Romania Clarifies 2026 E-Invoicing Rules: Unified Deadlines and New Registration for Individuals

1.1. Registration obligations for individuals conducting economic activities

Individuals identified by their Personal Identification Number (CNP) who are suppliers/providers subject to RO e‑Invoice obligations must:

• Apply for registration in the RO e‑Invoice Register before 15 January 2026.
• They will be automatically registered on 15 January 2026.
• ANAF must update the registration procedure for the RO e‑Invoice Register within 15 days after GEO 89/2025 enters into force.

💡 This closes an important legal gap: from 2026, individuals acting as economic operators (e.g., sole traders without CUI) are fully included in e-Invoice.

2. RO e‑Invoice – B2C invoices and non-established VAT‑registered customers

The Ordinance addresses two previously unresolved issues:

2.1. Missing deadline for B2C invoices – formally recognized

The Government acknowledges that no legal deadline currently exists for transmitting B2C (business–to–consumer) invoices in RO e‑Invoice, although the obligation to transmit them is already established.

💡 GEO 89/2025 itself does not introduce the deadline but sets the context for future regulation.

2.2. Obligatory transmission of invoices issued to VAT‑registered but non‑established persons

Suppliers in Romania must also transmit invoices to beneficiaries who are:

• Not established in Romania, but
• Registered for VAT purposes in Romania

This removes previous uncertainty in identifying customer status for cross‑border but Romanian‑VAT‑registered entities.

3. RO e‑VAT Pre‑Filled VAT Return – Major adjustments

GEO 89/2025 introduces several important changes and suspensions to the RO e‑VAT system (introduced by GEO 70/2024).

3.1. Repeals – Key articles removed

The Ordinance repeals the following provisions of GEO 70/2024:

• Art. 5(8) and 5(10) – related to data integration and taxpayer obligations
• Art. 7 – fully repealed
• Art. 8(1) and 8(3) – repealed (relating to data validation and system workflows)
• Art. 12(1)(b) – repealed (regarding institutional responsibilities)

These repeals indicate a simplification or deferral of several parts of the pre‑filled VAT return processing and governance mechanisms.

3.2. Modified provisions

Art. 13(1)(b) – updated

The National Center for Financial Information must collaborate with ANAF for:

• Development
• Implementation
• Testing
• Operationalization

of the national RO e‑VAT information system, which manages:

• The pre‑filled VAT return, and
• The RO e‑VAT Compliance Notification

4. RO e‑VAT Compliance Notification – Suspension for VAT cash‑accounting taxpayers

A crucial suspension:

Taxpayers applying the VAT cash‑accounting system (art. 282 Fiscal Code)

→ Do NOT apply Articles 5 and 8 of GEO 70/2024 until 30 September 2026.

This means that, for these taxpayers:

• The RO e‑VAT Compliance Notification
• And related deadlines/processes

are postponed until 30 September 2026.

This is important because many small/medium companies use VAT cash accounting.

5. RO e‑VAT – Temporary suspension of taxpayer response obligations

The preamble clarifies:

• The obligation for taxpayers to submit responses to the RO e‑VAT Compliance Notification
• And the suspension for those applying VAT cash accounting

was previously suspended until 1 January 2026, and GEO 89/2025 now extends/supplements these measures as described.

6. Reason for changes – High data volume & phased rollout

The Government notes:

• Significant volumes of discrepancies between taxpayers’ VAT returns and the RO e‑VAT pre‑filled return
• Complex and data‑heavy taxpayer responses
• Need for phased implementation and progressive analysis workflows
• Need to adjust governance structures before full enforcement

Thus, several obligations are postponed or simplified.

7. Effective dates

• Articles on RO e‑VAT and suspensions (Art. X(1–3), XII, XIII): in force 1 January 2026
• Articles on e‑Invoice register updates (Art. X(4–5)): in force 15 January 2026

✅ Executive Summary of VAT‑Relevant Changes

RO e‑Invoice

• Mandatory inclusion of individuals identified via CNP → must register before 15 Jan 2026.
• Technical procedure for registration updated by ANAF within 15 days.
• Clarification of obligations for invoices issued to VAT‑registered non‑established entities.
• Recognition that B2C deadlines are missing (future regulation expected).

RO e‑VAT Pre‑Filled Return

• Several articles of GEO 70/2024 repealed, simplifying the system.
• Governance/technical responsibilities adjusted.
• High‑volume data handling → phased and progressive rollout.
• Compliance Notification obligations suspended for VAT cash‑accounting taxpayers until 30 Sept 2026.
• Some taxpayer response obligations continue to be suspended.