Taxpayers, whether individuals or companies, against whom ANAF has started enforced collection, can request tax mediation. The procedure is provided by Article 230¹ of the Fiscal Procedure Code (Law no. 207/2015). The implementation rules, established by ANAF Order no. 1,757/2019, have been recently amended, and mediation sessions can now also take place online.
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The debtor has 15 days from the notification of payment summons to submit a notice expressing the intention to mediate.
The notice is sent:
- via SPV, if the debtor is registered;
- at the tax authority’s office or by post, if there is no obligation to use SPV.
- For companies with secondary offices registered for tax purposes, the notice is submitted by the parent company to the competent tax authority.
The notification automatically suspends the enforcement of tax obligations, fines, and other budget claims from the summons. However, if the tax authority sees an imminent risk that the debtor might hide or squander their assets, it can take precautionary measures.
Deadlines and the videoconference session Within a maximum of 2 days from receiving the notification, ANAF sends a notice regarding the organization of the mediation.
The meeting takes place within 10 days from the notification. If the debtor has valid reasons, the date can be rescheduled by mutual agreement, still within this period. The session is held at the ANAF office or online, on the MF–ANAF videoconference platform.
For the online option, the debtor announces their choice via SPV within 2 working days of receiving the notice. At the same time, they provide participant details and, if needed, the electronically signed authorization. Then they receive the access link. Conditions for videoconference sessions are set by ANAF President’s Order no. 705/2026.
How mediation takes place
The meeting is led by two representatives of the tax authority:
one from the payer records department and one from the enforcement department. Their hierarchical supervisors can also participate in the discussions.
Mediation has two objectives: Clarifying the fiscal situation. The payer’s record, tax returns, unresolved refund or reimbursement requests, and enforceable titles sent by other institutions are reviewed. The debtor can present any documents that support their position. Analyzing the economic and financial situation. The debtor shows that the financial difficulty is temporary and indicates the period in which they can pay. The goal is to find a solution to settle the debts or grant payment relief (installments or deferral).
Completing the mediation and resuming enforcement
The result is recorded in a report, in two copies: one for the debtor, one for the tax file. If the meeting was online, the minutes of the meeting must also be attached to the report.
Enforcement proceedings resume if:
- the debtor does not show up on the set date and time and has not requested a rescheduling. In this case, the enforcement continues immediately after the absence is recorded in the official report;
- 15 days pass from the official report without the debts being paid and without any request for payment relief being made. If it is found that the debtor does not meet the conditions for relief, they must pay the full amount within the same 15-day period.
Legal basis:Law no. 207/2015 regarding the Tax Procedure Code, with subsequent amendments and completions (art. 230¹); Order of the ANAF president no. 1,757/2019 for the approval of the Mediation Procedure and the documents that debtors submit to support their economic and financial situation; Order of the ANAF president no. 992/2026 for amending and completing Order no. 1,757/2019.