SAF-T and e-Factura
SAF-T and e-Factura Compliance in Romania
RO e-Factura uploads and the D406 file for a Romanian SRL run from abroad, filed by CECCAR-registered accountants as the company's representative, explained in English.
- D406 due by the last day of the following month
- Monthly or quarterly, following your VAT period
- e-Factura upload within 5 working days
- SPV is free; no state fee for e-Factura or D406
Every invoice uploaded, every period filed.
Monthly e-Factura and D406 work for a company run from abroad
Between businesses established in Romania, only an invoice that goes through RO e-Factura counts as an invoice (art. 319(1^1) Fiscal Code, consolidation to Law 170/2026); the e-invoicing guide explains the system. Every company also files the SAF-T file, D406, electronically (art. 59^1 Fiscal Procedure Code). Our CECCAR-registered accountants do both.
The service is for owners and finance leads of an SRL run from abroad, or of a foreign group's Romanian subsidiary. It sits inside our bookkeeping service, and the yearly D406 'Active' section follows preparing the annual accounts of a Romanian SRL, due by 31 May (OMF 2.036/2025).
What's included
Seven parts of the monthly accounting contract, performed by CECCAR-registered accountants as the company's împuternicit (representative under a power of attorney).
Scope check
Which sales go through RO e-Factura, from Romanian businesses and consumers to foreign buyers, and which D406 period applies: monthly, or quarterly.
SPV and signature set-up
Enrolment in SPV (Spațiul Privat Virtual, ANAF's free online account), the legal representative's qualified digital certificate, and a power of attorney to our accountant.
Ledger mapping to the SAF-T schema
Chart of accounts and master data (partners, tax codes, products, assets) mapped for external generation, the route the SAF-T order provides for outsourced accounting.
Monthly RO e-Factura handling
Sales invoices issued by the 15th of the month after the tax point and uploaded within 5 working days; supplier e-invoices downloaded within 60 days and booked; error messages checked.
D406 every month or quarter
Generated, checked with ANAF's current validator, signed with the qualified certificate and filed online by the last calendar day of the month after the period.
Annual and on-request sections
'Active' (fixed assets) once a year by the annual statements deadline; 'Stocuri' (inventory) only when ANAF asks, within the term it sets, at least 30 calendar days.
Archive
The e-invoice XML and the D406 files, kept with the accounting records for 10 years from the end of the financial year.
Not included: ERP or invoicing-software development and integration, stand-alone tax advice or representation outside the accounting contract, audit, legal drafting, and the certificate itself, which the client buys.
Which invoices go through e-Factura, and your D406 period
The scope check at onboarding settles both questions before the first upload.
| Situation | What applies | Source |
|---|---|---|
| Sale to a business established in Romania | RO e-Factura | art. 319(1^1) Fiscal Code |
| Sale to a consumer | RO e-Factura since 1 January 2025, whether or not the seller is VAT-registered | ANAF Iași information note, 13 August 2024 |
| Sale to a buyer not established in Romania but registered for VAT here | RO e-Factura from 1 January 2026 | art. 10(1^1) OUG 120/2021, inserted by OUG 89/2025 |
| Sale to a foreign parent or client neither established nor VAT-registered in Romania | outside RO e-Factura | ANAF Iași information note, 13 August 2024 |
| Monthly VAT period, the general rule, with the monthly D300 VAT return | D406 monthly | Annex 4 pt. 2 OPANAF 1783/2021; art. 322(1) Fiscal Code |
| Quarterly VAT period: previous year's turnover not above 100,000 euro and the other conditions of art. 322(2) met | D406 quarterly | Annex 4 pt. 2; art. 322(2) Fiscal Code |
| Not registered for VAT (see our VAT registration service) | D406 quarterly | Annex 4 pt. 3 |
| Non-resident company with a Romanian VAT code, often through a fiscal representative for a non-resident company | on the list of D406 filers | Annex 5 pt. 3 |
| PFA (persoană fizică autorizată, authorised sole trader) | on the exempt list | Annex 5 pt. 4 |
How the set-up and the monthly cycle work
law a term set by law or an official rule none no official time found
once, at set-up
- 1
Scope check
Our accountant and the owner
- 2
Certificate and SPV
Your administrator; ANAF
- none no official processing time found
- 3
Power of attorney
The company; our accountant as împuternicit
- 4
Ledger mapping and invoicing-tool check
Our accountant, with your finance team
every month or quarter
- 5
Every sales invoice
Your tool or our accountant; ANAF
- law issued by the 15th of the month after the tax point
- law uploaded within 5 working days
- 6
Every supplier e-invoice
Our accountant; SPV
- law downloaded inside the 60-day window
- 7
D406 filed and receipt read
Our accountant as împuternicit; ANAF
- law by the last calendar day of the following month
once a year or on request
- 8
'Active' and 'Stocuri' sections
Our accountant; ANAF
- law 'Active' by 31 May for an SRL
- law 'Stocuri' within ANAF's term, at least 30 calendar days
Scope check
Our accountant and the owner sort every type of sale into RO e-Factura or outside it, and fix the D406 period: monthly, or quarterly.
Certificate and SPV
The administrator buys a qualified digital certificate from a private trust-service provider, then enrols the company in SPV on ANAF's online form. We found no official processing time for either.
Power of attorney
The company signs a power of attorney and our accountant becomes its împuternicit (art. 18(1) Fiscal Procedure Code); an expert contabil's mandate takes the form the profession's law sets (art. 18(3)).
Mapping and invoicing-tool check
Our accountant maps the ledger and master data to the SAF-T schema, with your finance team where a group ERP is used, and checks invoices leave as RO_CIUS XML with complete buyer data.
Every sales invoice
Your tool or our accountant issues it by the 15th of the month after the tax point and uploads it within 5 working days (art. 319(16) Fiscal Code; 10(7) OUG 120/2021, from 1 January 2026).
Every supplier e-invoice
Our accountant downloads supplier e-invoices from SPV inside the 60-day window the system keeps them, archives the XML and books each one.
D406 each month or quarter
As împuternicit, our accountant generates, validates, signs and files the D406 online by the last calendar day of the following month, then reads the receipt in SPV (OPANAF 1783/2021 Annex 3, from 1 January 2022).
Once a year and on request
'Active' by the annual statements deadline, 31 May for an SRL; see what happens when a Romanian company misses the financial statements deadline. 'Stocuri' within ANAF's term, at least 30 calendar days.
Monthly or quarterly, and since when?
The scope check settles your D406 period and the first period due, before anything is filed.
What you will need to supply
Most of this is set up once; the period documents arrive every month.
- The legal representative's qualified digital certificate, and the ID its provider asks for
- The company's SPV enrolment, done with that certificate
- A signed power of attorney to our accountant
- The CUI, registration data, VAT status and VAT period
- Access to, or exports from, the invoicing tool or ERP, and the chart of accounts
- Client and supplier master data, and which foreign buyers hold a Romanian VAT number
- The fixed-asset register, for the 'Active' section
- Each period: purchase documents received outside RO e-Factura, bank statements, contracts
- For an SRL taken over or onboarded late: its D406 and e-Factura history in SPV
- A new certificate as soon as the old one expires or the administrator changes
The form of a power of attorney signed abroad (notarisation, apostille, translation) is settled with you at onboarding.
Deadlines, fines and state costs
Each filing, the period it covers, its deadline and what the state charges for it.
| Filing | Period | Deadline | State cost | Source |
|---|---|---|---|---|
| RO e-Factura upload of each sales invoice | each invoice | 5 working days from the invoice date, never later than 5 working days after the issue deadline | none in OUG 120/2021; SPV is free | art. 10(7), 10^1(2^1) OUG 120/2021, as amended by OUG 89/2025, from 1 January 2026 |
| Issuing the invoice | each tax point | by the 15th of the month after the tax point | none | art. 319(16) Fiscal Code |
| D406 SAF-T file | monthly or quarterly with the VAT period; quarterly if not VAT-registered | last calendar day of the month after the period | none in the SAF-T order; the certificate is a private provider's price | art. 59^1 Fiscal Procedure Code; Annex 4 pt. 1 to 3 OPANAF 1783/2021 |
| D406 replacing a rejected file | the same period | a valid file within 5 working days after the deadline keeps the original date | none | art. 59^1(3) Fiscal Procedure Code |
| D406 corrective return | the same period | before the next file's deadline, to avoid the fine | none | art. 337^1(3)(a); Annex 3 pt. 18 |
| D406 'Active' | the financial year | by the annual statements deadline, 31 May for an SRL | none in the SAF-T order | Annex 4 pt. 7; OMF 2.036/2025 |
| D406 'Stocuri' | on ANAF's request | the term ANAF sets, at least 30 calendar days | none in the SAF-T order | Annex 4 pt. 10 |
| Keeping the records | continuous | 10 years from the end of the financial year | kept by the company | art. 25(1) Law 82/1991 |
| No filing at all for a calendar half-year | a calendar half-year | a ground for inactive status: why ANAF declares a Romanian company inactive and what it costs | not a fee | art. 92(1)(a) Fiscal Procedure Code |
Forms 300, 390, 394, 100 and 112 run in the same contract: see which returns a Romanian SRL files each quarter and each year.
one reporting period: the rules, not a worked date example
- 1
Tax point
The supply that starts the count
- 2
Invoice issued
art. 319(16) Fiscal Code
- law by the 15th of the following month
- 3
Uploaded to RO e-Factura
art. 10(7) OUG 120/2021
- law within 5 working days of the invoice date
- 4
D406 filed
Annex 4 pt. 1 OPANAF 1783/2021
- law by the last calendar day of the month after the period
- 5
Rejected file replaced
art. 59^1(3) Fiscal Procedure Code
- law valid file within 5 working days after the deadline keeps the original date
- 6
Correction without a fine
art. 337^1(3)(a) Fiscal Procedure Code
- law before the next file's deadline
Problems we solve
Five situations owners bring to us, and how each is handled.
We never started D406
Small taxpayers have filed since 1 January 2025, a new company from its registration (Annex 5 pt. 1 OPANAF 1783/2021). Late filing is fined 1,000 to 5,000 lei (art. 337^1), so missing periods come first.
Our group ERP already exports SAF-T
The file must still pass ANAF's validator, republished on 19 February 2026, carry a qualified signature and be filed by the company or its împuternicit. Ledger data that does not reconcile is mapped first.
ANAF rejected the file
The whole file is resent, since partial corrections are refused (Annex 4 pt. 12). A valid file within 5 working days after the deadline keeps the original date (art. 59^1(3)).
Nobody can log into SPV from abroad
SPV needs the company's enrolment with a qualified certificate (art. 80(1)(a) Fiscal Procedure Code). We coordinate that set-up with the administrator, then file under the power of attorney.
We bought an existing SRL
Its D406 and e-Factura history is read in SPV before the first period we file, since missing periods carry the art. 337^1 fines. Buying one from stock: see a shelf company in Romania.
Missing periods or a rejected D406?
A D406 corrected before the next file's deadline carries no fine (art. 337^1(3)(a)). Send the company's CUI and we list what to file first.
Why work with us
Ioana Marinescu
Accounting and reporting client lead in Bucharest, runs the closing calendar and the onboarding checklist: certificate, SPV, power of attorney.
Filing as împuternicit is sold only inside the accounting contract, performed by CECCAR-registered accountants (art. 6(a) OG 65/1994).
From our practice
The SPV history is read before the first filing, and every D406 receipt is read, not assumed.
Frequently asked questions
Our group ERP (SAP, Odoo or another) can export SAF-T: why would we need an accountant for D406?
An export is not yet a filing. The D406 must pass ANAF's current validator, republished on 19 February 2026, be signed with a qualified digital certificate and be filed by the company or its empowered representative. The SAF-T order itself provides external generation for companies with outsourced accounting, which is the work our CECCAR-registered accountants do.
I don't speak Romanian: can I handle e-Factura and SPV myself from abroad?
A company uses SPV, ANAF's free online account, after enrolling with its legal representative's qualified certificate (art. 80(1)(a) Fiscal Procedure Code). A company's accounts may be kept under a service contract only by CECCAR members (art. 10(3) Law 82/1991), so the uploads and the D406 sit with our accountant, under a power of attorney from the company.
Who signs the D406, and whose certificate is used?
The D406 is signed with a qualified digital certificate (Annex 3 pt. 9 OPANAF 1783/2021). Only the company or its empowered or legal representative may file it (pt. 14). Our CECCAR-registered accountant files as the company's empowered representative under a power of attorney (art. 18(1) Fiscal Procedure Code), in the form the profession's law sets for an expert contabil's mandate.
Who pays the fine if a D406 is late or wrong?
The company is the taxpayer, so the fines of art. 337^1 Fiscal Procedure Code are the company's: 1,000 to 5,000 lei for a late D406 and 500 to 1,500 lei for an incorrect or incomplete one. The accountant files as the company's empowered representative, and a correction made before the next file's deadline carries no fine.
What does the Romanian state charge for SPV, e-Factura and D406?
SPV is free and permanently available. OUG 120/2021 and the SAF-T order set no state fee for uploading an e-invoice or filing the D406. The qualified certificate is bought from a private provider. Our own fee is quoted on request and depends on the number of invoices, the VAT period and whether a group ERP must be mapped.
Does my small Romanian SRL have to file SAF-T, and since when?
Yes. SRLs are on the list of D406 filers in Annex 5 to OPANAF 1783/2021, and small taxpayers have filed since 1 January 2025. A company registered after that date files from the date it is actually registered. An authorised sole trader (PFA) is on the exempt list.
Does my SRL file D406 monthly or quarterly?
D406 follows the company's VAT period (Annex 4 pt. 2 OPANAF 1783/2021). The VAT period is the calendar month, or the quarter where the previous year's turnover did not exceed 100,000 euro and the other conditions of art. 322(2) Fiscal Code are met. A company not registered for VAT files D406 quarterly.
What is the D406 deadline, and when are the 'Active' and 'Stocuri' sections due?
The D406 is due by the last calendar day of the month after the reporting period. The 'Active' section on fixed assets is filed once a year by the date the annual financial statements are filed, 31 May for an SRL. The 'Stocuri' inventory section is filed only on ANAF's request, within at least 30 calendar days.
What happens if ANAF rejects our D406 file?
The receipt and processing messages arrive in SPV. A file with errors is resent whole, because partial corrections are not accepted. If a valid file follows within 5 working days after the deadline, the date of the original message counts as the filing date (art. 59^1(3) Fiscal Procedure Code). A later file for the same period is a corrective return.
What are the SAF-T fines, and can a correction avoid them?
Late filing is fined 1,000 to 5,000 lei and incorrect or incomplete filing 500 to 1,500 lei, under art. 337^1 of the Fiscal Procedure Code in its consolidation to OUG 38/2026. No fine applies to a company that corrects the file by the legal deadline of the next file.
My SRL has no activity: does it still file D406?
Yes. D406 is a filing obligation like any other (art. 59^1(1) Fiscal Procedure Code), and a company that fulfils no filing obligation during a calendar half-year meets a ground for fiscal inactivity (art. 92(1)(a)). An SRL without activity still has its returns to file: see nil returns for an inactive company.
What is the RO e-Factura upload deadline in 2026?
From 1 January 2026 an invoice is uploaded within 5 working days from the invoice date, and no later than 5 working days after the deadline for issuing it, the 15th of the month after the tax point (art. 10(7) OUG 120/2021, as amended by OUG 89/2025). Invoices to consumers have the same 5 working days.
Do invoices to our foreign parent company or foreign clients go through RO e-Factura?
Not where the buyer is neither established nor registered for VAT in Romania. From 1 January 2026, invoices to a buyer that is not established in Romania but holds a Romanian VAT number do go through RO e-Factura (art. 10(1^1) OUG 120/2021, inserted by OUG 89/2025). The scope check at onboarding sorts every buyer into one of these cases.
How long must we keep the e-invoices and the D406 files?
Accounting documents are kept for 10 years from the end of the financial year in which they were drawn up (art. 25(1) Law 82/1991). The e-invoice XML files and error messages can be downloaded from RO e-Factura for only 60 days from publication, so the company archives its own copies with its accounting records.
Ready to hand over next month's uploads and D406?
The set-up plan covers the scope, SPV, the power of attorney and the first period due. Fees on request.