Standard audit file for tax (SAF-T) submission obligations – taxpayer categories, reference data, grace periods and reporting deadlines: OPANAF 1783/2021

The takeaway

SAF-T reporting obligations apply as of: 

• 1 January 2022 for large taxpayers which were in this category during 2021; 

• 1 July 2022 for large taxpayers which were not in this category during 2021; 

• 2023 for medium-sized taxpayers, banking financial institutions, non-banking financial institutions and insurance/reinsurance companies; 

• 2025 for small taxpayers.

All taxpayers with monthly SAF-T reporting obligations will benefit from grace periods for the first five submissions.  

PwC has a dedicated team ready to assist you in preparing for the new SAF-T reporting system. That assistance includes access to a PwC-designed application which processes, checks and validates the SAF-T information, then generates the .xml format D406 statement. Our dedicated team is available to provide more details regarding the SAF-T preparation steps and our application. 

In detail

President of the National Agency for Fiscal Administration (ANAF) Order no. 1783/2021 (OPANAF 1783/2021) has been approved regarding taxpayers SAF-T reporting obligations, including the information required, the reporting model, procedures and conditions, submission deadlines and start dates. 

Submission of the D406 Informative Statement becomes mandatory as of:

• 1 January 2022 for large taxpayers which were in this category during 2021;

• 1 July 2022 for large taxpayers which were not in this category during 2021;

• 1 January 2023 for medium taxpayers which were in this category as at 31 December 2022;

• 1 January 2025 for small taxpayers which were in this category as at 31 December 2021;

• 1 January 2023 for banking financial institutions, non-banking financial institutions and insurance/reinsurance companies (including investment management companies, alternative investment funds, managers of alternative investment funds, managers of private pension funds and/or occupational pensions, and entities authorised, regulated and supervised by the Financial Supervisory Authority) in the large taxpayer category as at 31 December 2021.

Taxpayers which change size category will continue to submit the D406 Informative Statement in line with the requirements for the previous category until the next reference date for the new category.

Non-resident companies registered in Romania for VAT purposes (as permanent establishments and those registered directly or through fiscal representatives) also have SAF-T reporting obligations. 

Taxpayers will benefit from reporting grace periods of:

• six months for the first statement, five months for the second, four months for the third, three months for the fourth and two months for the fifth statement for taxpayers with monthly SAF-T reporting obligations;

• three months for the first statement for taxpayers with quarterly SAF-T reporting obligations.

Grace periods run from the last day of the reporting period for which the grace is granted.

Reporting process and deadlines

Taxpayers’ SAF-T D406 Informative Statement reporting obligations will be either monthly or quarterly based on the applicable fiscal period for value added tax (VAT). Taxpayers not registered for VAT purposes and those with a non-calendar tax year will submit the SAF-T file on a quarterly basis.

SAF-Ts will have to be submitted in electronic format with the following deadlines:

• For information not related to Stocks and Assets – by the last day of the month following that for which the reporting is performed (either monthly or quarterly).

• For the D406 Informative Statement for Assets – by the financial period submission deadline for financial statements. 

• For the D406 Informative Statement for Stocks – by the deadline established by the tax authorities, but no sooner than 30 calendar days as of the date of request. 

In addition to information provided by the Order, further details are to be published on the ANAF website regarding the SAF-T information requirements, a guide to preparing and reporting the D406 Informative Statement for SAF-T, the D406 Informative Statement submission procedure, start and submission dates for taxpayers’ SAF-T reporting obligations, and a list of except taxpayer categories. 

Source: [Order of the President of the National Agency for Fiscal Administration no. 1783/2021 on the nature of the information that the taxpayer/payer must declare through the standard audit file for tax (SAF-T), the reporting model, procedure and conditions, deadlines and start dates for taxpayer reporting obligations, published in the Official Gazette no. 1073 dated 9 November 2021]