General considerations
The Romanian authorities have published an Order regarding the reporting of the SAF-T. In brief, the document includes information on the nature of the data to be reported by taxpayers, the procedure for submissions to the ANAF, as well as the submission deadlines and date on which this obligation arises (to be established in stages, depending on the category of taxpayer).
Submission deadlines
The deadline for submitting Form D406 is as follows:
- the last day of the month following the reporting period (month or quarter, depending on the reporting period used for VAT purposes) – for all sections of the file, except information on “Assets” and “Inventories”
- same deadline as that for submitting financial statements, for information relating to the “Assets” section
- upon request by the fiscal body, for the information related to the “Stocks” section.
Reporting obligation
According to the Order, the reporting obligation becomes effective at:
- 1 January 2022 – for taxpayers included in the category of large taxpayers on 1 January 2022 and who also belonged to this category in 2021
- 1 July 2022 – for taxpayers included in the category of large taxpayers on 1 January 2022 and who did not belong to this category in 2021
- 1 January 2023 – for taxpayers included in the category of medium taxpayers on 31 December 2021
- 1 January 2025 – for taxpayers included in the category of small taxpayers on 31 December 2021
- Newly established taxpayers will be required to submit the SAF-T file starting with the date of registration, while the actual submission will be made on the last day of the month following the reporting period
Grace period
The Order also introduces a grace period for all taxpayers who have the obligation to submit the SAF-T file.
Taxpayers who report quarterly will be able to benefit from a grace period of 3 months in respect of their first reporting, while for those taxpayers who report monthly, the grace period will 2 to 6 months, applied degressively over the first five reporting periods. In brief, taxpayers will benefit from a grace period of up to 6 months for the first reporting period, a period of 5 months for the second reporting period, and so on.
Source: Order no. 1.783 / 2021 of the President of the National Agency for Fiscal Administration on the nature of the information that the taxpayer / payer must declare through the standard fiscal control file, the reporting model, the procedure and conditions of transmission, as well as the transmission deadlines and date / date from which categories of taxpayers / payers are required to submit the standard tax control file, in the form published on November 9, 2021
