital Age” (VIDA), click HERE

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