e‑VAT Pre‑Filled Returns: Enforcement Tightens as Transparency Falls

Romania’s RO e‑VAT (RO e‑TVA) regime represents a significant shift in VAT control. Rather than relying solely on taxpayer‑submitted VAT returns (Form D300), the National Agency for Fiscal Administration (ANAF) reconstructs taxpayers’ VAT positions using a broad range of digital data sources—including RO e‑Invoice, SAF‑T, e‑Transport, customs data and cash register systems—and issues a pre‑filled VAT return for reconciliation. [mfinante.gov.ro], [pwc.ro]

Since August 2024, taxpayers have been required to review these pre‑filled datasets and explain discrepancies versus their filed VAT return. While a penalty‑free “soft‑launch” applied initially, this transitional period ended in January 2026, marking a clear move toward enforcement. [vatfaqs.com]

2026: ANAF Steps Up Scrutiny

New enforcement features were introduced through Government Emergency Ordinance (GEO) No. 13/2026, further strengthening ANAF’s position while limiting taxpayer insight:

• Suspension of risk transparency: ANAF is no longer required to communicate taxpayers’ fiscal risk classifications or subclasses until 31 December 2026, even though these profiles continue to be used internally to drive data‑led controls and audits. [kpmg.com]
• Continued reconciliation pressure: Where discrepancies exceed materiality thresholds, taxpayers must respond to ANAF compliance notices within statutory deadlines, or face penalties and heightened audit risk under the RO e‑VAT framework. [pwc.ro]

In practice, this creates an asymmetry: ANAF retains full digital visibility across VAT data, while taxpayers lose insight into how their risk level is assessed.

Expansion of the RO e‑Invoice Register

Implementation of RO e‑VAT is closely linked to the continued expansion of RO e‑Invoice. Under Order No. 3789/2024, ANAF is updating the mandatory RO e‑Invoice Register to:

• Include registration history, increasing traceability over time;
• Align procedural rules with GEO No. 120/2021; and
• Extend mandatory e‑invoicing obligations to certain individuals identified by personal identification numbers (CNPs) from 1 June 2026. [pwc.ro], [kpmg.com]

These changes further widen the dataset feeding into RO e‑VAT and reinforce Romania’s data‑driven VAT compliance model.

Operational Impact for Taxpayers

With enforcement live and transparency reduced, Romanian taxpayers face a higher compliance burden. Robust data reconciliation processes, governance over e‑invoicing and SAF‑T submissions, and timely responses to ANAF notices are now critical. Automated solutions—such as reconciliation tools linking e‑invoicing data to VAT returns—are increasingly being used to manage discrepancies and reduce operational risk. [vatfaqs.com]

Further reading / sources

• KPMG TaxNewsFlash Romania – GEO No. 13/2026 and e‑VAT changes (7 April 2026):
  Changes to the e‑VAT system and e‑invoicing
• VATfaqs / VatCalc – Romania e‑VAT pre‑filled VAT returns update (8 April 2026):
  Romania e‑VAT pre‑filled VAT returns
• PwC Romania – Order No. 3789/2024 and RO e‑Invoice Register:
  Mandatory RO e‑Invoice Register procedure