The procedure for the organisation and registration in the optional RO e-Invoice Register and the registration form 081 “Request for registration in the optional RO e-Invoice Register/waiver of the request” were published: ANAF Order no. 3.788/2024

The takeaway 

Order of the President of the National Fiscal Administration Agency no. 3.788/2024 (OPANAF no. 3.788/2024) approved the procedure regarding the organisation and registration in the optional RO e-Invoice Register and the model, content and filing instructions of form 081 “Request for registration in the optional RO e-Invoice Register / waiver of the request for registration in the optional RO e-Invoice Register”. 

In detail 

The following entities that do not have to use the national RO e-Invoice system, but exercise this option, have to be registered in the optional RO e-Invoice Register: 

• The persons provided for in art. 294 para. (1) lit. j)—n) of the Fiscal Code, for supplies of goods/services in favour of diplomatic missions and consular offices, to the European Community, the European Atomic Energy Community, the European Central Bank, the European Investment Bank, etc. 

• The institutes/cultural centers of other states that operate on the territory of Romania based on intergovernmental agreements, for the deliveries of goods/services performed until 1 July 2025; associations and foundations established on the basis of Government Ordinance no. 26/2000, other non-profit/patrimonial associations, political parties and religious groups which are not registered for VAT purposes and which carry out economic activities, for invoices issued between 1 July 2024 and 30 June 2025.

• Individual farmers who apply the special regime for farmers, for invoices issued between 1 July 2024 and 30 June 2025.

• Economic operators not established in Romania, in business-to-business commercial relationships or in business-to-government relationships.

To request registration, the entities/persons mentioned above must submit form 081 by electronic means, and the registration in the optional RO e-Invoice Register has to be completed by the first day of the month following the submission of the form. From the moment of registration in the optional RO e-Invoice Register, the issuer also acquires the status of recipient. 

In the optional RO e-Invoice Register, all economic operators not established in Romania which opted for the use of the national RO e-Invoice system by submitting form 083, as well as those who were registered in the RO e-Invoice Register by submitting form 084, by 1 July 2024. 

The authorities will assign to the economic operator not established in Romania a record number, used only within the national electronic invoice system RO e-Invoice. Although the record number has the structure of the fiscal registration code/fiscal identification number. It is not a fiscal identification code in the sense of the provisions of the Fiscal Procedure Code. 

The waiver of the request for registration in the optional RO e-Invoice Register can be made until the date of registration in the optional RO e-Invoice Register, i.e. until the first day of the month following the submission of form 081. Registered taxpayers are deleted from the RO e-Invoice Register optionally, from the date of elimination from the Register of taxpayers/payers. 

Source: [Order of the President of the National Fiscal Administration Agency no. 3788/2024 for the approval of the Procedure regarding the organisation and registration in the optional RO e-Invoice Register, as well as the model, content and filling instructions of the form (081) “Request for registration in the optional RO e-Invoice Register / waiver of the request for registration in the optional RO e-Invoice Register”, published in the Official Gazette no. 736, dated 29 July 2024]