Romanian Standard Audit File for Tax returns in phased launch 2022-25
The Romanian National Agency for Fiscal Administration (ANAF) has launched a phased rollout of its OECD SAF-T based program. SAF-T in Romania is known as Declarației informative (Informative Statement) D406 return, and is in XML format. This is based on the following waves:
- Jan 2022 – large taxpayers first wave (12-month soft landing to 31 Jan 2023)
- Jul 2022 – large taxpayers second wave (6-month soft landing to 31 Jan 2023)
- Jan 2023 – mid-sized taxpayers
- Jan 2025 – small taxpayers
- Jan 2025 – non-resident taxpayers
Non-resident taxpayers with a Romanian VAT number may be required to complete SAF-T from January 2025 – but to be confirmed.There is a reduced data set requirement for non-resident VAT registered businesses. RO e-invoicing is starting in January 2024.
SAF-T in Romania is known as Declarației informative (Informative Statement) D406 return, and is in XML format. Voluntary testing is now underway ahead of the 2022 mandatory launch. It will be phased in between January 2022 and January 2025 – subject to the six-month grace period.
Check which countries have implemented SAF-T.
Romanian SAF-T filing obligations – monthly reporting
D406T returns will be due on a monthly basis in line with the VAT return obligations. There will be an initial 6-month grace period where submissions do not have to be completed to the new timetables. The D406T is due by the final day of the following month. For taxpayers with turnover not exceeding RON500,000 per annum, this is quarterly in line with their VAT filing obligation. There is also:
- Annual reporting of capital or fixed assets, due by the following 31 January; and
- On-demand stock movements reports should be available within 30 days of a request from ANAF.
The first returns for large taxpayers which are published on ANAF’s website, will therefore by due in February 2022 – but with an optional six-month grace . No implementation date for medium-sized companies has been made public. Small enterprises will start in January 2025.
SAF-T D406T structure
ANAF have been consulting with business groups on the development of the transactional-based reporting obligation. It will follow the OECD model (v2.0). It has now issued speficiations, including:
- SAF-T_Romania_SchemaDefinitionCodes.xlsx: the structure of the Romanian SAF-T format
- Romanian_SAF-T_Financial_Schema.xsd – the schema to be adopted under the XML format
- Annex SAF-T – Structura_D.docx – the tax office’s validation rules
The proposed return is structured as follows:
- Header – company details and software used for preparation
- Mater Files
- General Ledger Accounts
- Customer details
- Tax table
- OUM table
- Analysis Type Table
- Product details
- Warehouse inventories
- Fixed assets ledger
- General Ledger – transaction-level details to assist in tax assessment
- Source documentation
- Sales invoices
- Purchase invoices
- Movements of stocks
- Fixed asset movements (due annually)
Voluntary reporting started in August, and large taxpayers will be mandated to submit SAF-T filings from the start of 2022. It is expected that businesses will submit three ledgers on a monthly basis (journals; receivables; and payables). A fixed ledger will be required annually. The fifth ledger, warehouse stocks, will only be on demand.
How to compile the D406 statement
- Prepare the XML files in accordance with the listing above
- Use a structure verification tool to be provided by ANAF to validate the strucuctures
- Create D406 in PDF format with XML attached along with ANAF-issued digital signature of the taxpayer
- Ensure receive ANAF electronic receipt of upload
How to submit SAF-T D406
Taxpayers have three options for filing their XML SAF-T D406:
- From adapted ERP and accounting information;
- Using an XML editor to convert accounting information
- Third-party specialist service provider who can extract, prepare and submit the return on the taxpayer’s behalf.
SAF-T by OECD to harmonise tax data exchange
SAF-T is an OECD developed standard schema for the exchange of data between tax authorities and businesses. It was developed in 2005, and has been so far adopted in: Poland; Norway; Portugal; France; Luxembourg; Austria; and Lithuania. Hungary is looking to be the eighth country in two years’ time.
Standard Audit File for Tax SAF-T countries
|Country (click for details)||Date||Scope|
|14||Ukraine||Jan 2025||Phased 2025 to 2027 implementation|
|13||Bulgaria||Jan 2025||Phased introduction over two years|
|12||Denmark||2024?||Phased implementation from 2024|
|11||Romania||Jan 2022||Mandatory monthly filings initially large taxpayers (due Jan 2023)|
|10||Hungary||2024||eVAT digital ledgers|
|9||EU OSS & IOSS||Jul 2021||On-demand for sellers, marketplaces or Intermediaries|
|8||Norway||2020||Replaced VAT return 2022|
|6||Lithuania||2019||On-demand; residents and non-residents above €30,000 sales threshold|
|5||Poland||2016||Mandatory, monthly replaced VAT return Oct 2020|
|1||Portugal||2009||Monthly for residents and non-residents (Jun 2022)|