Romania

Overview of Romania's Standard Audit File for Tax (SAF-T) implementation, known locally as D406 - SAF-T (Declarația 406).

Modules

Romania implemented the Standard Audit File for Tax (SAF-T) in 2022This implementation represents one of the newer SAF-T adoptions in Europe and follows a phased approach based on taxpayer categories:


Module	Description	Filing requirement	Deadline
D406 General	Sales, purchases, and general ledger data	Monthly or quarterly	Last calendar day of the month following the reporting period
D406 Assets	Fixed asset register and movements	Annual	Same deadline as annual financial statements
D406 Stocks	Inventory movements and valuations	On-request only	Within 30 days of request

Note:

Unlike some countries where SAF-T is only submitted on request, Romania requires regular filing of the D406 General module, with frequency depending on the taxpayer's VAT filing regime. The Assets module must be filed annually, while the Stocks module is only required when specifically requested by tax authorities.

Possible penalties

Non-compliance with Romania's D406 requirements can result in penalties:

Failure to submit: Fines ranging from RON 1,000 to RON 5,000 (approximately €200 to €1,000)
Late submission: Administrative penalties based on the delay period
Inaccurate data: Penalties proportional to the tax impact of errors
Repeated violations: Increased penalties for systematic non-compliance

Special considerations

Non-residents

Non-resident entities registered for VAT in Romania will be required to submit a simplified version of the D406 SAF-T file starting January 1, 2025. This simplified version will only include information about purchases and sales carried out through their Romanian VAT ID.

Small businesses

Romania has implemented SAF-T in phases based on taxpayer size:

From January 1, 2022: Large taxpayers (with grace period until January 2023)
From January 1, 2023: Medium-sized taxpayers
From January 1, 2025: Small taxpayers and non-residents

Industry-specific requirements

Certain industries have specific requirements:

Financial institutions and insurance companies had a delayed implementation date (January 1, 2023)
Retail sector has special considerations for cash register transactions
Manufacturing sector has additional requirements for production and inventory tracking

File structure

The Romanian D406 follows the OECD SAF-T standard version 2.0 with country-specific adaptations:

Header section
- Contains metadata about the file, company, and reporting period
- Includes digital signature details
- Identifies the software used to generate the file
- Specifies contact information for responsible persons
Master files section
- Chart of accounts (aligned with Romanian accounting regulations)
- Customer and supplier source data
- Product and service catalogs
- Tax tables and codes
- Unit of measure tables
- Physical locations
General ledger entries section
- Journal entries
- Transaction details
- Account movements
- Opening and closing balances
Source documents section
- Sales invoices
- Purchase invoices
- Payments
- Inventory movements (for D406 Stocks)
- Asset transactions (for D406 Assets)
Additional Romanian-specific requirements
- Alignment with D300 VAT return
- Integration with e-Factura system
- Specific document numbering requirements
- Detailed tax analysis codes

Deadlines

Before filing the D406 SAF-T report, you should understand the submission deadlines based on your taxpayer category:

D406 General (Monthly): By the last calendar day of the month following the reporting period for taxpayers with monthly VAT reporting obligations.
D406 General (Quarterly): By the last calendar day of the month following the quarter for taxpayers with quarterly VAT reporting obligations and non-VAT registered entities.
D406 Assets (Annual): By the deadline for submitting the annual financial statements (typically May 31 of the following year).
D406 Stocks (On request): Within 30 days of receiving a formal request from ANAF (Romanian tax authority).

Missing these deadlines triggers immediate penalties, with no automatic grace period except for initial implementation phases.

Filing formats & methods

File format: XML, conforming to the schema published by ANAF
Character encoding: UTF-8
File size limit: Maximum 500 MB (files exceeding this limit must be split)
Final format: PDF with attached XML file
Submission methods:
1. SPV portal (Spațiul Privat Virtual): Primary submission channel
2. E-Guvernare portal: Alternative submission channel
3. API integration: For automated submissions (requires certification)

Note:

Unlike some countries, Romania has specific formatting requirements, including the unusual requirement to submit the XML file attached to a PDF.

Authentication

Files must be authenticated using:

Qualified electronic signature: Digital signature from an authorized provider
ANAF-issued digital certificate: Official certificate issued by tax authorities

Each submission receives a confirmation receipt that should be preserved as proof of filing.

How to file

Follow these steps to prepare and submit your D406 SAF-T file:

Prepare your D406 file.
- Extract required data from your accounting system
- Ensure all mandatory fields are correctly populated
- Verify data consistency across all sections
- Format according to XML specifications
Validate using ANAF tools.
- Use the validation tools provided by ANAF
- Check for structural, logical, and mathematical errors
- Resolve any validation issues before proceeding
- Document validation results
Generate the final submission file.
- Use the DUKIntegrator tool provided by ANAF
- Create the PDF with attached XML
- Apply digital signature
- Verify final file integrity
Submit through appropriate channel.
- Log in to the SPV portal
- Go to the D406 submission section
- Upload your prepared file
- Complete the submission process
Retain confirmation and monitor status
- Save the submission confirmation
- Check the SPV portal for processing status
- Address any reported issues promptly
- Maintain records of all submissions

Upon submitting your D406 file, you will receive an immediate technical receipt confirmation followed by a validation status notification typically within 24 hours. There is no subsequent "approval" notification - you will only hear from authorities if there are issues with your submission.

Post-submission process

The system performs automated validation checks
Cross-checking with other taxpayers' submissions may occur

Response requirements

If ANAF identifies issues or has questions after accepting your file, you must respond within the timeframe specified in their request. Maintaining good documentation of your accounting processes and transactions is essential for efficiently addressing these inquiries.

Respond to any official inquiries within the timeframe specified by ANAF (typically 5-7 days). A correction submission must contain the complete data for the reporting period, not just the corrected parts.

Archive expectations

All supporting documents and underlying data must be retained for the Romanian statute of limitations period (typically five years) from the end of the financial year. This includes:

Original accounting records
Supporting documentation for transactions
System documentation explaining data structures
D406 submissions and related correspondence

Electronic records must remain accessible throughout the retention period, with clear audit trails maintained between documents, entries, and reports. System changes or upgrades must not compromise access to historical data.

Each accounting entry must have supporting documentation that can be readily accessed if questioned during an audit. Changes to data after initial recording must follow proper accounting procedures with audit trails maintained.

Archived data must be secured against unauthorized changes. Access controls must be maintained throughout the retention period, and backup procedures must ensure data can be restored if primary systems fail.

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