Romanian SAF-T For Non-Established by January 2025

Romania is introducing gradually the SAF-T reporting obligation, which will be due as from January 2025 for non-established taxpayers.

Romanian SAF-T reporting became mandatory for large taxpayers established in Romania as of January 2022. However, the transition period was extended to a 12 months period, so in practice, the first round of SAF-T implementation for large taxpayers was postponed to January 2023. The Romanian SAF-T is known as the D406 form - Declarația informativă D406.

As for the purpose of this new requirement, Romanian tax authorities state that “SAF-T allows tax authorities access to data from the accounting and tax records of taxpayers / payers, stored and processed electronically, in an easy-to-read format for substantial testing of system controls and data, using proprietary audit software, as part of a methodology that ensures increased efficiency and productivity in fiscal control computer assisted” (Annex I to the Order of ANAF, nr 1783 of 04.11.2021).

What should be included in Romanian SAFT returns?

This is an accounting SAF-T initially set up for established taxpayers. Taxpayers will have to extract the information from their ERP systems and adapt it to the SAF-T XML format for its submission to the tax authorities. The data must be verified and subject to checks previous to its submission.

The Romanian SAF-T will be divided in 5 sections, in accordance with the general standard file v2 of the OECD: i) General Ledger, ii) Accounts Receivable, iii) Accounts Payable; iv) Fixed Assets and v) Inventory. 

The content of the D406 form will be more extensive than the current 390 Recapitulative Statement.

In order to generate the SAF-T file, the taxpayers can opt for the following methods:

  • For those taxpayers with electronic accounting systems or ERP systems, it is possible to automatically generate the XML file from the computer system.
  • Manual direct entry of the relevant data in an XML editor. The validation of the Informative Declarations D406 can be done with the validator provided by ANAF. This method is available for taxpayers who do not have computer accounting systems or ERP systems.
  • "External generation" by a specialized data operator. This method can be used by taxpayers recurring to outsourced financial accounting services.

Submission deadlines on SAF-T returns in Romania

The frequency of filing the form D406 will correspond to the frequency of filing VAT returns for those taxpayers registered for VAT in Romania.

  • Regular submission: The frequency of filing the form D406 will correspond to the frequency of filing VAT returns for those taxpayers registered for VAT in Romania. The deadline of the regular D406 submission will be the last calendar day of the month following the reporting period (monthly or quarterly, as appropriate, for sections other than Inventories and Fixed Assets).
  • Fixed Assets section: the deadline for submitting this section of the D406 Informative Statement will coincide with the deadline for filing the financial statements for the financial year.
  • Upon request from the tax authorities (Inventory section): the deadline will be confirmed by tax authorities, which cannot be earlier than 30 calendar days from the date of the request.

How to submit Romanian SAF-T returns

The submission of the D406 form will be done electronically via the submission of a PDF file with the XML attachment prepared. These two files cannot exceed the size limit of 500 MB, otherwise, the electronic platform will reject the submission. In case the size limit is exceeded, there is a specific module to submit the information divided in different portion for the same period.

Corrective SAF-T must be submitted if there is an error or inaccuracy on the file initially submitted. In order to correct the D406 form, the taxpayer must submit a second SAF-T file for the same reporting period, containing complete information to be reported for the period; this second submission will be considered the corrective SAF-T return.

What companies are required to submit the Romanian SAF-T

The tax authorities have implemented a calendar to make mandatory the submission of the  D406 form based on the company’s size criterium:

  • 1 January 2022: large taxpayers established in Romania.
  • 1 July 2022: second group of large taxpayers – as per tax authority’ guidelines.
  • 1 January 2023: medium taxpayers – as per tax authority’s guidelines.
  • 1 January 2025: small taxpayers. Non-established businesses registered for VAT in Romania follow in principle the same deadline for SAF-T compliance as small taxpayers.

Within the Orders published by the tax authorities (namely Order no. 1782/2021 and Order no. 3610/2016), non-established companies registered just for VAT purposes in Romania are not mentioned as eligible to be included within the category of large or medium taxpayers. This is why it is expected that for these businesses SAF-T will effectively apply as from 1st of January 2025. Also, given the complexity of the current SAF-T return set up for established companies, it is expected the implementation of some changes and simplifications. Nevertheless, we must wait for the tax authority’s confirmation on the real impact of the Romanian SAF-T for non-established companies registered for VAT in Romania.

Grace Period for First SAF-T Returns

The tax authorities have granted grace periods where they will not apply penalties for late submission as follows:

  • If the company must submit the SAF-T on a monthly basis, there is a grace period for the first reporting periods: 6 months grace period for the first SAF-T deadline, respectively five months for the second reporting period, four months for the third reporting period, three months for the fourth reporting, and two months for the fifth reporting period.
  • If the company must submit the SAF-T on a quarterly basis, there is a grace period of 3 months following the reporting period for the first quarter of mandatory submission.

Do you need help?

Marosa can assist you with your VAT compliance obligations in Romania. 

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