On April 8, 2025, ANAF Order no. 407/2025 was published in the Official Gazette no. 310. This order updates and replaces Annex no. 5 to ANAF Order no. 1783/2021, regarding the nature of information to be reported through the Standard Audit File for Tax (SAF-T), the reporting model, procedure, conditions and deadlines for submission, as well as the effective dates for different categories of taxpayers.
Updated reporting deadlines based on taxpayer category
The order clearly specifies the reference dates from which the obligation to submit Form D406 (SAF-T) begins for each taxpayer category:
- Large taxpayers (as of 01.01.2022 and in 2021) – reporting starts on January 1, 2022.
- Large taxpayers (as of 01.01.2022 but not in 2021) – reporting starts on July 1, 2022.
- Medium taxpayers (as of 31.12.2021) – reporting starts on January 1, 2023.
- Small taxpayers (not classified as large or medium as of 31.12.2021 and maintaining this status after 01.01.2022) – reporting starts on January 1, 2025.
- Non-resident taxpayers registered solely for VAT purposes in Romania – reporting starts on January 1, 2025.
- Taxpayers who changed category after 2021 – reporting start date depends on the new category: January 1, 2023 (for medium) or January 1, 2025 (for small).
- Newly registered taxpayers after the reference date – reporting starts from the effective registration date, with the first submission due on the last day of the month following the reporting period.
Special rules and exceptions
- Taxpayers who voluntarily submitted SAF-T before their mandatory reporting date cannot reverse this option. It becomes binding only after a D406 is validated by ANAF.
- If a taxpayer moves into a category without an obligation to file SAF-T, the reporting obligation continues.
- Credit institutions, non-banking financial institutions, and insurance/reinsurance companies classified as large taxpayers as of January 1, 2022, will start reporting from January 1, 2023.
- Fund managers, brokerage firms, and other entities supervised by the Financial Supervisory Authority (ASF) will start reporting after January 1, 2023, on a date to be later established by ANAF.
Who is required to submit Form D406 (SAF-T)?
The following entities are subject to the SAF-T reporting obligation:
- Autonomous administrations, national R&D institutes;
- All forms of commercial companies: SA, SCA, SCS, SNC, SRL;
- National companies/societies;
- Cooperative organizations (OC1, OC2, OC3);
- Romanian branches of foreign legal entities;
- Foreign legal entities with a permanent establishment or effective management in Romania;
- Non-profit associations keeping double-entry bookkeeping;
- Entities organized under the Civil Code (e.g. pension funds, investment funds);
- Non-resident entities registered for VAT purposes in Romania.
Who is exempt from submitting Form D406?
The following categories are exempt from the SAF-T obligation:
- Sole traders, self-employed individuals (PFA), family enterprises (II, IF), freelancers;
- Individual medical, legal, notarial, or insolvency practices;
- Public institutions and government authorities;
- Entities managing classified information;
- Non-profit associations/entities using single-entry bookkeeping;
- Entities temporarily suspended, both in the trade register and at other authorizing bodies;
- Other individuals performing liberal professions governed by special laws.
ANAF guidance and updates
Detailed information on deadlines and categories of obligated or exempt taxpayers is available in the “Taxpayer’s Guide for the preparation and submission of the SAF-T Informative Statement (Form D406)”, published on the ANAF website.