Briefing document & Podcast: E-Invoicing & E-Reporting in Moldova

• Domestic B2B (Business-to-Business) – All domestic B2B sales of goods and services will require e-invoicing via e-Factura. This is the core scope of the mandate. Currently, B2B e-invoicing is voluntary except for certain taxpayers designated by the tax authority (e.g. high-risk or large taxpayers on an official list), but as of 1 October 2026 it becomes mandatory for all B2B transactions between VAT-registered businesses in Moldova. If a company is VAT-registered and making a taxable supply locally, it will have to issue the invoice through the e-Factura platform instead of paper. Notably, suppliers to other businesses must use e-Factura even when the sale is taxed at 0% (e.g. exports) or exempt – the platform supports indicating VAT at zero or an exemption code, so zero-rated and exempt supplies are included in the e-invoicing scope (there is no blanket exemption for invoices with special VAT treatment). [sirius.expert] [vatupdate.com] [contabilsef.md]
• Domestic B2G (Business-to-Government) – Electronic invoicing for sales to public authorities has been mandatory for several years. Since January 2021 (phased in through 2023), any company supplying goods or services to Moldovan government entities (ministries, agencies, schools, hospitals, municipalities, etc.) must issue e-invoices via e-Factura; paper invoices are no longer accepted for public procurement. (Certain utilities and telecom services were initially excepted from this rule.) This B2G requirement has effectively served as a “proving ground” for the system and continues in the new framework. B2G transactions remain in scope of e-Factura (and in fact pioneered the mandate), with suppliers obliged to use the platform and comply with the local XML format and archiving rules for those invoices. [sirius.expert] [rtcsuite.com] [vatupdate.com]
• Domestic B2C (Business-to-Consumer) – Retail sales to consumers are not directly subject to the e-invoice clearance mandate, since consumers typically do not receive VAT invoices in the same way businesses do. Instead, Moldova is modernizing B2C transaction reporting through electronic receipts (“eBon”) and virtual cash registers rather than the e-Factura invoicing system. A new law (proposed in 2025 and expected to be implemented by 2026) will allow merchants to issue electronic fiscal receipts to consumers via smartphones or computers, with receipts delivered by email/SMS in lieu of paper slips. This “virtual cash register” system is intended to cover cash sales and B2C transactions, providing real-time data to tax authorities without generating a full e-invoice. Thus, B2C transactions fall under e-reporting via eReceipts (eBon) rather than e-invoicing via e-Factura. Traditional cash register receipt rules remain in force until eBon is fully adopted. If a B2C transaction does require an invoice (e.g. a consumer specifically requests a VAT invoice or in certain online sales), the seller can issue it in e-Factura, but this is not generally mandated. The focus for B2C is on implementing eBon receipts and linking these to the tax system in real time. (In short: the CTC framework encompasses B2C through electronic receipts, not clearance of every retail invoice.) [vatupdate.com] [kpmg.com], [cereport.eu] [rtcsuite.com]
• Intra-EU and Cross-Border B2B – Transactions that cross Moldovan borders are increasingly brought into the e-invoicing/e-reporting net. Although Moldova is not in the EU, new rules extend the mandate to many cross-border dealings. Effective 1 January 2025, Moldovan law requires e-Factura to be used for transactions with any business that “does not have fiscal relations with the Moldovan budget.” This phrasing covers cross-border B2B sales (exports) and certain other international operations. In practice, since 2025, if a Moldovan company sells to a foreign business (whether EU or non-EU), it is obliged to issue an electronic invoice through e-Factura for that supply. For example, a local exporter of goods must create a 0% VAT e-invoice in the system for its foreign customer. These invoices serve domestic VAT evidence purposes (and can be shared electronically, especially as Moldova connects to international networks – see Peppol integration below). Intra-EU acquisitions (imports) by Moldovan companies are handled differently: a foreign supplier cannot access Moldova’s e-Factura, so their invoice won’t be issued on the platform. The Moldovan buyer, however, may need to report such an import through e-Factura or a related e-reporting mechanism. While not explicitly labeled “e-reporting,” the 2025 legal changes imply that Moldovan taxpayers must document cross-border purchases as well – possibly by self-issuing an e-invoice for the reverse-charge transaction or by ensuring the data is captured in a report. (This is analogous to Italy’s approach where domestic businesses upload self-billed invoices for imports.) As of now, outbound cross-border B2B transactions are definitely in scope via e-Factura, and inbound transactions are at least recorded for VAT via normal returns (with potential future integration into the e-Factura system). [sirius.expert]
• Imports and Exports – Imports (goods brought into Moldova) require customs declarations but not an e-invoice from the foreign seller. The Moldovan buyer will account for import VAT via the VAT return or self-billing documents. There is no separate “import e-invoice” mandated yet beyond the buyer’s general obligation to have proper documentation. Exports (goods shipped out of Moldova) are treated as cross-border B2B sales – as noted, since 2025 these must be accompanied by an e-Factura invoice even though they are zero-rated. This ensures the tax authorities have a record of the export sale in real time. The export invoice in e-Factura can also facilitate any verification needed for VAT refund claims. [sirius.expert]
• Intra-Community (EU) Supplies and Acquisitions – Moldova is outside the EU, but it trades under similar principles. An “intra-EU supply” from Moldova’s perspective is just an export to an EU country (handled via e-Factura as above). An “intra-EU acquisition” is an import from an EU supplier; the Moldovan buyer must self-account for VAT. There is no separate e-invoice required from the EU supplier (they will issue their invoice per their own rules), but the Moldovan buyer must report the purchase. Currently, that reporting happens through the VAT return and supporting documents. As Moldova’s system evolves and with Peppol interoperability, it’s conceivable that in the future an EU supplier’s e-invoice could flow directly into Moldova’s system (via Peppol network), but at present the buyer likely needs to ensure the transaction is recorded (e.g. by generating an electronic self-invoice or keeping the foreign invoice on file). [sovos.com]
• Cross-Border B2B Services – If a Moldovan company provides services to a foreign client (an export of services), this falls under the cross-border B2B scope and an e-Factura invoice should be issued (with VAT exemption if applicable). Conversely, if a Moldovan company receives services from abroad (subject to reverse charge VAT), the service is not invoiced via e-Factura by the foreign provider. The Moldovan recipient will account for VAT internally. There is no explicit mandate (yet) to create a self-billing e-invoice for such imports of services, but the broad language of including transactions with non-residents suggests that even these could be voluntarily logged in e-Factura for completeness. (In practice, most companies will simply handle it via the VAT return unless guidance emerges requiring an entry in e-Factura.) [sirius.expert]

• Self-Billing – Self-billing (where the buyer issues the invoice on behalf of the supplier) is not explicitly excluded from Moldova’s e-invoicing framework. Moldovan VAT law generally permits self-billing given mutual agreement, similar to EU practice. Under the new system, a self-billed invoice would also need to be recorded in e-Factura to be valid. In practice, this likely means the buyer would coordinate with the supplier to ensure the invoice is created on the platform. The e-Factura system allows a user to act as “Furnizor” (supplier) or “Cumpărător” (buyer) in transactions. A self-billing arrangement might work by the buyer preparing the invoice data and the supplier (or system) approving it. There is no separate module for self-billing; instead, the transacting parties must still produce an e-invoice in the system. For example, if Company A (buyer) self-bills on behalf of Supplier B, they must ensure an e-invoice is generated (with B as supplier and A as buyer) in e-Factura – likely by B’s account or a shared access – so that the tax authority has the record. The invoice should also contain the legend or indicator that it was issued by the buyer (self-billing). In summary, self-billing is allowed but must also pass through the e-Factura platform to count as an official invoice, with the same content and digital signing requirements. The buyer’s system might initiate it, but the platform will still require the supplier’s authorization (or at least their registration) to finalize it. Companies using self-billing will need to set up appropriate workflows within e-Factura, but no exemption from the mandate is provided – self-billed invoices are in scope and subject to the same rules. [legis.md], [legis.md]
• Triangulation and Chain Transactions – Triangulation (three-party chain transactions) and other complex supply chains do not receive any special exclusion in the Moldovan e-invoicing regime. The general rule is that each taxable supply involving a Moldovan entity must be documented with an e-invoice. If multiple companies are involved in a chain, each link where a Moldovan VAT-registered business is the seller must issue an e-Factura invoice to its customer. For example, in a domestic chain where A sells to B who then sells to C (with A delivering directly to C), A must e-invoice B, and B must e-invoice C – both invoices go through the system as separate transactions. The platform doesn’t have a special triangulation document; companies should handle these as normal sales invoices. In cross-border chains (e.g., EU triangulation involving a Moldovan party), the Moldovan leg must comply with e-invoicing. So, if a Moldova business is the intermediate trader purchasing from one foreign company and selling to another, its purchase from abroad is reported (as described above) and its resale (export) must be e-invoiced. There is no exception for chain transactions – they are treated like any other sale/purchase for e-invoice purposes. The tax authority will want each individual supply to be traceable via e-Factura if it touches the Moldovan VAT system. [sirius.expert]
• Special VAT Regimes (e.g. margin schemes, travel agent scheme, etc.) – There is no explicit carve-out in the e-invoicing mandate for transactions under special VAT regimes. If a business operates under a special scheme (for instance, a travel agency using the margin scheme, or a second-hand goods dealer under a margin scheme), they are still a taxable person and must issue invoices for their sales. These invoices too will fall under e-Factura if the person is within scope. The only difference is that such invoices might require certain notations (for example, “VAT applied on margin – not deductible” on a margin scheme invoice). The e-Factura system supports including necessary text in invoice details, and the expectation is that even special-regime invoices be electronic. No exemption is provided based on the VAT regime – the mandate is generally applied across the board to all VAT-registered taxpayers’ sales. For example, a tour operator selling a package under the travel scheme would still issue an e-invoice to its business customer (or even consumer, if needed), even though the VAT is calculated specially. The content of the e-invoice will reflect the scheme (as per existing invoice rules), but it must be delivered through the platform. Similarly, any other sector-specific invoicing (like agricultural flat rate, etc.) must use e-Factura if an invoice is issued.

2. Taxable Persons in Scope

• Established Entities (Moldovan businesses) – All companies and individuals registered for VAT in Moldova and conducting taxable activities will fall under the mandate. This includes resident companies (LLCs, JSCs), sole proprietors, and any other legal persons registered as VAT payers. As of the full mandate (Oct 2026), if you are a Moldovan VAT-registered seller, you must issue your invoices electronically via e-Factura for B2B and B2G transactions. Currently, many domestic businesses are already using e-Factura voluntarily, and some are mandated (see below), but by the go-live date virtually all must use it. This covers large companies as well as SMEs (with no size threshold for mandate apart from the VAT registration threshold). Organizations like public institutions on the buying side are on the platform as recipients, but they typically do not issue invoices (they issue purchase orders, etc., so the mandate mainly concerns suppliers issuing invoices to them). There is no sectoral exemption for established businesses – manufacturers, retailers, service providers, etc., all are included if they issue VAT invoices. The tax authority has even been adding companies to a mandatory e-invoicing list using risk criteria in recent years, which has compelled many domestic firms to adopt e-Factura ahead of the universal mandate. As of September 2024, 69 entities were on that mandatory list (mostly those deemed high VAT fraud risk or large volume with suspicious profiles). By 2026, that piecemeal approach will be superseded by a blanket requirement for all. [sovos.com], [sovos.com] [contabilsef.md], [contabilsef.md] [contabilsef.md]
• Non-Established Entities with a Moldovan VAT Registration – Foreign businesses that are not physically established in Moldova but have registered for Moldovan VAT (for example, via a fiscal representative or direct registration to trade in Moldova) are also in scope. If such a business is the supplier in a transaction that requires a Moldovan invoice (e.g. a non-resident company supplying goods locally and registered for VAT), it must use e-Factura just like a local company. Moldovan law does allow non-established taxpayers to register for VAT (especially if making local supplies), and once registered they have the same obligations as resident taxpayers. The e-Factura platform is accessible to non-resident registrants – typically via the same online portal, using credentials obtained through their representative or the government’s digital services login. These non-established taxable persons must ensure they can digitally sign invoices and submit them. There is no exemption for foreign companies: if they are liable to issue a Moldovan VAT invoice, they need to do so electronically. For instance, if a foreign company has a fixed place of business or VAT number in Moldova and sells to a local client, the invoice must be through e-Factura. (The platform and authorities may provide guidance for such users, but procedurally they are included in the mandate scope.) [sovos.com]
• Foreign Entities without a Fixed Establishment or VAT Registration – Foreign entities that do not have a Moldovan VAT registration – i.e., those merely exporting to Moldova (with the import handled by the local buyer) – are outside the direct scope of issuing e-invoices, because they cannot access the system. Instead, the onus is on the local buyer to handle VAT reporting (reverse charge or import VAT). For example, a German company selling goods to a Moldovan importer will issue a German invoice (not via e-Factura), and the Moldovan importer will pay import VAT at customs and record the purchase. The foreign seller in that scenario isn’t expected to use e-Factura (they wouldn’t even have login credentials). Thus, the mandate covers foreign suppliers only if they have taken on a Moldovan VAT registration; if they haven’t, they are not directly subject to Moldovan e-invoicing obligations. However, note the new rule from 2025 requiring e-Factura for “transactions with entities that have no fiscal relationship in Moldova” – this rule actually places responsibility on the Moldovan side of such deals. In practice, that means if a Moldovan company buys from a foreign entity (which itself isn’t registered locally), the Moldovan company might need to create an electronic document to record that purchase (ensuring the tax authority sees the transaction). This is an e-reporting obligation on the buyer, not a direct requirement on the unregistered foreign seller. In summary, foreign companies without any Moldova VAT registration do not issue e-Factura invoices, but their transactions with Moldovan parties still get captured via the Moldovan side (through self-billing or through the VAT return). [sirius.expert]
• Exemptions and Special Cases – Very few exemptions by sector or entity type exist. The e-invoicing law does not exempt specific industries (aside from the early B2G utility exceptions, which are temporary). Financial institutions and insurers (who mostly have VAT-exempt output) usually do not issue VAT invoices for their exempt services, so they might largely avoid e-Factura simply because they have no taxable invoices. But if they do issue an invoice (say for a taxable auxiliary service or a B2B sale of an asset), they must use e-Factura. Charitable and nonprofit organizations that are not VAT-registered are outside the scope (since they don’t issue fiscal invoices). Small businesses below the VAT registration threshold are effectively exempt because they don’t charge VAT or issue fiscal invoices; they usually just provide receipts. The VAT registration threshold in Moldova is currently MDL 1.2 million annual turnover (about €70k) and is proposed to increase to MDL 1.5 million. Businesses below that threshold generally do not register for VAT and hence will not be forced onto e-Factura – this functions as an indirect exemption for micro-enterprises. (If such a small business voluntarily registers for VAT, then they join the mandate like any other taxpayer.) There is also an optional participation model: any company, even if not yet mandated, may use e-Factura voluntarily. Indeed, many SME taxpayers have been voluntarily using the system to issue invoices to willing counterparts since 2014. This voluntary use has been encouraged to spread adoption. Through 2025, usage remains optional for those not covered by B2G or the risk list, but by 2026 it becomes obligatory. After 2026, voluntary use is moot (it’s required), but one could imagine that a very small business that isn’t technically obliged (e.g. not VAT-registered) might still choose to use e-Factura to issue invoices – this is possible if they sign up for the service, though typically non-VAT-registered entities use simpler receipts. [vatupdate.com] [sovos.com]
• Sector-specific Rules – Apart from the utilities exceptions in the early B2G phase (where energy, gas, communal services, and telecom were temporarily allowed to continue paper invoicing to government), there are no permanent sector-specific exemptions. Some sectors have additional reporting systems (e.g. oil & gas might have fuel sale reporting), but they do not replace e-Factura for invoicing. One noteworthy change: as of 2025, suppliers involved in certain international aid or investment projects must use e-Factura. That is, if a company makes supplies under donor-funded projects (which might be VAT-exempt by treaty), they are now included in the mandatory e-invoice scope – previously they might have used special paper invoices; now they must issue them electronically. This was an expansion to improve transparency in those projects. Another special case: farmers under special VAT regimes (like the delayed VAT accounting for agriculture) still have to issue invoices for their sales, so if they are VAT-registered, they too join e-Factura – the law makes no distinction. [sirius.expert]
• Optional/Voluntary usage prior to mandate – It’s worth noting that before the mandatory dates, many companies have joined e-Factura voluntarily. The system has been open to all taxpayers since 2014, and the government has published guides and lists to encourage adoption. The State Tax Service periodically updates the official list of taxpayers required to use e-Factura (for compliance reasons) and also those who joined voluntarily. Through these efforts, a segment of businesses is already experienced with the platform, easing the transition. For example, by 2025, virtually all regular suppliers to government (including many SMEs) are on e-Factura due to the B2G rule, and dozens of private firms were roped in via risk-based selection. Others joined because their trading partners encouraged it. This means that at the time of full mandate in 2026, a lot of the medium and large taxpayers in Moldova will already be on-boarded, leaving mainly the smaller or more isolated businesses to join. [sovos.com] [sirius.expert] [contabilsef.md], [contabilsef.md]

3. Implementation Timeline

• 2014 – Introduction of e-Factura (Voluntary Phase): Moldova launched the e-Factura platform in 2014 as a voluntary electronic invoicing service for businesses. In this early phase, companies could choose to issue invoices through the system, but it was not obligatory. This allowed the State Tax Service (STS) to test and improve the system. Throughout the late 2010s, thousands of invoices were issued voluntarily and the system gained features. The legal framework to recognize electronic invoices as equivalent to paper was established (ensuring e-invoices have full legal value). Also in this period, risk-based enforcement began: the STS in 2018 set criteria to identify high-risk VAT taxpayers and in 2019 issued an order mandating certain listed companies to use e-Factura. This targeted approach functioned as an incremental step – by forcing risky companies to invoice through the platform, the tax authority could gain real-time visibility into their transactions. So, from 2019 onward, a published list of firms (updated a few times each year) were legally obliged to use e-Factura for all their sales on the domestic market. This list mechanism effectively launched a pilot mandate for select businesses before any general law was passed. [sovos.com], [sovos.com] [egov.md], [egov.md] [contabilsef.md], [contabilsef.md] [sirius.expert]
• 2020 – Platform Regulation and Industrial Rollout: In mid-2020, the STS formally approved the Regulation for the automated system “e-Factura” (Order 317/2020), which set out how the platform operates, user rights, invoice life-cycle (draft, signed, accepted, etc.), and legal statuses of electronic invoices. By July 1, 2020, e-Factura was declared to be in “industrial exploitation,” meaning it was fully operational for widespread use. This regulatory clarity paved the way for expanding mandates. At the same time, Government also mandated that from 2021, electronic invoicing would be compulsory in the public procurement sphere. [legis.md] [sirius.expert]
• 2021 – B2G Mandate Effective: Starting January 2021, suppliers to the government were required by law to issue only e-invoices (no paper) for their sales to public entities. This meant if a company participated in a public tender or had a state contract, it must be on e-Factura. The STS and Ministry of Finance supported public sector and vendor onboarding for this transition. By 2023, B2G e-invoicing was well-established. (Some sources cite 2023 as the date B2G became fully compulsory – likely because initial enforcement may have been lenient in 2021–2022 and became strict by 2023, and also the inclusion of the National Health Insurance Fund (CNAM) contracts by 2023.) In practice, 2021–2022 was a grace period for B2G: the rule existed, but some entities took time to comply. By 2023, B2G e-invoicing was universally enforced, marking the first broad segment under mandatory e-Factura usage. [sirius.expert] [sovos.com]
• 2021–2024 – Gradual Expansion and Pilots: During this period, apart from B2G, the authorities continued to enlarge the circle of mandatory users via the risk-based list. For example, new batches of taxpayers were added in March 2024 and March 2025 to the list of those obligated to use e-Factura. These were often companies flagged for tax non-compliance risks – by forcing them onto e-Factura, the tax service could monitor their invoicing closely. Meanwhile, Moldova engaged in international e-invoicing pilots: in Dec 2021, an e-delivery pilot with Ukraine was launched to test cross-border exchange via the EU’s Peppol network. This pilot demonstrated that a Moldova-issued e-invoice could be transmitted to a foreign partner and vice versa, presaging future cross-border capabilities. Throughout 2022 and 2023, development continued on integrating Peppol standards and preparing technical documentation for a broader mandate. [sirius.expert] [sovos.com]
• Mid-2024 – Legal Framework for Expansion: In July 2024, the Parliament adopted Law No. 214/2024 (Fiscal and Customs Policy for 2025) which included significant e-invoicing provisions. This law amended the Fiscal Code Article 117 to extend mandatory e-invoicing beyond the existing cases. Notably, it added that from 1 January 2025, e-Factura use is compulsory for transactions with parties that are not registered in Moldova’s tax system, and for supplies under international aid projects. Essentially, this brought cross-border B2B and donor project invoices into mandatory scope starting 2025. The same law also envisaged the eventual repeal (by Jan 2026) of a provision that tied VAT deductions to having an e-invoice from listed suppliers – implying that by 2026 all suppliers should be using e-Factura, making that specific enforcement mechanism unnecessary. In parallel, proposals were introduced (and later passed) to enable virtual cash registers and e-receipts (eBon) for B2C, indicating that by 2025–2026, B2C would have its digital reporting channel as well. Also in late 2024, the government and STS likely drafted secondary regulations and technical specs for the full B2B mandate. [contabilsef.md] [sirius.expert] [contabilsef.md], [contabilsef.md] [kpmg.com], [moldpres.md]
• H2 2025 – Finalize Regulations & Documentation: The Ministry of Finance has outlined that in H2 (second half) of 2025, the regulatory and technical documentation for mandatory B2B e-invoicing will be completed and published. This includes final specifications, API documentation for software providers, any remaining legislative adjustments, and guidance for taxpayers. Essentially, the second half of 2025 is dedicated to preparing all stakeholders for the imminent mandate. The authorities may also use this time for outreach, training seminars, and system scaling. Indeed, by late 2025 many signals of the upcoming mandate were public: for example, an EY global tracker noted Moldova’s plan and timeline in early January 2026 publications, and local news in December 2025 discussed fiscal framework changes effective 2026 (though focusing on technical tax rules rather than the e-invoice mandate explicitly). [vatcalc.com], [vatcalc.com] [mf.gov.md]
• January 1, 2026 – Pilot Phase for B2B Mandate Begins: A pilot phase starts in January 2026 for the broader B2B e-invoicing mandate. During Q1–Q3 2026, businesses are expected to trial the mandatory processes. This pilot is essentially a soft launch: companies that are ready can begin issuing all their B2B invoices through e-Factura under the new requirements, and any teething issues can be addressed. The pilot is voluntary in the sense that penalties for non-compliance may not yet be enforced for everyone, but it’s strongly encouraged that businesses onboard by this date. Large taxpayers and those already on the platform will likely start full electronic invoicing from day one of the pilot. The STS will monitor and possibly assist late adopters in this period. According to the Ministry of Finance’s announced schedule, the pilot runs from January up to October 1, 2026 for the B2B sector. This roughly 9-month pilot gives companies time to adapt their ERP systems, integrate digital signatures, and adjust business processes ahead of the hard mandate. It also allows the government to iron out any remaining technical issues in real-world use. (It’s unclear if this pilot is formally structured or just a lenient enforcement period; in practice it means the requirement exists but with leniency.) [vatupdate.com], [rtcsuite.com] [vatcalc.com]
• October 1, 2026 – Full Mandatory Go-Live for B2B: On 1 October 2026, electronic invoicing becomes legally mandatory for all B2B transactions in Moldova. This is the official go-live date of the full mandate as confirmed by the Ministry of Finance. From this date, all VAT-registered businesses must issue invoices electronically, and paper invoices for B2B are no longer accepted (they won’t be considered valid for VAT or legal purposes). The transition period/grace period ends at this point. The e-Factura platform will by then be the exclusive channel for domestic B2B invoicing and reporting. Enforcement (penalties for non-compliance) will fully apply after this date. Effectively, 1 Oct 2026 is the “CTC switch-on” date when Moldova pivots from a voluntary/hybrid system to a de facto clearance system for all business invoices. [vatupdate.com], [vatcalc.com] [sirius.expert]
• Post-2026 – Ongoing Developments: There may be some staged follow-ups even after October 2026. For instance, if any specific sector was given extra time (no such sector is confirmed as of now, but hypothetically SMEs could get a slight extension – however no public timeline suggests a stagger by sector or size; the mandate appears to hit everyone at once in Oct 2026). The timeline might differentiate transaction categories: by 2026, domestic B2B and exports are covered; what remains is possibly B2C e-reporting which could have its own enforcement timeline. The eBon electronic receipt system, once the law is passed, will likely have a timeline (e.g. voluntary in 2025, then gradually mandatory for retail in 2026–27). Additionally, integration with EU’s ViDA (Vehicle for Digital Reporting and e-Invoicing in Europe) by 2030s is likely in Moldova’s strategy, given the Peppol steps taken. For now, the focus is on 2026 goals. After go-live, there might be a short grace period (perhaps a few months) where authorities might issue warnings instead of fines for laggards, but no official “grace” beyond the pilot has been announced. In essence, companies should treat Oct 1, 2026 as a hard deadline. [vatcalc.com]

• B2G by 2021–2023 proved the system in a controlled environment.
• Risky taxpayers were forced on early to prevent fraud and test mass usage.
• Legal changes in 2024 set the stage for universal adoption by 2026.
• A generous pilot in 2026 allows adaptation.
• Final enforceable mandate by late 2026.

4. Technical & Functional Requirements

• E-invoice Format: Moldova’s e-invoice uses a standardized XML format defined by the State Tax Service. This is often referred to as the “Factura Fiscală electronică” schema. Invoices must be issued in this XML format when submitted to e-Factura. The format is a local schema aligned with Moldova’s national invoicing requirements – essentially digitizing the fields of the paper invoice form (known as “Factura fiscală”) and adding electronic metadata. The e-Factura XML contains all necessary invoice elements: supplier and buyer information (tax identification numbers, names, addresses), invoice number and date, line item details (description, quantity, unit price), VAT rates and amounts per line, total amount, etc., as well as additional fields for electronic processing (document identifiers, statuses, timestamps). It is not explicitly UBL or PEPPOL BIS 3.0 at this time, but Moldova is working to ensure interoperability with European standards. In fact, the system is being made Peppol-compatible: Moldova has piloted use of the Peppol eDelivery network, implying that its data model can be mapped to Peppol BIS format for cross-border exchange. However, for domestic purposes, taxpayers will generally produce invoices in the required Moldovan XML structure and submit that to the portal. Many companies will use the web interface where they fill a form (which then generates the XML behind the scenes). Those with IT systems can integrate via API to submit XML directly. The electronic format is legally equivalent to the paper invoice format – the system ensures the e-invoice contains all information the law requires on an invoice. There is also a PDF rendering available: the portal can generate a PDF version of the XML invoice for human readability (complete with QR code, etc.), which can be used as a printout when needed. But the authoritative record is the XML data itself. [sovos.com] [vatupdate.com], [sovos.com] [egov.md], [egov.md] [legis.md], [legis.md]
• E-reporting Format (for non-invoice data): Alongside e-invoices, Moldova’s CTC approach encompasses e-reporting of transactions that are not invoiced (notably B2C retail). The e-receipt (eBon) format will be different from a full invoice XML. The eBon data likely contains receipt details (seller, date/time, items, price, tax, etc.) in a JSON or simplified XML sent in real-time to the tax authority’s server from the virtual cash register app. This system is still being implemented – technical specifications for eBon have yet to be published publicly, but it will follow the international trend of using secure APIs for point-of-sale to government reporting. For the purpose of e-invoicing obligations as asked in this analysis, eBon is a parallel format. Another aspect of e-reporting is the summary reporting: if any transactions remain outside e-Factura, authorities might require periodic reports. For example, currently, companies file VAT returns and listings of sales/purchases (the “Registrul livrărilor/procurărilor” as annexes). With full e-invoicing, those listings might eventually be auto-generated, but until then, taxpayers continue to file them. There isn’t a separate “digital reporting” schema like SAF-T in place yet in Moldova (though Moldova is aware of such concepts via EU initiatives). So in summary: the primary format businesses need to worry about is the e-Factura XML for invoices. The e-receipt format will concern retailers once mandated, and any periodic aggregated report formats remain the same as existing VAT return forms for now. [cereport.eu], [moldpres.md]
• Data Content and Mandatory Fields: Every e-invoice must include all the legally required fields of a Moldovan VAT invoice. This includes: [legis.md], [legis.md]
  • Invoice header information: unique series and number (assigned by the system, see below), date of issuance, type of operation (sale, self-invoice, etc., if applicable).
  • Supplier (Seller) details: Tax Identification Number (IDNO for companies), name, address, VAT registration status. In e-Factura, when you input the buyer’s or seller’s tax code, the system auto-fetches the entity’s name to avoid errors. [legis.md]
  • Buyer (Customer) details: Tax ID or personal ID (if individual), name, address. The system will validate the buyer’s existence; it will warn if a buyer’s ID is not found or if the buyer is a public institution requiring special handling (see B2G specifics). [legis.md]
  • Line items: description of goods or services, unit of measure, quantity, unit price, and value. Each line will have a VAT rate applied (standard 20%, reduced 8% if applicable, 0% or VAT exempt). The XML has fields for VAT rate and VAT amount per line.
  • Totals: total amount without VAT, total VAT amount, and total with VAT. The invoice can show breakdown by VAT rate category. All these must compute correctly – the system performs arithmetic checks to validate totals match the sum of lines.
  • Additional info: Invoice currency (Moldovan lei by default, though multi-currency invoices are presumably allowed – possibly the system requires MDL for VAT reporting but can capture equivalent in foreign currency if needed for cross-border), reference to any order or contract if provided, and for certain cases specific notes (e.g., “Self-billing” note, or “VAT Reverse Charge” note, etc. if applicable to that transaction). The platform supports adding explanatory text or attachments to an invoice. For instance, if goods are delivered with a dispatch note, the dispatch note number can be indicated, and you can attach a PDF of that document to the e-invoice record. [legis.md]
  • Signatures and statuses: these are not conventional invoice fields but part of the electronic record. The invoice will carry information on whether it’s signed by the supplier and buyer, its status (draft, sent, accepted, rejected, cancelled, etc.), and a timestamp of submission.
  The mandatory fields essentially mirror those of a paper invoice as per Article 117^1 of the Fiscal Code and Ministry of Finance Order 118/2017 (which defined the paper invoice format). E-Factura enforces these: for example, you cannot submit an invoice without specifying a buyer, or without line details. If any required field is missing, the system will not allow final signing. Thus, compliance with field requirements is guaranteed by the platform’s design – it will prompt the user to fill in all necessary data. [legis.md], [legis.md]
• Validation Rules: The e-Factura system performs multiple validation checks both at the time of invoice preparation and upon submission. Some key validation rules include:
  • Tax ID validation: When entering the parties’ IDs, the system checks them against the national database. It will alert if, say, the buyer’s IDNO is not found or if the taxpayer is inactive (e.g., deregistered for VAT). It also knows if the buyer is a budget entity (which triggers a requirement that the supplier must have the treasury contract number included). For example, if you try to invoice a government entity, the system expects a public procurement contract reference due to art.117(12) of the Fiscal Code; e-Factura integrates with the Treasury system to validate contract numbers. [legis.md], [legis.md] [legis.md]
  • Arithmetic checks: The system automatically calculates line totals and VAT and ensures the totals add up. It will flag discrepancies (like if rounding causes a minor mismatch). This reduces human error and ensures the invoice data is internally consistent. [egov.md]
  • Unique numbering: The system controls the assignment of invoice numbers (each e-invoice gets a unique series/number when signed). It guarantees no duplicate invoice numbers can occur from the same supplier. This replaces the old paper practice of pre-printed invoice ranges. If a user tries to incorrectly assign numbers or create a duplicate, the platform would prevent it. [legis.md], [legis.md]
  • Date rules: The invoice issue date (data eliberării) is constrained by the system. Currently, e-Factura allows the invoice date to be the current date or up to 10 calendar days in the future (to accommodate post-dating slightly). It does not allow setting an invoice date far in the past or far in the future beyond that tolerance. Additionally, if an invoice is signed on a certain date, the system ensures the “eliberare” date is not earlier than the signature date (to avoid back-dating after the fact). Violating these rules (e.g., trying to create an invoice with a date last month) will either be blocked or result in an invoice needing cancellation. [legis.md]
  • Signature checks: The platform ensures that invoices are digitally signed before they attain a final “issued” status. If an invoice remains unsigned (a draft), it’s not counted as issued. Also, if buyer signature is required (in long cycle mode), until the buyer signs, the invoice is marked pending acceptance, not fully valid. If the buyer rejects an invoice, it is flagged and essentially invalid for VAT (and should be corrected and re-issued). [legis.md], [legis.md]
  • Duplicate prevention: The system likely prevents uploading the exact same XML twice for the same supplier (to avoid accidental double issuance of the same invoice).
  • Mandatory e-invoice enforcement: For those on the mandatory list pre-2026, the STS cross-checks that they indeed issue invoices through the system. If they were to issue paper invoices, those are not recognized for VAT (the buyer can’t deduct VAT on a paper invoice from a listed supplier). After 2026, this principle extends – a buyer’s VAT deduction requires an e-invoice in the system. This “validation” is more at enforcement level: essentially if a company tries to operate outside the system, their customers will complain or lose credit, prompting enforcement. [sirius.expert]
  In summary, the platform automates validation to a high degree, ensuring data quality and compliance (which is a major goal: to eliminate common errors and fraud like fake invoices). The government notes that e-Factura “reduces the risk of falsification… avoids errors… and ensures immediate registration”, highlighting that built-in rules catch mistakes upfront. [egov.md], [egov.md]
• Digital Signature and Integrity: Every e-invoice in Moldova’s system must be digitally signed to ensure authenticity and integrity. The law on electronic document and signature (Law 91/2014) and the e-Factura Regulation require use of an advanced qualified electronic signature on invoices. In practice, this means: [legis.md], [legis.md]
  • The supplier (issuer) signs the invoice electronically within e-Factura. Companies typically obtain a qualified digital signature certificate (often issued by an accredited provider in Moldova). The signing can be done by the responsible person (e.g., director or chief accountant) using an USB token or through the Government’s MSign service integrated in the portal. E-Factura supports either one or two signatures from the supplier side, based on internal controls (some companies require two officials to sign an invoice, which the system can accommodate). Once the supplier signs, the invoice is considered issued (if the “short cycle” is used) or sent to buyer for counter-signing (if “long cycle”). [legis.md], [legis.md]
  • The buyer may also sign the invoice electronically in the case of “ciclul lung” (long cycle) processing. In a long cycle, after the supplier signs and sends it, the buyer logs in and applies their qualified e-signature to acknowledge/accept the invoice. This dual-signature process is mandated for public sector buyers – they must sign to confirm receipt (similar to signing a paper invoice). In B2B, buyer signature is optional but available; if the buyer doesn’t e-sign, the invoice can still be considered valid after supplier signature (“short cycle”). However, even in short cycle (where the buyer doesn’t sign electronically), the invoice’s integrity is protected by the supplier’s signature and the system’s audit trail. [legis.md] [legis.md], [legis.md]
  • Integrity and authenticity: Once signed, the invoice’s content is locked. The digital signature ensures that any tampering would invalidate the signature. The system also maintains an audit log of changes in status. The combination of digital signatures and the centralized system provides a high level of assurance that the invoice is genuine and unaltered – satisfying the EU-standard requirements of authenticity of origin and integrity of content for electronic invoices.
  • Signature storage: E-Factura attaches the digital signatures to the invoice record (likely in XML DSig format). If one prints the invoice, the print will note that an electronic signature was applied by X person on Y date. Also, printed copies carry a QR code or bar code linking to the electronic record. [legis.md]
  • All users of e-Factura (supplier or buyer) must authenticate via the government’s secure authentication service (MPass) and have roles assigned (director, accountant, etc.). Only authorized users can sign or send invoices for a company, which also enforces integrity. [legis.md], [legis.md]
  In short, applying a valid digital signature is mandatory for invoice issuance – an unsigned draft has no fiscal value. This guarantees that invoices meet legal requirements of authenticity (proving who issued it) and integrity (content cannot be changed unnoticed), which is critical for both trust and audit purposes. The e-Factura regulation explicitly equates an e-invoice signed with a qualified signature to a paper invoice signed and stamped traditionally. In fact, a fully electronic invoice (signed by supplier and possibly buyer) is considered the original invoice, whereas any paper printout is just a copy for reference. [legis.md], [legis.md] [legis.md]
• Real-time or Near Real-time operation: Moldova’s model is essentially a real-time clearance system for e-invoices. The workflow is as follows:
  • The supplier creates an invoice (via API or on the portal) and submits it to the e-Factura central platform in real-time. When they hit “Sign & Send”, the data goes to the STS system immediately and is stored/registered. [egov.md]
  • If the buyer is configured for full electronic receipt (long cycle), the invoice appears instantly in the buyer’s e-Factura account for review. The buyer can then accept (sign) or reject it online. If accepted (signed by buyer), that signature is also captured in real-time and the invoice status flips to “finished” (finalized). If rejected, the invoice is marked rejected and the supplier is notified immediately to potentially issue a corrected invoice. [legis.md] [legis.md], [legis.md]
  • If the buyer is not on the platform or not using the electronic acceptance (short cycle), the invoice is considered finalized for tax purposes as soon as the supplier signs and the system generates an invoice number and “Finisat” status. In that case, the supplier typically prints a copy to give the buyer for their records (the system notes that the original is electronic and stored). [legis.md], [legis.md]
  • The tax authority effectively receives the invoice data in real-time at the moment of issuance. There is no separate reporting step later; submission to the platform is the reporting. This is why it’s called a clearance model – the tax service’s system is in the loop of invoice exchange, not afterward. In practical terms, the moment an invoice is signed on e-Factura, it’s “cleared” – it has an official number and is available to the tax authority for audit or VAT processing.
  • Deadlines: Because it’s clearance, there isn’t a grace period of X days to report the invoice – you must issue it through the system at the time of the transaction. In the old system, one might have 5 days to issue an invoice after a supply; under clearance, you effectively need to issue at the time of supply. (Romania, for instance, gave a 5-day deadline for e-invoice reporting, but Moldova’s approach is direct issuance, so no separate deadline need be defined beyond the general rule “invoice by the next working day after delivery” which is met by using e-Factura immediately.) Thus, invoices are essentially in real-time. If a company somehow issues an invoice late, that is a compliance violation – previously, the law said not reporting within 5 days could be penalized, but once mandatory e-Factura is in place, that scenario should not happen if processes are followed.
  • For e-reporting of receipts (eBon), the design is also real-time. A virtual cash register will send each receipt to the authority’s server at the moment of issuance (or batch them in near-real-time if connectivity issues). The goal is continuous reporting of retail sales. [moldpres.md], [cereport.eu]
  • Monthly summaries: There is no requirement to submit monthly invoice summaries because the tax authority is already getting each invoice. However, businesses must still submit the periodic VAT return (monthly or quarterly depending on turnover). The VAT return could eventually be pre-filled (see section 10), but until then, companies use their internal records (which match e-Factura records) to compile the return. One exception in reporting is if any sector or specific data not covered by e-invoices needs a summary – for example, companies currently submit a monthly summary of delivered goods under certain simplified regimes. With e-invoices capturing everything, those may be phased out. Also notable: as of Jan 2026, a simplified VAT declaration exists for energy traders, standardizing how they report domestic vs cross-border energy sales. But that pertains to how VAT is self-accounted (reverse-charged) in that sector, not to invoicing itself (they still invoice via e-Factura but handle VAT in a unified way). [vatupdate.com]
  In effect, the e-Factura system operates as a clearance platform with real-time exchange and government access. From a functional perspective, the workflow for a fully compliant invoice is near-instantaneous data transmission to the STS. This provides timely information for audit and potentially for pre-filling VAT returns in future. It also means businesses need an internet connection and ability to use the platform at the time of invoicing (or soon after delivering goods, at least the same day). The days of sending invoices in batches at month-end are over – they must be entered as they are issued.

5. Transmission & Workflow

• Central Platform (Clearance Model): Moldova’s solution is a single central e-invoicing platform (“SIA e-Factura”) operated by the State Tax Service (STS). All e-invoices are either created directly on this platform or sent to it via API from external systems. The STS platform acts as the hub through which invoices flow. When a supplier issues an invoice, they are essentially uploading it to the STS’s system; the buyer then retrieves it from that system (if using long-cycle electronic acceptance), or at minimum the invoice is stored there for audit. Unlike some countries where invoices might be exchanged peer-to-peer and only reported later, in Moldova the tax authority’s system is in the middle of the exchange (clearance). This ensures the authority receives the data in real time. [legis.md] [egov.md]
• Transmission to Tax Authorities: Because the authority runs the platform, transmission to the tax authority is automatic. The moment an invoice is submitted in e-Factura, the data is in the tax authority’s database – no separate filing needed. In essence, by using the platform, companies are simultaneously delivering the invoice to their customer and fulfilling their legal reporting requirement to STS. There is no concept of sending invoices by email to the tax authority or uploading periodically; it’s all handled by the platform. The STS can view or extract reports of all invoices in the system at any time. [egov.md], [egov.md]
• Delivery to Buyers (Interoperability model): For domestic transactions, both supplier and customer typically use the same e-Factura platform to exchange the invoice. The workflow:
  • The supplier prepares and signs the e-invoice on e-Factura.
  • The supplier then “sends” it within the platform – this moves the invoice to the buyer’s inbox on the same platform. [legis.md]
  • The buyer (if also a user of e-Factura) logs in, sees the invoice, and can download it (or sign it if required). The buyer can also opt to receive an email notification when a new e-invoice arrives. [legis.md] [legis.md], [legis.md]
  • If the buyer is not registered on e-Factura or chooses not to handle it electronically, the supplier will use “short cycle” mode: the invoice is finalized with only the supplier’s signature and then the supplier delivers a printed copy or PDF to the buyer through conventional means (email, etc.). The platform indicates that the invoice was delivered in short cycle, and that is acceptable – the invoice is still stored in the system, but the buyer receives it on paper. For instance, if selling to a small shop that isn’t on e-Factura, the wholesaler can still issue the e-invoice, print it with its QR code and note “electronically issued”, and send the paper to the shop with the goods. The legal original is the e-invoice, but the shop can use the paper as a supporting document. [legis.md], [legis.md]
  • Over time, almost all VAT-registered buyers will be on the platform, so the vision is to have invoices exchanged fully electronically business-to-business. In fact, companies can set preferences to only receive e-invoices electronically. E-Factura allows a buyer to indicate they accept invoices only via “ciclul lung” (i.e., they want to electronically approve all incoming). Conversely, if a buyer hasn’t opted in, the supplier might automatically go short cycle. The system helps manage these preferences to streamline flow. [legis.md], [legis.md]
• Interoperability with external networks: For cross-border transactions, Moldova is leveraging the Peppol interoperability framework. Rather than developing a separate international portal, Moldova has joined Peppol eDelivery, meaning that Moldovan businesses can exchange e-invoices with foreign partners through Peppol Access Points. The vision is: [sovos.com], [sovos.com]
  • If a Moldovan company needs to send an invoice to an EU customer that uses Peppol, the Moldovan company (or an intermediary) can send the invoice in Peppol BIS format through the network, and it will reach the buyer’s system. Meanwhile, that invoice would also be registered in e-Factura (since it originated there or is transmitted to STS in parallel). Conversely, if an EU supplier sends a Peppol invoice to a Moldovan buyer, Moldova’s infrastructure can receive it (the STS or its IT partner acts as a Peppol Access Point) and route it into the e-Factura platform for the Moldovan buyer’s view. This ensures cross-border B2B invoices can be integrated – effectively, e-Factura will not be an island; it’s connected to the broader network, allowing a “Connect once, exchange with many” scenario. As of 2026, this is at pilot stage, but progress means by the time many companies need it (post-mandate), it should be operational. [sovos.com] [rtcsuite.com], [rtcsuite.com]
  • Also, for cross-border, if Peppol isn’t used, companies might still revert to PDF/email plus manual reporting. However, the long-term transmission model for cross-border B2B that Moldova aims for is via Peppol to avoid custom integrations with each country. [rtcsuite.com], [rtcsuite.com]
• Accredited Service Providers: Unlike some countries (e.g., Italy) that allow multiple certified exchange systems, Moldova’s approach is centralized. There is no requirement for businesses to use an intermediary service provider; they can interact directly with the government platform for free. However, businesses may choose to use third-party software or providers to manage their e-invoicing process – for instance, a software company might offer a service to convert invoices to XML and send them to e-Factura on the company’s behalf. These are effectively software solutions or outsourcing, not distinct transmission networks. There’s no “clearance agent” accreditation needed because the clearance is done by STS itself. Many companies will rely on their accounting software vendors for integration (Sovos, for example, provides compliance tools that connect to e-Factura), but these tools still ultimately transmit through the official portal or API. So the concept of accredited service providers is minimal here – think of it more as software vendors or consultants rather than separate channels. The security and authenticity are guaranteed by the platform and digital signatures, not by trusting an outside provider. [sovos.com], [globalindi…gement.com]
• API and Gateway: For companies that automate, the STS provides an API (Application Programming Interface) and possibly an AS4 gateway (for Peppol) for machine-to-machine transmission. Through these, invoices can be transmitted from ERP systems to the STS platform and vice versa. This is essentially an “API gateway” approach – the e-Factura platform exposes web services endpoints (likely SOAP/REST) that allow:
  • Sending an invoice (upload XML, sign via web service or send already signed XML).
  • Querying invoice status or retrieving invoices.
  • Receiving push notifications of new invoices (for buyers).
  The technical documentation includes schemas and WSDLs for these interactions. Integration through the API means that the transmission is direct and secure – typically using TLS and requiring an authentication token or digital certificate. Many larger taxpayers will use this method so that their staff don’t have to re-key data into the portal. The government encourages this by publishing the integration guide in the Help section of e-Factura, including syntax validators for submitted files. Notably, by using APIs, companies can have an almost seamless workflow – an invoice created in their system is automatically transmitted to STS and on to the customer, without manual intervention. This modern approach is part of the design to keep business processes efficient while still achieving tax control. [legis.md], [legis.md]
• Deadlines for Transmission: As discussed, the “deadline” for transmitting an invoice to the authorities is essentially at issuance. In a clearance model, you don’t have an end-of-month deadline; you have to clear each invoice as you issue it. The legal requirement remains that an invoice should be issued no later than the moment the taxable supply is performed or shortly after (Moldova’s Fiscal Code generally required invoices by the fifth day of the month following delivery, but with real-time e-Factura, in practice businesses will invoice on delivery date or immediately after). If an invoice somehow was not transmitted timely, it’s non-compliance. The system design pushes for immediate issuance, so real-time or very near-real-time (same day) transmission is effectively mandated.
• Monthly Summaries or Periodic Reports: For certain transactions not covered by e-invoice, periodic reporting may apply. For example, prior to eBon, daily/monthly Z-reports from cash registers or sales ledgers were required. With eBon, those will be electronic in real-time too. If any monthly summary remains (e.g., summary of self-billed import services, or summary for special regimes), those would be submitted via the usual electronic declarations portal (raportare.gov.md) until phased out. However, under the fully implemented system, the goal is to avoid requiring separate summaries. Invoices and receipts are reported individually, and the VAT return aggregates them. Notably, Moldova is heading toward pre-filled or automated VAT returns eventually, so monthly summary reports of invoices might become obsolete (see Section 10 on pre-filled returns).
• Buyer Acknowledgement Workflow: The e-Factura system includes a workflow for buyers to acknowledge invoices. In long cycle, when a buyer receives an e-invoice, they have the option to:
  • Accept (approve) the invoice by applying their e-signature (this is common in B2G and B2B scenarios where formal acceptance is needed). [legis.md], [legis.md]
  • Reject the invoice (with a reason) if, for example, it has errors or they disagree with it. A rejection sends it back to the supplier’s attention – the supplier then should correct and cancel the original. The platform marks rejected invoices and they are not considered valid for tax credit (naturally, since the buyer didn’t accept the supply). [legis.md] [legis.md], [legis.md]
  • Do nothing (tacit acceptance) – if a buyer simply does not respond in long cycle, the invoice might remain in “pending” status. The system, however, allows switching cycles: if a buyer is not responding, the supplier can revert the invoice to short cycle to finalize it without buyer signature (with buyer notified accordingly). This prevents indefinite limbo. In practice, many B2B invoices will likely be processed short cycle (especially once trust is established, the buyer might not feel the need to formally sign each invoice). Long cycle is more relevant for controlling contexts or where the law demands (public sector). [legis.md], [legis.md]
  From a transmission perspective, this workflow ensures the buyer gets the invoice and either confirms it or flags issues, all within the platform environment – improving transactional transparency for both parties and the tax authority.
• Notifications and communications: The platform can send email or SMS notifications of new invoices or needed actions. For example, a buyer might get an email: “You have received Invoice #X from Supplier Y in e-Factura” with a link. Also, when an invoice is rejected or a buyer gives preliminary acceptance, the other party gets notified in the system (and optionally by email). This replaces old-fashioned mailing of paper invoices. All communication about the invoicing event is consolidated in the system – it provides an audit trail (e.g., “Buyer A rejected invoice at 10:30 with reason X” is recorded). [egov.md], [egov.md] [legis.md], [legis.md]
• Security and Gateway Management: Because all transmissions go through STS systems, security is paramount. The system uses the government’s secure access (MPass) for user login, and likely secure API keys/certificates for system integration. Data is transmitted over HTTPS. The portal and API have high availability – as of now, no specific downtime windows are mandated, implying it’s expected to be available virtually 24/7 (with maintenance as needed off-hours). If the system were down, presumably the law might allow issuing on paper as contingency and then uploading when it’s back (though this isn’t explicitly stated, common sense dictates there’s some business continuity plan, but STS aims to minimize downtime). So far, no major service interruptions have been reported publicly, and by making it the sole channel, the authorities commit to its robust uptime.
• PEPPOL / International Gateway: For cross-border, if using Peppol, transmissions will go through Peppol Access Points rather than the STS portal directly. Moldova’s STS or Ministry likely partnered with an IT center (CTIF) to act as the country’s Peppol Access Point aggregator. Essentially, the e-Factura system will plug into Peppol so that if an invoice is addressed to a foreign Peppol participant, the system can hand it off to Peppol network (and vice versa). This is an interoperability layer being added, enhancing the workflow for cross-border invoices by making it seamless – the supplier just uses e-Factura as usual, and behind the scenes the invoice finds its way to the foreign buyer’s system via Peppol eDelivery. Peppol also ensures authenticity via its own PKI and transports invoice in UBL format, which Moldova has prepared to map to/from. This shows Moldova’s commitment to modern, networked transmission standards, not just a siloed national system. [sovos.com] [rtcsuite.com], [rtcsuite.com]

• Real-time for B2B invoices: effectively at issuance (clearance).
• Real-time for B2C e-receipts: at sale (once implemented).
• No end-of-month delay: the data is reported continuously, not in batch.
• VAT return filing: still monthly/quarterly but that’s post-transaction compliance, not invoice transmission.

6. Self-Billing

• Allowance of Self-billing: Moldovan legislation does not prohibit a buyer from issuing the invoice for a transaction, as long as both parties agree (usually a written agreement is required, per common VAT principles). This might happen in scenarios like: a customer has an automated system to generate invoices for its numerous small suppliers (common in retail chains), or in a commissionaire arrangement, or where the buyer calculates the value (e.g., yield-based contracts). In the past, self-billing invoices were issued on paper or PDF and marked “Autofactura” or similar. Now, with e-Factura, self-billing is still possible, but the process must be integrated with the electronic system.
• Issuing a self-billed e-invoice: In practice, there are a couple of ways this can be handled in the platform:
  1. Via the Buyer’s Account: The buyer could create an invoice in e-Factura under their account, but with themselves as “Buyer” and the supplier as “Seller”. However, the system normally prevents you from issuing an invoice on behalf of someone else’s tax ID – you can only issue as the supplier linked to your account. So a buyer cannot directly issue an invoice listing another company as the seller without that company’s involvement.
  2. Via the Supplier’s Account (preferred method): The likely approach is that the buyer prepares the invoice data (perhaps in a file or via API) and then feeds it into the supplier’s e-Factura account for final issuance. This could be done if the supplier grants the buyer (or the buyer’s representative) access to create drafts in their account. E-Factura allows adding authorized users, so conceivably the supplier could authorize the buyer’s agent as a “responsible person” limited to creating invoices. The buyer would then create the invoice (with the buyer’s info and seller’s info accordingly) and the supplier would just electronically sign it, or the system might even allow auto-signing if pre-agreed. Essentially, the buyer does the work but the invoice formally comes from the supplier’s side in the system. [legis.md], [legis.md]
  3. Using API integration: The buyer and supplier could integrate their systems such that when the buyer generates an invoice, it triggers an API call to e-Factura using the supplier’s credentials to create and sign the invoice. This requires a high level of trust and possibly sharing of a signing key or automated signing procedure on the supplier’s behalf.
  Regardless of method, the end result must be an e-invoice in the e-Factura system, under the supplier’s VAT number, covering that transaction. Only then will it count as a valid tax invoice. The buyer cannot simply generate a PDF and consider it a VAT invoice – it needs to be cleared in e-Factura.
• Buyer’s validation/approval requirements: In self-billing, the roles are reversed – the buyer is effectively the issuer, and the supplier is the approver. The e-Factura workflow is flexible in the sense that normally the supplier issues and buyer approves. For self-billing, one could imagine using the same mechanism but flipped: the buyer (as “supplier” in system terms) issues the invoice, then the actual supplier (as “buyer” in system terms) would have to approve it. However, that literal flip isn’t straightforward in the current system because accounts are tied to tax IDs: the invoice must show the real supplier’s tax ID as seller or it’s not valid. Thus, it’s more likely the supplier will still be “issuer” in the system but will rely on the buyer’s provided data. In either case, both parties need to collaborate: the buyer essentially drafts the invoice and the supplier quickly formally issues it. This meets the spirit of self-billing (buyer initiates) while conforming to the platform’s requirement that the “seller” issue the invoice. In effect, the buyer’s role is moved to before issuance (pre-approve the content), and the supplier’s role is just sign+submit.
• Content rules for self-billed invoices: Self-billed invoices must contain all normal invoice details, plus typically a notation that it is self-billing. Under EU practice (which Moldova often mirrors), invoices issued by the buyer should state “Factura emisă de beneficiar” (invoice issued by customer) or similar. Moldovan guidelines likely require a phrase to indicate self-billing so that there’s clarity in audits. The e-Factura system probably doesn’t automatically add such a note, so the buyer/supplier should include it in the “notes” field of the invoice. Aside from that note, the invoice content is standard: it will show the supplier’s name/ID as seller, buyer’s name/ID as buyer, etc., as usual.
• Passing through the platform: Critically, a self-billed invoice must “pass through” the e-invoicing platform just like any other invoice. This means it gets an e-Factura number, date, and is stored for the authorities. If a buyer were to try to self-bill outside the system (e.g., just create a paper invoice), that document would not be considered a valid fiscal invoice after the mandate kicks in – because from the tax authority’s perspective, it was never reported/cleared. The consequence would be that the buyer cannot use that invoice to claim input VAT (since it’s not in STS’s e-invoice database) and the supplier would be penalized for not issuing an official invoice. Therefore, both buyer and supplier have strong incentives to route self-billed invoices through e-Factura: [contabilsef.md]
  • The buyer wants a deductible VAT invoice – so it must exist in e-Factura (the STS can see it).
  • The supplier wants to avoid fines for “not issuing an e-invoice” – letting the buyer’s invoice go through the system covers that compliance.
• Approval requirements: Typically, self-billing requires the supplier’s consent to each invoice (to avoid abuse). With e-Factura, that consent is essentially given when the supplier signs or approves the invoice in the system. So, yes, the supplier must validate/approve the self-billed invoice in e-Factura, either by electronically signing it or at least by not rejecting it. This satisfies the formal requirement that the supplier agreed to have the buyer issue the invoice. Many companies would formalize this with an agreement on file, but in daily practice, the platform’s record of the supplier’s electronic sign-off is evidence of acceptance.
• Restrictions or notifications: No specific additional restrictions on self-billing have been announced beyond standard VAT law (which requires an agreement and typically periodic verification). The tax authority will likely monitor that self-billing isn’t used to circumvent controls. But since invoices still go through STS, there’s no circumvention. Possibly, the STS might be more vigilant to ensure no duplicate invoicing: e.g., if a buyer self-bills an invoice, the supplier should not also issue one for the same transaction. The platform could help avoid that by unique numbering and by the parties coordinating through the system. As for notifications – the supplier, as the nominal issuer in system, would obviously see the invoice in their sent box, and the buyer (who actually drafted it) sees it in their received box. Both have a record.
• Example scenario: Consider a farming cooperative (buyer) that buys crops from many small farmers (suppliers). The cooperative might handle invoicing to simplify things for farmers. In a self-billing setup, after weighing and valuing the crops, the cooperative generates an invoice: listing each farmer as supplier, cooperative as buyer, including quantity and price. Using e-Factura, the cooperative could prepare those invoices perhaps via an API. Then each farmer either pre-signs an agreement so the cooperative can sign on their behalf, or the farmer logs in to e-Factura and clicks “approve” on the invoice the cooperative created for them. The invoice is then finalized and both have it. This way, farmers don’t need to manually issue invoices (helpful if they lack capacity), but STS still gets every invoice (with farmer as seller) in real-time. It’s a win-win: farmers comply easily, the cooperative gets the paperwork done efficiently, and tax authority sees all.

• The supplier should not treat a buyer-created invoice as valid until it’s on e-Factura.
• The buyer should ensure the supplier is on board and the invoice gets into e-Factura promptly (maybe even on the same day of supply, since legally that’s required).
• Notification to tax authority is inherent once it’s on e-Factura (no separate notice needed).
• Usually, self-billing agreements are communicated to the tax authority in some jurisdictions, but Moldova hasn’t specified a need to notify STS of such agreements. The existence of self-billed e-invoices in the system is itself evidence.

7. Triangulation & Special Scenarios

• Triangulation Transactions: Triangulation typically refers to a three-party transaction where goods are sold from A to B and B to C, but shipped directly from A to C. If such a transaction involves Moldovan parties, each leg of the transaction must be invoiced via e-Factura by the party responsible for that leg. For example:
  • If Company A (Germany) sells to Company B (Moldova) who resells to Company C (Ukraine) and goods go directly from Germany to Ukraine, B (Moldova) is the intermediary. B will receive an invoice from A (which A cannot put in e-Factura since A is foreign), and B will issue an invoice to C. B’s sale to C is an export from Moldova (zero-rated) and as of 2025 it is required to be issued as an e-invoice in e-Factura. So B must generate an e-Factura invoice for C (with 0% VAT, noting it’s an export). B will not charge Moldovan VAT (since it’s export) but the invoice still must be in the system for record. On the purchase side, B’s import from A is likely done as a “virtual import” (since goods didn’t enter Moldova physically, tax-wise B often does a triangular simplification if Ukraine is involved, but since MD is not in EU, B might have to account for a import then export – complicated scenario beyond scope). [sirius.expert]
  • If all three parties are domestic (A->B->C all in Moldova), then it’s just two normal domestic sales. A will e-invoice B; B will e-invoice C. Even if goods drop-ship from A to C, both invoices must be in e-Factura. There’s no special process needed beyond issuing both invoices. The system doesn’t inherently link the two, but in practice B might want to attach A’s invoice as support (they can attach a PDF of A’s invoice or mention reference).
  • The key is: no matter how complex the chain, every taxable supply involving a Moldovan taxable person must generate an e-invoice by that person. Triangulation in an EU context often has simplifications, but Moldovan VAT still requires documenting the sale. So B must do so electronically. [sirius.expert]
  There is no separate “triangulation invoice” form – use the normal invoice format. Possibly the invoice note can clarify if it’s part of a triangulation (e.g., “Triangular transaction: goods delivered from X directly to Y” could be written, but not mandatory by law).
  Conclusion: Triangulation doesn’t exempt one from e-invoicing. Each party issues through e-Factura for their piece. The STS will see, for example, that B issued an export invoice and had no local VAT, which is fine as long as B can show the chain in case of audit. (The STS may pay attention to such patterns to ensure no VAT loss – but since B neither charged nor deducted VAT in that chain, it’s tax-neutral beyond confirming it’s legitimate.)
• Chain Transactions (Multi-stage domestic supply chains): Similar to triangulation but all domestic: e.g., A sells to B, B sells to C, C sells to final consumer, potentially with direct shipments among them. Every sale in the chain must be invoiced via e-Factura by the respective seller. There’s no special exception. If goods are transferred without an actual sale (e.g., consignment stock or branch transfers), those might not require an invoice but a dispatch note (which can also be handled in e-Factura if needed by using the “Non-delivery” option for internal transfers – but that’s beyond an invoice scenario). In any case, if it’s a sale, it gets an e-invoice. The platform allows linking related documents (such as referencing the original invoice from A to B in B’s invoice to C if needed in the notes or attachments). But there’s no formal chain document that covers multiple legs – each leg stands on its own invoice(s). [legis.md], [legis.md]
• Cross-border Reverse Charge Scenarios: This refers to typically services or certain goods where VAT is accounted by the buyer (reverse charge). For example, a Moldovan company purchases consulting services from abroad. Under VAT law, the Moldovan company must self-assess VAT (reverse charge) – earlier, they would issue themselves a “Autofactura” (self-invoice) to have a document for VAT records. With the new system, how is this handled?
  • It appears that as of 2025, Moldova expects such transactions to be reported as well. The 2025 extension of e-Factura to dealings with non-residents might imply that the Moldovan buyer should generate an e-invoice (self-invoice) in e-Factura for the purchase from the foreign supplier. Essentially, the buyer would create an invoice showing the foreign supplier as “not registered in RM” (the system might allow that, or maybe using a special dummy tax code for non-residents) – so that the purchase is recorded. This would be analogous to Italy’s esterometro replacement via SDI. However, since details on implementation are scarce, the safest current procedure is: [sirius.expert]
    • The Moldovan buyer accounts for reverse charge on their VAT return (no physical invoice in e-Factura unless required).
    • If STS clarifies, possibly the buyer will be asked to create a self-billing invoice in e-Factura marking it as “for reverse charge – external supplier” similar to how internal invoices can be logged.
  • Another case: import of goods – those are handled by customs, not by e-Factura (customs docs serve as VAT docs). So reverse charge on imported goods isn’t needed because VAT is paid at import. But for services and intangibles from abroad, reverse charge is done via accounting.
  • In summary, cross-border purchases where reverse charge applies currently do not produce an e-Factura record by default (unless voluntarily self-issued). The plan likely is to incorporate them – as the law now says transactions with entities with no fiscal relationship in RM must use e-Factura, which strongly suggests the local buyer should issue an e-Factura for such a purchase (i.e., a self-invoice). We can interpret that: from 2025, if you buy a service from abroad, you should enter it into e-Factura (with you as both supplier and buyer, or using a special non-resident ID for the supplier). By doing so, you create an official electronic document of that transaction, which the STS can track, and you have what you need for deduction (if any) and audit trail. [sirius.expert]
  • That said, specifics might be pending. In absence of clarity, many companies may continue just to account reverse charge in the VAT return and perhaps keep the foreign supplier’s invoice on file. But as e-invoicing matures, expect the STS to mandate self-invoicing through the system for these cases to fully close the loop.
• Zero-rated Supplies (Exports, International transport, etc.): Zero-rated supplies must be invoiced electronically through e-Factura just like taxable supplies. The only difference is that the invoice will show 0% VAT and the reason (e.g., “Export of goods – VAT 0%”). E-Factura supports VAT codes including 0%. For instance, if a company exports goods to Romania, it issues an e-invoice to the foreign buyer via e-Factura (with 0% VAT). This invoice is delivered likely by printing or via Peppol to the foreign buyer, but it’s in the Moldovan system for record. Starting 2025, as we noted, exports by Moldovan companies are explicitly within mandatory scope (prior to that, it was arguably optional to put exports in e-Factura, but now it’s required). This aligns with the move toward real-time reporting of all sales. [sirius.expert]
  • For international services provided (which are zero-rated under Moldovan VAT if the place of supply is outside Moldova), similar logic applies: the Moldovan provider should issue an e-invoice with 0% or an indication “service is outside scope” depending on exact case. There isn’t an “out of scope” flag in e-Factura known, but 0% can be used if it’s zero-rated by law, or possibly “scutit” if considered exempt. However, typically export of services is treated as zero-rated as well.
  • Exempt vs 0%: Note the difference – zero-rated is a taxable supply at 0%, exempt is not taxed at all. The platform and the law treat them differently for VAT accounting, but in terms of invoicing, both still require an invoice to be issued (the VAT Directive doesn’t require an invoice for exempt supplies to private consumers, but B2B generally yes; Moldovan law historically required invoices for all taxable supplies including 0%, and for exempt supplies if to VAT-payers so they have documentation).
• Exempt Supplies: Exempt supplies (like financial services, education, healthcare if provided by VAT-exempt entities) – these usually do not carry VAT and historically might not require a “factura fiscală” (some exempt sectors used simplified receipts). However, if an exempt supplier does issue an invoice (for instance, a financial institution providing a fee-based exempt service may issue an invoice for record), the expectation is that under the new system, they should also use e-Factura. There is no harm in issuing an e-invoice that shows 0 VAT with explanation “exempt per Art. ___”. In fact, the e-Factura schema allows marking a line as VAT exempt (they likely have a VAT code for “scutit fără drept de deducere” meaning exempt non-creditable).
  • Importantly, many exempt persons are not VAT-registered (like a small education service might not be in the VAT system at all). If they aren’t VAT registered, they likely won’t be mandated to use e-Factura (since the law compels VAT taxable persons). So some exempt supplies might remain outside if the supplier is outside the VAT net. But if a VAT-registered business makes an exempt supply (it happens if some activities are exempt), they still have to invoice it normally. For example, a VAT-registered hospital that also sells exempt medicines – they issue fiscal invoices for medicine sales (with 0% or exempt label) even if no VAT. Those should be through e-Factura.
  • So, exempt B2B supplies by VAT-payers will be in e-Factura. Exempt B2C sales usually are done via receipts (e.g., bus tickets, etc.), which will go via eBon presumably.
• Special VAT Regimes (Margin Schemes, etc.): If a company operates under a special VAT scheme (like margin scheme for travel agents or second-hand goods), they still are obliged to issue invoices, but the VAT they show is not the full tax on the price, rather they might not show VAT at all (margin schemes often prohibit showing VAT). In such cases:
  • They will still use e-Factura for invoices. The invoice likely won’t show a VAT amount (or might state “Scheme of margin – VAT not indicated”). The e-Factura system can handle a 0% or exempt code and allow additional text. The company should include the legally required notation (for example in EU one would put “Margin scheme – Travel agents” on the invoice; in Moldovan context they’d do similar). The system doesn’t automatically know it’s a margin scheme invoice; it relies on the user to put correct VAT amount (e.g., effectively 0 on the invoice, since VAT is internally accounted from margin but not charged to client).
  • These invoices are still sent to STS. The tax authority, seeing a company consistently issuing invoices without VAT but not claiming zero-rate, might inspect to confirm they indeed apply a margin scheme properly. But there’s no separate process – it goes through like any invoice, just with special annotation.
  • Conclusion: Special regime invoices are treated as exempt or no-VAT invoices in the platform. They’re rare and handled case-by-case, but the platform doesn’t exclude them.
• Domestic Reverse Charge: Moldova has a reverse charge internally for certain supplies (e.g., supply of scrap metal, etc., where the buyer accounts for VAT). If such rules exist (some countries do that to combat fraud), how is it handled? Typically, the supplier issues an invoice stating “Reverse charge – VAT to be accounted by buyer” and does not charge VAT. If Moldova has any such provisions (it occasionally has for wood materials etc.), the e-invoice would be made with 0% VAT and a note “reverse charge per art__”. So again, the system handles it similar to exempt/0%. The buyer upon receiving e-invoice will then reverse charge in their VAT return. The tax authority can cross-check that supply and purchase are matched. So e-Factura actually enhances oversight of domestic reverse charges too.

• For example, self-withdrawals or self-supply invoices: If a company takes goods out of stock for private use, they must issue a self-invoice and pay VAT. E-Factura can handle that by letting them issue an invoice to themselves (supplier and buyer same). The system explicitly allows an entity to appear as both supplier and buyer (as a “transfer” invoice). This covers those special cases. [legis.md], [legis.md]
• Credit notes / debit notes: The system likely handles these as “stornare” or adjustment invoices – the user can issue an invoice with negative amounts or mark it as an adjustment referencing the original. In Moldova, the practice for corrections is to issue stornare invoice (with negative values) or to cancel and reissue. E-Factura provides an annulment feature (you can cancel an invoice with mutual agreement, which then requires issuing a corrected one). There’s also a function to “re-open” a canceled invoice as a draft for editing (Redeschidere). These tools ensure even corrections are tracked. [legis.md], [legis.md] [legis.md]
• Chain documentation of delivery: If goods are delivered by a third party (transporter), the e-Factura can show a “shipping from A to C” if needed. But that’s more logistic, not invoice content necessarily.

• STS can see cross-border flows (making VAT refunds on exports easier to verify because they see the invoice and can match it with customs export data).
• STS can see exempt supplies volumes (for example, if a company does partly exempt business, STS can monitor how much via e-Factura for pro-rata calculations).
• STS can cross-check that self-invoices for internal use are being issued (if a company has inventory and some is consumed internally, STS expects to see a self-supply invoice in e-Factura to tax it).
• Triangulation: though tricky, at least the part involving the Moldovan intermediary is captured, which helps ensure that intermediary properly zero-rated their sale and didn’t try to claim any undue VAT.

• Triangulation & chain: invoice each leg via e-Factura – no special exemption.
• Cross-border purchases (reverse-charge): likely require self-invoice via e-Factura from 2025, though implementation details are emerging.
• Zero-rated & exempt: still require invoices through e-Factura (with proper notation, 0% or “exempt” code).
• Margin schemes & special VAT regimes: issue e-invoices normally, with no VAT or special note as appropriate, all through the system.
• Archival and audit trail: all such invoices end up in the central archive (discussed next in archiving) so the tax authority has a full picture of transactions, special or not.

8. Archiving & Retention

• Mandatory Retention Period: Tax invoices in Moldova must be retained for at least 6 years for VAT and accounting purposes. This 6-year period aligns with the general tax record-keeping rules in the Fiscal Code (most tax documents must be kept for 6 years from the end of the fiscal year they pertain to). The e-Factura regulation explicitly notes adherence to the standard six-year archiving period for e-invoices. Some specific transactions may have longer retention (for example, certain cross-border documentation or projects might require 10 years if EU funds are involved, etc.), but 6 years is the baseline for tax. Companies should not discard electronic invoices before this period elapses. [sovos.com]
• Format of Archiving: Electronic invoices must be preserved in an electronic format that guarantees their integrity and readability. The e-Factura system itself acts as an archive for all invoices processed – every invoice is stored on the STS servers with its digital signatures. Taxpayers can rely on the e-Factura portal as a form of secure storage (since it’s unlikely STS will delete them after 6 years exactly; they might eventually purge older data, but presumably not without notice). However, prudent practice is for taxpayers to also archive their invoices themselves. They can download the signed XML and/or a human-readable PDF from the system and store it in their own archive systems or document management systems. The legally primary record is the XML with digital signature (that’s what proves authenticity), but for practical purposes a PDF printout (with the verification data) can be kept as well – though the PDF alone wouldn’t prove integrity unless one also can validate it against the XML or platform. The e-Factura system ensures integrity by storing the original signed data; any copy of the XML with its signature can be verified with the public key of STS or the certificate of the signer. So companies should maintain the original XML files if archiving outside the system.
• Local vs. Offsite Storage: Moldovan law does not explicitly mandate that archives be stored domestically, but it does require that data be available to tax inspectors on request. Many companies will use the STS’s own archive as evidence (since the inspector can log into the system and see the invoices). If a company wants to store data abroad (e.g., use a cloud service in EU to back up invoices), they must ensure accessibility. Moldova doesn’t have strict data residency rules for invoices – given it’s not under GDPR fully, etc., their focus is just that the tax info must be accessible to them. Thus, companies can use EU-based or other cloud archives for e-invoices, or even print them out to paper (not recommended as primary method since the digital signature would then need separate verification). The main rule is that authenticity and readability must be preserved. Storing electronically with signatures intact achieves both. So it’s acceptable to store on any reliable medium: local server, external drive, cloud, etc., as long as during an audit, the company can present the invoices in a legible form and demonstrate their origin and integrity (for instance, by showing the STS export with its digital signature or referencing the STS platform record).
• Ensuring Integrity and Authenticity: As mentioned, digital signatures are the cornerstone of guaranteeing the integrity and authenticity of archived e-invoices. An invoice signed in 2026 and stored as an XML with its signature can be verified in 2030 to confirm it hasn’t been altered. Tax inspectors have tools to validate the signature (either through the e-Factura interface or separate software). Moreover, the platform’s audit trail provides another layer – each invoice status is logged. If an archive copy didn’t match what’s on STS records, that would be apparent. So, businesses must ensure they archive the original signed version of each invoice (not an altered copy). The e-Factura currently does not allow altering after finalization, so whatever you download from the platform is the fixed record. If companies store only PDFs or printed copies, they should also keep evidence of the digital origin (like the QR code on the print which can be used to query the invoice on e-Factura). The QR code printed on invoices contains identifying info that could be used to retrieve the invoice from the portal within the retention period. That’s a backup way: even a paper with QR can lead an auditor to the electronic record in STS, ensuring authenticity. [legis.md], [legis.md] [legis.md]
• Archiving System: There is no requirement to use a special certified e-archiving system inside Moldova as some countries require. Using e-Factura itself and/or one’s normal IT backup is fine. The law OSF317/2020 and related instructions likely treat e-Factura as part of STS’s information system, which is considered a secure environment. Many companies will trust that having data in e-Factura suffices (since STS won’t lose it presumably). However, solely relying on STS might be risky if some day the portal is unavailable or if the business needs archives for their own purposes outside tax (like internal control, customer disputes etc.). So best practice: download and store all your e-invoices in your own archive too (the system likely has a bulk export or API to fetch documents for a given period).
• Format for Archive: The invoices should be kept in their original electronic format (XML + digital signatures). If a company prints them out, those printouts are not considered originals – they are copies. The law does accept that an invoice can be stored on paper if originally issued on paper. But here they are originally electronic, so to maintain full legal value, they should remain electronic with signature. E-Factura confirms that an electronically signed invoice printed out is a copy, and the true original is the digital file. That’s an important distinction for audits: auditors might accept a printed copy for readability, but if authenticity is in question, they’ll want the digital version to verify the signature. So companies should be prepared to produce the digital file if asked (or allow the auditor to access it on STS system). [legis.md]
• Audit Access Rules: In the event of a tax audit or inspection, the taxpayer is obligated to provide access to their invoicing records. With e-Factura, much of that data the auditor can independently access (with appropriate permission – STS auditors likely have back-end access to query any taxpayer’s e-invoices directly). In practice, during an audit, an inspector might ask the company to print certain invoices or export them to Excel/PDF for review. Because all invoices are already in STS’s possession, the audit dynamic changes: it’s easier for inspectors to do digital analysis (they could, for example, run software on all of a company’s invoices to detect anomalies). But legally, the company still must ensure records are “available”. E-Factura essentially guarantees availability to STS. If an auditor requests documentation, the company can either retrieve it from e-Factura on the spot or confirm the auditor has it.
  • One potential rule: a company might be asked to grant read-only access to its e-Factura account for auditors. However, since STS operates the system, the auditor likely has a way to see the data without needing the company to do anything (they might have an internal audit interface to e-Factura).
  • Audit trail & Readability: The regulation ensures that invoices must remain readable for the entire retention period. This means if technology changes, the company must still be able to present them (e.g., if XML format evolves, they need a viewer for old ones, etc.). Usually, storing the PDF rendering alongside the XML helps with readability decades later.
  • Because the data is structured and centrally stored, audits may become more efficient – less risk of lost invoices or illegible records.
• Local Storage vs EU-only vs Third-country storage: Moldova does not explicitly forbid storing data abroad, unlike some EU countries historically. Since Moldova is aligning with EU standards, it may allow electronic archives to be kept in any country that has agreements for cooperation. There hasn’t been a highlighted restriction in publications – likely because the primary archive is with STS (which is local by definition). If a company wanted to only store with, say, a parent company’s servers abroad, as long as they could produce them when required, STS would accept. But if the STS couldn’t get those promptly, the company would be at fault. So at a minimum, they should ensure a copy can be accessed in Moldova at audit time (either via the STS system or by bringing them in on a drive). In essence, pragmatic approach: always have immediate access to your invoices within Moldova.
• Security of archives: The e-Factura platform is a secure government system with regular backups and protections. For company-managed archives, the company is responsible for keeping them safe (from deletion, tampering, etc.). The digital signature means even if a file is copied, one cannot alter it without invalidating the signature. So authenticity is inherently protected. Companies should protect confidentiality as well – these files contain business info, so their own IT policies should secure the archived data (e.g., encryption of backups).
• Converting paper to electronic for archive: Not directly needed here, as invoices start electronic. If any supporting documents (like signed delivery notes) are on paper, companies often scan them and attach to digital records. The law likely requires also 6-year retention of primary accounting documents (some of which might be on paper, like contracts). Many are moving to digital. For audit, an inspector may ask to see not just the invoice but proof of delivery, etc., which could be archived alongside.

• Retention period: 6 years minimum (potentially longer if required by other laws). [sovos.com]
• Format: maintain original electronic format and signatures (XML/EDI + signatures), plus human-readable form.
• Storage: can be on the STS platform and/or company’s own systems. E-Factura keeps an official archive that companies can rely on, but best to have your own backup.
• Storage location: No strict localization rule; must ensure access for authorities. The government portal is in-country and can be considered the primary repository. Additional company archives can be anywhere provided accessibility and data protection.
• Integrity/Authenticity: ensured by qualified e-signatures and platform controls. Archived e-invoices must remain intact (any attempt to alter invalidates signature). So companies should not modify archived files; they typically should be stored as read-only files.
• Readability: The invoices are in a structured format that can be rendered in plain text. The STS interface or downloadable PDFs ensure they stay legible. If technology changes, STS would presumably maintain backward compatibility or the taxpayer might need to convert old XML to new format (but since XML is text, it’s usually fine).
• Audit and Retrieval: The platform means at any given moment, an authorized person can retrieve an invoice from the archive by query (e.g., search by number, date, etc.) – a big improvement from digging through paper files.

• Emails vs platform: Before e-Factura, companies might email invoices (PDF). Those emails needed archiving as evidence that an invoice was sent. Now, sending is through the platform which logs delivery, so that simplifies things – no need to keep email logs as proof of sending; the platform itself shows if/when buyer viewed or accepted the invoice. That’s part of the audit trail automatically kept. [legis.md]

9. Penalties & Enforcement

• Failure to Issue E-invoices (Not using e-Factura): If a taxpayer who is obliged to use e-Factura issues an invoice outside the system (e.g., on paper or not at all), there are heavy penalties. According to the Fiscal Code (Article 257(2) as amended), issuing a paper invoice when an electronic invoice is required carries a fine of 25%–35% of the transaction value. This is a very steep penalty (effectively a quarter to a third of the sale amount) designed to strongly discourage off-platform invoicing. This sanction took effect from 1 January 2024 for those already mandated, and will apply to all once the mandate is universal. For example, if a company should have e-invoiced a MDL 100,000 sale but instead issues a paper invoice, they could be fined MDL 25,000–35,000 for that single violation. Additionally, such a paper invoice is not recognized for tax purposes – meaning the buyer cannot use it to claim VAT credit and the sale might even be deemed unreported by the seller. Earlier enforcement (2021–2023) used a different scheme: per the Contravention Code, fines of MDL 6,000–12,000 for companies not using e-Factura when required, and critically, any paper invoices in those cases were deemed invalid for VAT. That rule essentially disallowed VAT deductions on non-e-invoices and is an enforcement mechanism through the business community (buyers force sellers to comply since otherwise buyers suffer). Thus, failure to comply not only results in direct fines but also disrupts the business’s VAT relationships (customers will reject non-e-invoices). In summary, not using the e-Factura platform when obligated can lead to substantial financial penalties and your invoices being treated as non-invoices. [intelcont.md] [sirius.expert]
• Late or Incorrect E-reporting: If an invoice is not reported in a timely manner (e.g., not submitted to the platform within the legal timeframe of issuance) or if data is misreported, penalties apply. The general penalty for “presenting obligatory information late” under Fiscal Code art.253(6) is 1.5%–2.5% of the amount (up to MDL 25k). For “presenting unauthentic (incorrect) information”, the fine is 5%–10% of the discrepancy (up to MDL 50k). These provisions would cover, for instance, failing to report some invoices or reporting wrong values (if it leads to underpayment of VAT, etc.). Additionally, if a taxpayer simply doesn’t submit required electronic data at all (non-presentation), that’s 10%–20% of the amount (up to MDL 150k). These are broad penalties in the Fiscal Code for tax information failures, and they certainly encompass e-invoice data as part of “information”. For example, if a company somehow issued invoices but did not record them in the system (thus under-reporting sales by, say, MDL 1,000,000), a 10%–20% fine of that unreported sum (i.e., MDL 100k–200k) could be imposed. These general penalties backstop the specific e-invoice ones. In practice, given the specific fine for not using e-Factura is already severe, those would usually apply. But if partial info is wrong (e.g., incorrect VAT amount on an invoice leading to underpayment), that could fall under incorrect reporting penalties besides needing correction. There’s also a daily penalty in some contexts (like Romania introduced fine for >5 days late reporting e-invoice there). In Moldova, because it’s clearance, “late” means you didn’t do it at all by the required time. So effectively not using e-Factura is both “failure to issue properly” and “non-presentation of info” – subject to both sets of fines if authorities choose, but likely they’d use one at a time. [intelcont.md]
• Platform Non-compliance: Platform non-compliance can mean various things: not registering on the platform when required, not maintaining your account (e.g., failing to update something needed), or not following the platform’s rules (like not signing invoices properly, etc.). There isn’t a specific fine listed for “not registering”, but in effect if you don’t register and you should, you simply end up failing to issue e-invoices – which falls under the 25–35% fine rule. So the enforcement will catch you via the act of non-issuance. If one tries to circumvent by issuing no invoice at all (which is tax evasion essentially), then hefty penalties or even criminal charges can come into play for tax evasion. Specifically, deliberate failure to issue invoices to hide sales would be considered tax evasion, penalized at 80%–100% of the unpaid tax (and possibly criminal if amounts are large). So the platform compliance is enforced indirectly by requiring its use for fiscal compliance. [intelcont.md], [intelcont.md]
• Archiving Violations: If a taxpayer fails to archive invoices properly, or destroys them too early, that can result in penalties for failing to present records during audit. According to the Contravention Code, failure to maintain or present required accounting documents can lead to fines around MDL 4,000–6,000 for individuals or MDL 10,000–15,000 for companies (this is implied from context, though exact article references in Code might be different). In the compiled list, “impeding fiscal control by not providing documents” is MDL 4,000–6,000. Also, not preserving documents for the required period would likely fall under “violation of rules for keeping records” for which fines exist (the intelcont list might not have explicitly listed that scenario, but it’s typically a contravention). So while archiving issues carry lesser fines than invoice issuance issues, they are still enforceable. Additionally, if archiving failure leads to inability to verify taxes, inspectors can apply indirect methods to assess tax, which could be costly. So best not to be in that situation. [intelcont.md]
• Intentional or Negligent Errors: If errors or failure to comply are deemed intentional (fraud, evasion) vs negligent (oversight), penalties differ:
  • Negligent (minor) errors: might result in smaller fines or just an instruction to correct if immaterial. But pattern of negligence can escalate. The contravention code has fines for “violation of rules of filling out documents” etc. E.g., if an invoice is issued but with a minor mistake not affecting tax, maybe a small fine or a warning.
  • Serious negligence: e.g., consistently not using e-Factura out of “ignorance” – likely still fined the same as intentional, because the obligation was clear. The law doesn’t differentiate much between “I forgot/ didn’t know” and “I refused” – both are violations, though an inspector might be somewhat more lenient in first instance of a genuine mistake (maybe issue minimum fine or caution).
  • Intentional non-compliance (fraud): If a company deliberately bypasses the system to hide sales or alter invoices, heavier consequences apply. For instance, issuing fake invoices or altering them – that could trigger not only the 100% tax evasion fine but also potentially criminal liability (if it constitutes tax evasion beyond a threshold, the case can be referred for criminal prosecution). The intelcont summary shows tax evasion (Art. 261) is fined 80%–100% of the evaded amount. That’s enormous and in addition to paying the due tax. And if extremely egregious (or repeated), criminal law can involve prison for tax evasion. So, forging or intentionally not reporting via the platform is very risky. Also, because the system improves traceability, attempts at fraud may be easier to catch (for example, if a buyer claims an invoice for VAT deduction that the seller failed to put in e-Factura, the STS will see mismatch and investigate). [intelcont.md]
• Penalties referenced in official sources: The Ministry of Finance and STS have communicated that non-compliance will not be tolerated. For example, in local advice blogs it was highlighted: if you are obligated to use e-Factura and don’t, you face fines of MDL 6,000–12,000 (companies) and your paper invoices “are not recognized” plus possible audits and contract loss risks. This was the state in 2025 for those on the list. Now with new law, the fine is even higher (percentage of transaction). Both are meant to strongly enforce. Many companies on the mandatory list learned that if they didn’t comply, their clients wouldn’t accept their paper invoices, forcing them into compliance or else they effectively couldn’t do business. This will extend economy-wide in 2026. In short: the enforcement strategy is both direct (fines) and indirect (making non-compliant invoices commercially unusable). [sirius.expert]
• Other penalties:
  • If a taxpayer tries to manipulate the platform (say, attempts to hack or generate false records), aside from criminal IT law, STS could sanction by blocking access or pressing charges.
  • If a taxpayer refuses an audit or to provide info: Fines of MDL 4,000–6,000 for obstruction. [intelcont.md]
  • If the taxpayer fails to implement required technical changes (like not obtaining a digital signature or not connecting to API) and thus cannot issue e-invoices, that doesn’t excuse them – they would still be fined for not issuing e-invoice. It’s on them to get the tech in place. Possibly smaller businesses might plead hardship – but given there’s a free web portal, that won’t hold water. They can always manually use the portal if nothing else.
• Enforcement mechanism: The enforcement of these penalties will likely be robust:
  • STS will know if a mandated company hasn’t issued any e-invoices – that’s a red flag (they can cross-check VAT returns against e-Factura data. If a VAT return shows sales but e-Factura has none, something’s wrong).
  • They may send notices or do surprise inspections for non-users.
  • Also, customers and suppliers will police each other: since a buyer cannot deduct VAT unless the invoice is electronic, buyers will insist sellers comply or they’ll escalate the issue (they might inform STS or just not do business with them).
  • Repeated non-compliance can lead to more severe consequences, e.g. being designated again as a high-risk taxpayer (if not already) which can lead to special scrutiny, potential VAT registration cancellation under certain conditions (like if a company continuously flouts VAT rules, STS can attempt to annul their VAT code in extreme cases, though usually they try not to unless it’s a shell or so).
• Peer enforcement (B2G): For government contracts, compliance is strictly enforced: if a supplier doesn’t e-invoice, the government entity won’t pay (since paper invoice not accepted), and they might terminate the contract. So risk of losing contracts is real in B2G and could occur in B2B if contract requires proper invoicing (and by 2026, “proper” means electronic). [sirius.expert], [sirius.expert]
• Recent Big4 references: Big4 newsletters emphasize compliance:
  • KPMG noted (in 2025) these proposals and obligations, implying companies must get ready to avoid sanctions. [kpmg.com], [kpmg.com]
  • EY’s global trackers likely list the penalties to caution multinational clients. Sovos also often warns that failure results in “steep fines or loss of input credit”. [vatupdate.com], [sirius.expert]
• Penalties for Improper Archiving:
  • If a company destroys or loses invoices before 6 years: they’d be penalized under rules for not maintaining records. They may also lose the right to deduct VAT on purchases if they cannot produce the purchase invoices in audit (though if they are in STS system, STS has them anyway – advantage of e-Factura).
  • If data is not readable due to negligence (say they stored in obsolete format and can’t show it): same as not presenting info – fines up to 150k or a percentage as given above. Probably they would require the company to fetch it from STS, which they could, so this scenario is rare. [intelcont.md]

• Sell to government? You must e-invoice or you won’t get paid.
• Sell to a VAT-registered buyer? If you don’t e-invoice, the buyer won’t be able to deduct VAT (so either buyer penalized or will demand remedy).
• If caught not using, heavy fines in proportion to invoice value to erase benefit of not paying VAT or any convenience.
• If caught hiding sales (which e-invoice aims to reduce), enormous evasion fines plus potential criminal case.
• These measures are backed by legal references: Article 117(11) requiring to issue e-invoice or else, and Code articles for fines, etc. [contabilsef.md] [intelcont.md], [sirius.expert]

• Not using e-Factura (paper invoice issued instead): 25–35% of transaction value fine. [intelcont.md]
• Previously (2023/early 2024): fine MDL 6000–12000 for company for not using, plus invoice invalid (this is superseded by above but shows trend). [sirius.expert]
• Each paper invoice not recognized, meaning VAT on it is non-deductible. [sirius.expert]
• Penalty for failing to provide e-invoice data (i.e., not presenting info): 10–20% of amount up to 150k lei. [intelcont.md]
• Penalty for incorrect data (errors): 5–10% of tax difference up to 50k lei. [intelcont.md]
• Late reporting: 1.5–2.5% of amount up to 25k (though in clearance not applicable as separate, since it’s either reported on time or not at all). [intelcont.md]
• Impeding audit (e.g., not giving access to records): 4000–6000 lei. [intelcont.md]
• Tax evasion (intentional under-reporting): 80–100% of the evaded tax (plus interest and possible criminal). [intelcont.md]
• Also mention possibility of contract loss and increased audits as indirect enforcement. [sirius.expert]

• Ensure they are fully on e-Factura by the mandate date.
• Train staff to not bypass the system.
• Have internal controls so that no sale goes uninvoiced or off-platform.
• Continuously reconcile VAT returns to e-Factura to catch any missing invoices themselves before STS does.
• Also ensure archive and data quality to avoid any sanctions related to record-keeping.

10. Pre-Filled VAT Returns

• Current Status – No Pre-Filled Returns Yet: As of early 2026, Moldova does not provide pre-populated VAT returns to taxpayers. VAT-registered businesses must still compile and file their periodic VAT returns (monthly or quarterly, depending on turnover) manually through the electronic filing system. The VAT return (Form TVA12) requires the taxpayer to summarize total sales, total purchases, VAT collected, VAT input credits, etc. There is currently no official system where the tax authority sends you a draft of those figures. Taxpayers use their accounting records (which now will be 100% mirrored by e-Factura for sales and potentially by e-reporting for purchases) to prepare the return.
• Plans for Pre-Filled Returns: Although not implemented yet, one of the strategic goals of introducing comprehensive e-reporting (including e-invoicing) is to move toward pre-completed tax declarations. With all invoice data in the STS database, in principle the STS could calculate each business’s taxable sales and purchases in real time. In fact, the EU’s proposed “VAT in the Digital Age” (ViDA) reforms aim for exactly this (the tax authority generating VAT returns from live data). Moldova, being aligned with European best practices, is likely to follow that trajectory once the e-invoice mandate matures. The Ministry of Finance has hinted at reducing administrative burden through digitalization. Pre-filled returns are a logical next step. However, as of the present, they are not yet in place or announced for a specific date. [moldpres.md], [moldpres.md]
• In Development: There have been discussions or minor projects in this direction:
  • For example, with the introduction of the simplified VAT declaration for the energy sector (from Jan 2026), the authorities might be using data to streamline those specific returns. This indicates a move to standardize and possibly pre-fill the info for that sector’s participants (like centralizing data on energy purchases, which are reverse-charged, to feed into their returns). [vatupdate.com]
  • Another is that the STS could practice by providing “verification statements” to taxpayers, e.g., a summary of their e-invoiced sales and purchases matching them with counterparties (some countries do this: Italy’s Agenzia provides mismatch reports). If a taxpayer’s self-filed return differs from e-Factura aggregates, STS may flag it. Over time, this can evolve into STS just computing it for them.
• Reliance on E-invoicing Data: For pre-filling to work, the tax authority must have essentially all requisite data:
  • Sales (outputs): Yes, with e-Factura they have details of all sales invoices. They can sum the VAT on those to know how much output VAT should be declared.
  • Purchases (inputs): They also receive all purchase invoices (as someone else’s sales, or as reported by self-billing if cross-border). Thus, they can also sum the input VAT amount on all purchase invoices issued to the taxpayer. However, one complication: A business can only deduct input VAT on purchases that are for taxable activities. If some purchases relate to exempt activities (mixed businesses), STS may not know which are non-deductible portion. The taxpayer must do a pro-rata calculation which the authority can’t fully pre-fill without additional info. But the return could be pre-filled with full amounts and the taxpayer would adjust for non-deductible part. Similarly, some input VAT might not be claimable due to rules (cars, representation expenses) – STS wouldn’t know usage intent from invoice alone. So pre-filling can cover the majority of straightforward cases, but the taxpayer might have to adjust or confirm certain fields.
  • Other fields: The VAT return also asks for things like VAT on import (which comes from customs, not e-Factura), any adjustments, etc. Data from Customs could be integrated (they have an electronic system too), enabling pre-filling import VAT amounts. E-invoicing doesn’t cover import VAT since that’s paid at border, but the system could combine with customs data to include that in the draft return. Since Moldova is integrating systems as part of digital strategy, this is plausible eventually.
• Whether planned: The ministry or STS haven’t formally announced “pre-filled VAT returns from X date” yet. But they frequently tout reduced compliance burden as a benefit of digitalization. In an official press release in Dec 2025, the MoF said modifications aim to apply uniform procedures and improve fiscal processes – which can be interpreted as steps toward things like automation. Additionally, in other contexts (personal income tax), some pre-filling is done for individuals in Moldova via e-declaration. So the concept exists. [moldpres.md], [moldpres.md] [mf.gov.md]
• Likely Approach: Once the e-invoicing system has been running for a while and data quality is high, the STS could start providing draft VAT returns in the taxpayer’s online account. The taxpayer would review:
  • If everything matches their records, they simply confirm/submit it – saving time.
  • If something needs correction (like they have non-deductible VAT or some supply not accounted for by e-invoice maybe like self-consumption needing adjustment), they can edit the draft before submission.
  • Countries like Spain (with SII) and Italy (with pre-filled VAT ledgers pilot) are going this way, so Moldova likely will emulate those practices, especially given they are aligning with EU norms via Eastern Partnership projects. [sovos.com]
• Dependency on full compliance: Pre-filled returns only work when nearly all transactions are captured electronically. The aim is that after Oct 2026, that condition will be met: all B2B and B2G and most B2C data (through aggregated eBon) will be in STS’s hands. Possibly by 2027 or 2028, STS could start a pilot for select businesses to receive draft returns. It might start with large taxpayers (which have mostly B2B invoices recorded and less complicated pro-rata issues) or purely taxable supplies companies.
• Which data fields could be prefilled: Likely:
  • Total taxable sales and VAT on those (broken down by 20%, 8% if that rate is still around, 0%).
  • Total exempt sales (the system can sum invoices marked exempt).
  • Total purchase VAT that is potentially deductible (i.e., from domestic and import invoices).
  • VAT due or credit carry-forward.
  • Maybe prefill list of top trading partners for info (like recapitulative statement style).
  • They might not prefill adjustments, corrections, or special items – those remain user input.
• No official yes/no on plan: The question specifically asks “Clearly state whether pre-filled VAT returns exist, planned, rely on e-data, which fields prefilled vs need input.”
  • Pre-filled VAT returns do not yet exist in Moldova.
  • They are not yet formally announced as a near-term deliverable, but are conceptually part of the long-term vision enabled by e-invoicing.
  • One can say they are likely in the pipeline (given global trends and local digital strategy “to align with European and international practices”), but with no confirmed start date.
  • If/when implemented, they would rely heavily on the e-Factura and e-Reporting data – using invoices to populate sales/purchase figures.
  • Fields that would still require taxpayer input: e.g., any non-deductible VAT (like if a purchase invoice is partly for exempt activity, the system wouldn’t know to exclude it – taxpayer must adjust that), adjustments such as credit notes issued late or annual pro-rata adjustments, etc., and VAT on import if that’s not auto-fetched.
  • Fields likely automatically filled: totals of domestic taxable outputs (by rate), total zero-rated exports, total exempt outputs, total domestic input VAT (the system sees all purchase invoices), and maybe VAT paid at customs if integrated with customs data system.
• Benefits if implemented: It will reduce errors and compliance cost and help SMEs in filing returns (which is an objective, per government statements of helping SMEs with digital solutions). Because everything is reported in near real-time via e-invoicing, it’s a natural next step to produce a draft return from that data. Many countries implementing continuous transaction controls foresee such pre-filled returns by 2028 (the EU ViDA plan suggests by 2028 pre-filled VAT returns across EU). Moldova could even beat that timeline since they are smaller and more agile. [moldpres.md], [cereport.eu]

• Do pre-filled returns exist now? No, they do not.
• Are they planned? There’s a strong expectation they will be introduced once e-invoicing is fully in place, as part of the digital economy initiatives (so yes, planned in concept, but not scheduled publicly).
• Do/would they rely on e-invoicing/e-reporting data? Absolutely yes – pre-filled figures would come straight from e-Factura and related systems (this is the whole point of gathering the data centrally).
• Which fields pre-filled vs still requiring input? Likely pre-filled: total sales by VAT rate, total output VAT, total input VAT (gross). Requiring input: adjustments (like non-deductible portion, any corrections, claims for refund vs carry-forward choice, etc.). Essentially, STS could pre-fill the raw numbers, and the taxpayer would confirm and handle any exceptional items.

11. Impact on SMEs and Startups

• Compliance Burden vs Simplification: For SMEs that are less digitized, the move to electronic invoicing represents an initial administrative burden. They must obtain the necessary tools (e.g., computers, internet, possibly a digital signature certificate) and learn to use the e-Factura system. This can be daunting for micro-businesses or sole proprietors not previously using accounting software. However, the government has worked to make the platform user-friendly and free of charge. The e-Factura web portal is provided at no cost to taxpayers, removing the need for SMEs to purchase invoicing software. Many SMEs already issue invoices via Word/Excel; switching to an online form on e-Factura is a change in habit but not necessarily a large financial cost. Over time, the e-invoicing mandate can simplify SME operations by eliminating paper handling, reducing errors, and automating record-keeping. For example, an SME will no longer need to buy physical invoice forms or worry about delivering them to clients by post – the platform does it instantly. Also, their VAT returns should become easier when all sales are tracked digitally (possibly even pre-filled, see section 10). So, after an adjustment period, the net compliance effort may decrease. Government and advisory sources note that digitization ultimately reduces manual work and delays. [sovos.com], [sovos.com] [egov.md], [egov.md] [vatupdate.com], [vatupdate.com]
• Simplified Regimes & Threshold Exemptions: Moldova appears mindful of SMEs in how it phases the mandate:
  • The VAT registration threshold is being raised from MDL 1.2 million to MDL 1.5 million turnover. This means very small businesses (below ~€88k revenue) remain outside the VAT system entirely and thus outside the e-invoicing mandate. That’s beneficial to micro-enterprises – they won’t have to worry about e-Factura at all if not VAT-registered. Even for those just above the threshold, the higher threshold reduces the count of companies drawn into compliance. Big 4 commentaries mention this threshold raise as a relief measure for SMEs. Additionally, SMEs under a special tax regime (like small business income tax regime) might have fewer VAT obligations if they opt out of VAT. In short, the smallest businesses can avoid the complexity by staying below threshold or under simplified regimes. [vatupdate.com]
  • Optional simplified regimes: There are talk of special schemes – e.g. a special regime for small traders with lower compliance or a flat VAT. None specifically introduced with e-invoicing yet, but the threshold raise effectively is the “simplification” (no VAT at all for smallest). For those above threshold, no simplified VAT regime exists – they must comply fully, but e-Factura itself simplifies some tasks (like no need to obtain physical invoice books or do separate sales ledgers).
• Phased Onboarding for SMEs: The timeline doesn’t explicitly stagger by size, but SMEs benefit from the general timeline – they’ve had extra time while large companies and risky ones went first. Also, the pilot phase in early 2026 allows SMEs to familiarize themselves without immediate penalty. The STS and Chamber of Commerce are likely to do trainings especially aimed at SMEs. Indeed, the government often runs information campaigns (some sources mention guides and manuals are published for users of e-Factura). There may also be a grace period in practice for very small companies to catch up (though not formally stated, enforcement might initially focus on larger evaders, giving genuine small businesses time to adjust if they show effort). [egov.md], [egov.md]
• Government Support Programs: The government has recognized costs to SMEs and has taken steps:
  • Virtual Cash Registers (eBon) for retail SMEs: This initiative is particularly to help small merchants by removing the barrier of expensive physical cash registers. Traditional cash registers can be costly and require maintenance; the new virtual cash register law allows a cheap app (~75 MDL/month subscription) to issue e-receipts. The Deputy PM explicitly framed this as a benefit for small and rural businesses to lower costs and simplify compliance. This shows direct support to SMEs in B2C trade – it reduces their hardware costs and automates sending receipt data to STS. [cereport.eu], [cereport.eu] [moldpres.md], [moldpres.md]
  • Training and guidance: While not a monetary subsidy, providing free training, online help (detailed user manuals are available on eGov website), and helpdesk support is crucial for SMEs with limited IT staff. The Agency for Electronic Governance and STS have published guides (in Romanian and likely Russian) on using e-Factura. This lowers the knowledge barrier. [egov.md] [egov.md], [egov.md]
  • There’s no known direct subsidy (like giving funds to buy a computer), but the costs remaining (internet, possibly a token for signing ~some tens of euros) are relatively low. For context, digital signatures in Moldova might be available via mobile ID or eID which can be inexpensive or free in some cases. The government or projects (like USAID mentioned in e-reporting context) often have grants to improve SME digital adoption.
• Cost of Compliance: Initially, SMEs may face one-time or ongoing costs such as:
  • Getting a digital signature (if not already) – costs for a 1-year or 2-year certificate (a modest fee).
  • Training employees or consultant fees to learn new system.
  • If they choose to integrate via API, software development costs – but most SMEs will use the free portal instead, avoiding this cost.
  • Possibly upgrading internet or devices. However, given how widespread internet is and that even small shops have smartphones, the threshold with solutions like mobile app for eBon is quite low-tech requirement. A smartphone or PC is generally already present at most businesses.
  • Ongoing: minimal – maybe the token renewal yearly, and negligible overhead of using the system vs previous paper cost (paper invoice forms also had costs, printers, etc., which this replaces). All considered, the direct outlay is not huge, but intangible cost is time to adapt. As per sources, digitization could save SMEs money in the long run (by automating tasks and reducing errors). For example, the cost of delivering an invoice by post or courier can be eliminated (which in some cases might have been significant over many invoices). [vatupdate.com], [moldpres.md]
• Cash Flow Effects: E-invoicing and e-reporting can affect SME cash flow in a few ways:
  • Faster Invoice Payment: E-invoicing can lead to faster invoice delivery and processing, potentially resulting in quicker payments from customers. When invoices are delivered in real-time to clients (especially large clients or government), SMEs might get paid sooner. For instance, the government paying suppliers might process e-invoices faster than paper. Private sector: some corporate buyers might integrate the e-invoice into their AP system quickly, scheduling payment earlier. A cited benefit is “increase transactional transparency and reduce delays”. [vatupdate.com]
  • Better VAT management: With real-time oversight, errors that cause VAT rejections or audits (which can freeze refunds) might drop, thus SMEs might get VAT refunds faster or avoid penalties that hit cash flow. If eventually pre-filled returns come, compliance is smoother, less chance of missing out on claims.
  • On the other hand, strict reporting deadlines enforce discipline – an SME can’t delay invoicing (which sometimes businesses did to manage VAT timing). Now they must invoice promptly, meaning VAT on sales is reported promptly as well. That may accelerate the payment of VAT to the state (slightly shortening cash retention on VAT by a few weeks if they earlier delayed issuing invoices at month-end). However, that is minor given monthly VAT cycles anyway.
  • Also, if an SME fails to comply and gets fined, those fines directly hurt cash flow. But that’s an avoidable scenario by compliance. In fact, eliminating fines by complying is a cash-flow benefit relative to non-digital behaviors that incur penalties.
  • Another subtle effect: with digital records, banks or lenders might view SMEs as more transparent/creditworthy, possibly easing financing. E.g., an SME could easily prove its revenue via e-invoice reports, possibly improving trust with creditors or partners. That’s an indirect benefit to business viability.
• Administrative Burdens vs Simplifications: Initially, SMEs perceive it as an administrative burden (learning new system, issuing each invoice online), but the system actually automates many aspects:
  • It auto-calculates totals, reduces mistakes (so less time fixing errors).
  • It maintains an archive (SMEs won’t need to manually file and store paper – less office space and admin for document retrieval).
  • It could simplify tax filing (as noted).
  • It reduces duplication of data entry (one enters data into e-Factura and can export for accounting, rather than writing an invoice, then separately entering it into accounting ledger).
  • For startups who build their processes digitally from day one, it could even be seen as simply how business is done – no comparative burden since they never did it the old way. Some officials highlight these automation gains: “reduces costs for SMEs, increases compliance”.
    On balance, after the initial adjustment, running an SME’s invoicing digitally should be more efficient than the old paper-centric approach. [vatupdate.com]
• Market Impact and Digitalization:
  • Increased Digital Requirements: All SMEs now need at least basic digital capabilities. This effectively forces laggard small businesses to adopt IT – which can be seen as a necessary modernization. While some very small traders may find it challenging, overall this push will improve the digital skill level in the SME sector. It aligns with the government’s Digital Transformation Strategy (2023–2030) goals to get businesses online.
  • Some SMEs will use the opportunity to integrate further (like connecting e-Factura with their inventory or billing software). Many tech providers in Moldova are offering affordable solutions or even free open-source connectors. So an ecosystem might evolve that gives SMEs more robust management tools as a side effect of meeting the invoice mandate.
  • Potential Advantages for Early Adopters: SMEs who quickly adapt may gain an edge. For instance, an SME that is fully compliant can work smoothly with large clients and avoid any disruption, whereas one who is slow may have issues (like clients refusing their invoices). Also, early adopters have time to optimize processes and maybe find insights from their digital data (like better understanding of sales patterns from e-invoice data analytics). If pre-filled returns come early, those who have consistent e-invoice history might get benefit first.
  • Digitally proficient SMEs can also potentially cut costs (less paper, postage, storage, fewer manual mistakes leading to rework or audits).
  • Competitive Advantage: There might be a split – those SMEs who adapt could take business from those who struggle. For example, if a small supplier fails to e-invoice and faces fines or client dissatisfaction, that client might switch to another supplier who complies. So being tech-savvy becomes a competitive advantage even in traditional sectors. Conversely, an SME that invests in compliance positions itself as a trustworthy partner (no risk to customers’ VAT credits, no delays due to compliance issues).
• Interoperability Challenges for smaller systems: Some SMEs might use older accounting software not ready for integration, or they manage with spreadsheets. They might continue manual data entry on the portal. This is not a huge problem if invoice volume is low, but for moderate volume SMEs it could be tedious. Ideally, their software would integrate via API. Many local software providers (1C, etc.) are providing e-Factura integration modules. Cost might be an issue for an SME – but since the API is freely available, some cheaper solutions likely appear. If an SME has to manually enter dozens of invoices daily, that’s time-consuming. Overcoming this might require adopting new software (which is again a cost/time hurdle).
• SME Readiness Assessments: International organizations (IMF, World Bank, EU) often monitor how reforms impact SMEs in developing markets. The Eastern Partnership, through EU4Digital, likely did pilot cross-border e-invoicing with some SMEs to test feasibility. That pilot success suggests SMEs can manage, especially if given proper tools. The government in public communications often references making things easier for businesses including SMEs. There’s acknowledgment that training and support are needed. It’s likely that by the time of full roll-out, the majority of VAT-registered SMEs will have had exposure to the system since many voluntarily used it (some stats might show a good uptake voluntarily; we don’t have exact numbers but given it’s available since 2014, a portion of SMEs probably already tried it). Another specific measure: increase of VAT threshold (to 1.5M MDL) clearly is cited as an SME support to “ease compliance for small businesses”. KPMG’s 2025 tax newsflash highlighted that threshold raise as a key help for SMEs that would otherwise have to do VAT compliance. [sovos.com] [moldpres.md] [vatupdate.com]
• Subsidies or financial support: We haven’t seen direct subsidies (like giving free tablets to small shops for eBon usage might be something, but not announced). However, sometimes the government or development agencies might run projects to assist, e.g., maybe distributing card readers or free e-signature for a year to SMEs. The Moldpres news implies the government is aware of cost: they mention cost ~75 lei/mo for virtual cash register which is said to be “much smaller” than old costs. That’s essentially a subsidy-like effect – the state developed a solution that’s cheap. It’s not giving money, but lowering mandated tech cost. Similarly, e-Factura being free is a form of “service subsidization” (in some countries, companies pay transaction fees to clearance operators – here it’s free through STS). [moldpres.md]
• SMEs in rural areas: One big concern is connectivity and tech in rural areas. The e-receipt initiative explicitly aims to help rural entrepreneurs with simpler tech (people can use phones to issue receipts). That indicates they want to ensure even micro businesses at markets or villages can comply easily, presumably via mobile internet which is widely available. If any area lacks stable internet, that’s a challenge – possibly they might allow offline issuance and later upload (some systems do allow that). There is an offline mode in e-Factura for generating XML to upload later if needed – not sure if present, but they could consider it. But such cases will be exceptions. [cereport.eu]

• The smallest are excepted by threshold (so truly micro businesses remain out).
• Those in scope get free tools and simpler compliance procedures (no paper, easier tracking).
• Government has reduced other burdens (like making cash registers virtual and cheaper).
• Once adapted, SMEs may see improved efficiency and fewer tax errors, and possibly quicker payments.
• It’s a push into the digital era, which can make them more competitive and integrated (for example, enabling them to trade cross-border via Peppol easily).
• There is risk if they fail to adapt (fines, losing business), but awareness efforts are underway so that hopefully doesn’t happen widely.

12. Official References

• Government of Moldova E-Invoice Service Portal (e-Factura – Agenția de Guvernare Electronică): Official site providing information and user guides for the e-invoicing system. This includes the “Ghidul de utilizare și Manual de operare a serviciului e-Factura”, a detailed manual for users (available in RO/RU), and links to the actual e-Factura application via the government’s electronic services portal. This is a primary reference for how the system works and is the go-to resource for businesses onboarding to e-Factura. [egov.md], [egov.md] [egov.md]
• State Tax Service (Serviciul Fiscal de Stat) Official Documents: The STS has issued the legal framework for e-invoicing. Notably, Order of the STS No. 317/2020 approving the Regulation on the automated e-invoice system. The full text (in Romanian) is available on legis.md (the official legal database). This regulation outlines how e-Factura operates, user obligations, invoice life-cycle, etc., and is an official reference for compliance requirements. Additionally, Fiscal Code of Moldova (Law 1163/1997) is accessible via legis.md; Article 117^1 and related provisions cover invoicing rules (including the mandate to issue e-invoice for those on the STS list). Also, Fiscal Code Article 257 was amended for penalties (via Law No. 214/2024 – which is published on legis.md as well). These legislative texts are authoritative references for the legal obligations and penalties. [legis.md] [contabilsef.md] [intelcont.md]
• Ministry of Finance – Press Releases and Consultations: The Ministry’s website has news and documents on fiscal policy changes. For example, a press release on 29 Dec 2025 details approved fiscal policy modifications effective 2026 (in Romanian) – relevant as it summarizes changes like uniform procedures and likely mentions e-invoicing indirectly. The MoF also had a draft law consultation page for electronic invoicing in public procurements back in 2020, indicating early steps toward the B2G mandate (on mf.gov.md). These sources show the policy intent and government communications around e-invoicing. [mf.gov.md]
• Moldovan Government Official News Agency (Moldpres) Releases: Moldpres provides official news in English and Romanian. Pertinent references include:
  • “Premiere for Moldova: merchants to be able to use virtual cash registers, electronic tax receipts” – Moldpres news article (02 May 2025) highlighting the introduction of e-receipts (eBon) and quoting officials on benefits for SMEs. [moldpres.md], [moldpres.md]
  • This serves as an official validation of the e-receipts initiative and its timeline (draft law submission) and is accessible publicly on moldpres.md.
  • Moldpres also often covers major law adoptions; any final adoption of the e-receipt law or updates on e-invoicing would be found there (e.g., if Parliament passes the eBon law, Moldpres will issue a news piece).
• Tax News from Big Four and Reputable Firms:
  • KPMG TaxNewsFlash – “Moldova: Proposal to allow issuance of e-receipts; guidance for SMEs exceeding VAT threshold” (22 July 2025): A publication outlining the proposed e-receipt legislation and the VAT threshold increase. It provides an international tax advisory perspective, confirming government proposals and giving context (available on KPMG’s website). [kpmg.com], [kpmg.com]
  • EY’s E-invoicing Global Tracker (January 2026): EY has an “E-invoicing developments tracker” (as referenced in search result) which would include Moldova’s status as of Jan 2026. The EY document (likely a PDF) is an authoritative summary for multinational clients, listing timeline and requirements for Moldova. It’s publicly available on ey.com (or via an EY representative) and is considered reliable and up-to-date.
  • Sovos Moldova E-invoicing Page: Sovos, as a compliance firm, publishes detailed country summaries. The Sovos UK site’s page on Moldova e-invoicing, updated in late 2025, is a good reference confirming dates and requirements (it’s based on official law and is freely accessible). It included source links (e.g., to the e-Factura portal) and is an authoritative industry interpretation. Not “official” government source, but widely trusted for compliance details (and it explicitly cites law and timeframe that align with official announcements). [sovos.com], [sovos.com]
  • Official Gazette (Monitorul Oficial) publications: While not easily accessible online to the public without subscription, the key laws and orders (like Law 214/2024, STS Order 317/2020) were published in the Monitorul Oficial. Legis.md covers them, so referencing legis.md is adequate for official text.
• EU4Digital / Regional Documentation: Since Moldova’s e-invoicing push is partly supported by EU programs, the EU4Digital e-Invoicing Readiness assessment or Eastern Partnership documentation might be available on EU websites (like EU4Digital has articles about Moldova joining Peppol). These are not “official law” but provide context and are official in terms of international support context. [sovos.com]
• Local Advisory Blogs / Analyses: For instance, Sirius Consulting’s blog post (18 Sept 2025) “Vezi dacă ești obligat să emiți e-facturi” – while a blog, it translates the official requirements into plain language for businesses and even links directly to STS’s official list and laws. It’s a publicly accessible summary aligning with the law (and presumably accurate since it quotes law and STS info). This can be used for guidance references (as I did above for penalties and obligations) – though the primary reference remains the law it cites, it is an easy front-end for SMEs to understand their obligations with references to [sirius.expert], [sirius.expert]

• 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