Stricter guarantee and eligibility criteria for importers and IOSS
Romania has repealed the old framework for the special import VAT mechanism (Order 1.019/2021) and replaced it with new rules under Order 2618/2025, tightening eligibility and compliance.
Key updates include a ban on inactive taxpayers applying, mandatory notification within 3 days of changes to the Import One Stop Shop filer, a new authorisation number format, and a guarantee requirement for deferred VAT.
See more in our Romanian VAT guide.
Why tightening the rules now?
- The stricter guarantee and eligibility criteria reduce the risk of VAT leakage, as only solid operators can access the scheme.
- The new national import system (automation) supports more efficient control and data sharing between customs and tax authorities.
September 2025 new rules
On 25 September 2025, Order No. 2.201/2025 was published in the Official Gazette (No. 877), repealing Order No. 1.019/2021, which had until now governed the rules for the special mechanism for the declaration and payment of import VAT (i.e. the regime whereby certain importers could defer or simplify import VAT obligations).
This change is not just a technical “housekeeping” move: it aligns this regime with the newer Order No. 2618/2025 issued by the Romanian Customs Authority (AVR), which entered into force 3 September 2025. In effect, 1.019/2021 becomes obsolete, and the new authorization rules and procedural requirements take over.
What is the “special import VAT” scheme?
The “special mechanism” (sometimes called “regime special” or “special scheme for import VAT”) is a mechanism that allows qualified importers to carry out import VAT formalities differently than in the standard model. In particular, for low-value goods (up to EUR 150, with transport ending in Romania), the special mechanism allows certain authorized parties (e.g. express couriers, postal operators, customs brokers) to defer or simplify VAT payment and reporting, collecting VAT from the end-recipients.
Under the old regime, that mechanism was regulated by Order 1.019/2021. But the new legal and procedural environment in 2025 made an update necessary.
Key changes on Romanian imports
Here are the main updates introduced in 2618 and their implications:
| Change / new feature | What’s new | Implications / what to watch |
| Repeal of the old order | Order 2.201/2025 formally repeals 1.019/2021, removing any residual legal basis for that older regime. | From now on, all matters must refer to 2618/2025; any transitional ambiguities should be handled in line with 2618. |
| New condition: not in inactive-taxpayer register | Applicants must not be listed in the special register of inactive taxpayers. | Entities that may have been borderline for “inactive” status must ensure they are active (i.e. maintaining proper filing status, no suspension) before applying. |
| Notification of changes in designated IOSS return filer | Authorization holders must inform authorities within 3 days of any change in the person designated to submit the IOSS (Import One Stop Shop) VAT return. | This imposes a tighter administrative compliance burden — if you change your IOSS-return agent or internal handler, you must proactively notify in 3 days to avoid potential sanctions or doubts over the validity of returns. |
| Changed format of authorization number | The format now includes two extra digits at the front marking the issuing year. | In internal systems and document checks, parties must accommodate the new numbering format (e.g. in validation logic). |
| Scope and eligibility clarifications | The authorization remains limited to consignments with intrinsic value ≤ EUR 150 and whose transport or dispatch ends in Romania. | Importers and express carriers must ensure that all conditions (value ceiling, delivery destination) are satisfied before applying the scheme. |
| Guarantee requirement & procedural steps | Under 2618, applicants must furnish a guarantee (via deposit or bank guarantee) covering the maximum amount of deferred VAT (calculated using a defined formula). The customs office reviews and assesses the guarantee. | Cash flow and capital tie-up become more significant. Prospective users of the scheme must plan for the guarantee cost and possible timing of constitution. |
| Other standard eligibility conditions | As before, the applicant must be registered for VAT, have no outstanding tax or customs debts, not be in insolvency, etc. | Entities must ensure full compliance and clean standing before applying; past defaults or debt issues may block authorization. |
Because 1.019/2021 is now officially repealed, importers or operators that relied on the older version must now re-assess whether their authorization remains valid under the new rules (or reapply under 2618). There could be transitional or grandfathering provisions, but none is obvious from the publicly available text.
