Order no. 2175/2025 issued by ANAF amends Order no. 1193/2021, updating the procedure for registering trust agreements, managing the Central Trust Register, and regulating access to it.
A trust is the legal operation by which real or patrimonial rights are transferred to one or more trustees for a specific purpose. Its legal basis is Law no. 129/2019 on anti-money laundering, which requires: submission of up-to-date information on the beneficial owner, organization of the central register, and conditions of access. The Civil Code also requires that trust agreements be registered with ANAF within one month, under penalty of absolute nullity.
Amendments introduced by Law no. 86/2025 strengthen access rules: only individuals or entities with a legitimate interest may consult beneficial ownership information, while simple requests are no longer sufficient.
Key changes under Order no. 2175/2025 include:
- updated procedure for accessing the Trust Register and similar legal arrangements;
- revised models and content of forms used for registration and access requests.
Access is granted in two steps: (1) online registration via the Virtual Private Space service and payment of an administrative fee, followed by (2) submission of an access request, including proof of legitimate interest and supporting documents.
Applications are processed by the competent tax authority, which verifies online registration, proof of payment, and documentation. If validated, access is confirmed via the Virtual Private Space. If legitimate interest is not demonstrated, the request is rejected.
These new rules align national procedures with EU standards, ensuring stricter control over access to beneficial ownership data as part of anti-money laundering measures.