Romania: ANAF Proposes Changes to the Mandatory RO e‑Factura Register and Form 082

Summary

• Romania’s ANAF has proposed draft amendments to the procedure for registration in the mandatory RO e-Factura Register and revisions to Form 082, primarily targeting individuals conducting economic activities identified by their personal identification number (CNP).
• These changes establish a clear transition framework, mandating that individuals who started economic activities before June 1, 2026, and fall under the RO e-Factura scope, must submit Form 082 by May 26, 2026, for effective registration on June 1, 2026.
• The updated Form 082 and its instructions aim to accommodate the expanded scope of taxpayers and provide clarity for individuals, ensuring they can prepare for the mandatory electronic invoicing system ahead of the key June 1, 2026, milestone.

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Romania: ANAF Proposes Changes to the Mandatory RO e‑Factura Register and Form 082

The Romanian tax authority (ANAF) has published a draft order proposing updates to the Procedure for registration in the mandatory RO e‑Factura Register, together with revisions to Form 082 (“Application for registration in the mandatory RO e‑Factura Register”). The changes primarily target individuals carrying out economic activities who are identified for tax purposes by their personal identification number (CNP) and introduce a clear transition framework leading up to 1 June 2026. [capital.ro]

The draft amendments build on the existing framework set out in Order of the ANAF President no. 3789/2024, which established the mandatory RO e‑Factura Register and approved the model and instructions for Form 082. The new proposal aligns the secondary legislation with more recent changes introduced at the level of primary law. [static.anaf.ro], [legislatie.just.ro]

Background: RO e‑Factura and the Mandatory Register

Romania’s RO e‑Factura system has been progressively expanded in recent years, first covering B2B transactions and later extending to additional categories of taxable persons. As part of this expansion, ANAF created a public, mandatory RO e‑Factura Register, managed electronically and used to identify suppliers and service providers that are required to issue invoices through the national e‑invoicing system. [static.anaf.ro]

Under the existing rules, registration in the mandatory register is carried out by submitting Form 082, with ANAF enrolling eligible applicants within a short statutory deadline. The register itself becomes operational and legally relevant as of the dates specified in the applicable legislation and transitional provisions. [static.anaf.ro]

Focus of the Draft Amendments: Individuals Identified by CNP

The newly published draft order specifically addresses individuals who carry out economic activities and are identified fiscally by CNP, rather than by a fiscal identification code (CIF). This category includes, for example, individuals earning income from independent services or similar activities who fall within the scope of RO e‑Factura but are not organised as legal entities. [capital.ro]

According to the draft:

• Individuals who started economic activities before 1 June 2026 and who fall within the scope of mandatory RO e‑Factura must submit Form 082 no later than 26 May 2026 in order to be included in the mandatory register. [capital.ro]
• Registration is performed by submitting Form 082 and explicitly marking the section dedicated to enrollment in the mandatory RO e‑Factura Register. [hotnews.ro]
• Effective registration will take place on 1 June 2026, which is the date from which the use of RO e‑Factura becomes mandatory for this category of individuals. [capital.ro]

These provisions introduce a clear and uniform cut‑off date, reducing uncertainty for individuals who are currently outside the system but will become subject to mandatory electronic invoicing in 2026.

Changes to Form 082 and the Registration Procedure

In addition to the revised deadlines, the draft order updates Form 082 itself, as well as the related instructions. The aim is to better reflect the expanded scope of taxpayers covered by the mandatory register and to accommodate the specific situation of individuals identified by CNP. [hotnews.ro]

Form 082 remains the sole formal mechanism for requesting registration in the mandatory RO e‑Factura Register. Once submitted electronically, ANAF continues to apply a short processing period, after which the applicant is entered into the public register with effect from the relevant statutory date. [static.anaf.ro]

Practical Impact and Next Steps

From a practical perspective, the draft order confirms that 1 June 2026 will be a key milestone for Romania’s e‑invoicing framework as it applies to individuals. Those already carrying out economic activities before that date must ensure timely submission of Form 082, while individuals starting activities after that date will be required to comply with the registration obligation before commencing their activity. [capital.ro]

Although the order is still in draft form, it provides important early visibility on ANAF’s intended approach and allows affected taxpayers and advisors to prepare system access, internal processes and compliance workflows well ahead of the deadline.

Sources

• ANAF – Draft Order / OPANAF no. 3789/2024 and annexes (Procedure and Form 082):
  https://static.anaf.ro/static/10/Anaf/legislatie/OPANAF_3789_2024.pdf [static.anaf.ro]
• Portal Legislativ – Order no. 3789/2024:
  https://legislatie.just.ro/Public/DetaliiDocument/286238 [legislatie.just.ro]
• Capital.ro – ANAF draft rules for individuals identified by CNP (1 June 2026):
  https://www.capital.ro/reguli-noi-anaf-din-1-iunie-persoanele-fizice-care-trebuie-sa-se-inregistreze-la-fisc-se-completeaza-formularul-082.html [capital.ro]
• HotNews.ro – Updates to Form 082 following legislative changes:
  https://hotnews.ro/e-factura-pentru-persoane-fizice-anaf-actualizeaza-din-nou-formularul-de-inregistrare-082-dupa-modificarile-aduse-de-ordonanta-6-2026-2184378 [hotnews.ro]

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