Question 1

When did mandatory B2G electronic invoicing begin in Romania?

Accepted Answer

Mandatory B2G electronic invoicing took effect on 1 July 2022 under Law 139/2022 Article II and OUG 120/2021 Article 2(1)(m). Romania-established economic operators must issue and transmit electronic invoices through RO e-Factura for qualifying B2G transactions, subject to the statutory classified-contract and security exceptions in Article 6.

Question 2

Are all simplified B2C invoices excluded from RO e-Factura?

Accepted Answer

No. Under OUG 120/2021 Article 10^1(2), as amended by OUG 138/2024, the statutory exception applies strictly to fiscal cash-register receipts that meet the statutory conditions for simplified invoices. Other simplified invoices are not automatically excluded and must be evaluated under general invoicing provisions.

Question 3

Do individual suppliers identified by CNP have to use RO e-Factura?

Accepted Answer

No, not for the specific obligations listed in OUG 120/2021 Article 10^10. From 1 June 2026, suppliers or service providers identified fiscally by CNP are exempt from Articles 5, 9^1, 10(1) and 10^1(2). They may opt into RO e-Factura under the optional registration rules introduced by Law 88/2026 Article III point 8.

Question 4

Are natural-person farmers under the special agricultural regime obliged to use RO e-Factura?

Accepted Answer

No. Under OUG 120/2021 Article 10^7, enacted by Law 88/2026 Article III points 4–6, natural-person farmers applying the special agricultural regime under Fiscal Code Article 315^1 are exempt from RO e-Factura. Suppliers delivering to them are also exempt from transmitting invoices through the system unless the farmer enrols in the optional register.

Question 5

What is the statutory transmission deadline for RO e-Factura?

Accepted Answer

From 1 January 2026, the statutory transmission deadline under OUG 120/2021 Article 10(7), as amended by OUG 89/2025, is five working days from invoice issuance, but no later than five working days after the statutory issuance deadline provided in Fiscal Code Article 319(16).

Question 6

What is the filing deadline for form 390 recapitulative statements?

Accepted Answer

Under ANAF Order 591/2016 Annex 2 and Fiscal Code Article 325, form 390 must be submitted monthly by the 25th day inclusive of the following month for calendar months in which VAT becomes chargeable for covered intra-EU supplies, acquisitions or services.

Question 7

What is the ordinary deadline for declaration D406 SAF-T reports?

Accepted Answer

Under ANAF Order 1783/2021 Annex 4, in-scope taxpayers generally file ordinary D406 data monthly or quarterly by the last calendar day of the following month. Special filing-period rules apply to certain VAT and non-VAT taxpayers. Distinct annual deadlines apply to asset records, and inventory records are submitted upon formal tax authority request.

Question 8

What technical specification identifier was established by the 2022 amendment?

Accepted Answer

Ministry of Finance Order 4092/2022 Article I point 1 amended the specification identifier to urn:cen.eu:en16931:2017#compliant#urn:efactura.mfinante.ro:CIUS-RO:1.0.1. This replaced the original 2021 identifier under Order 1366/2021. The currently accepted production identifier remains subject to confirmation.

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