e-Factura B2C in 2026: what changed and what it costs to get wrong

What actually changed, and when

Two dates are routinely merged into one in English-language summaries, and merging them produces the wrong control.

So the B2C flow is not new in 2026. What is new in 2026 is the clock, and it is the change most likely to be missed, precisely because it looks like a relaxation. It is not: it re-bases the deadline on the working calendar, which means a fixed-day reminder built in 2025 no longer matches the legal term in either direction.

Two structural consequences of the B2C mandate remain worth restating. First, the legal original of a B2C invoice is the file validated by ANAF, not the PDF emailed to the customer. Second, invoicing to consumers is no longer a purely internal process: every invoice carries a timestamp inside a state system, and any gap between what was issued and what was transmitted is visible without an inspection.

If the mechanics are new to you, the practical side is set out on our page about e-invoicing through RO e-Factura, including how the upload, the validation response and the archived file fit together.

Who is affected

The dividing line is establishment, not nationality. It is worth stating precisely, because it is the question foreign finance teams ask us most often.

A fixed establishment is a structure with sufficient human and technical resources in Romania to carry out supplies. A warehouse operated by a third-party logistics provider, on its own, is usually not one. An office with staff who negotiate and conclude local sales usually is. The distinction has always mattered for VAT; since the B2C mandate it also determines whether the group invoicing system has to speak Romanian XML.

For non-established companies, the B2C obligation does not apply. The company keeps invoicing under its ordinary rules, applying Romanian VAT where the place of supply is Romania, and the invoice issued under those rules is still the document its customer receives. For B2B transactions, however, it also transmits its invoices through RO e-Factura, for reporting purposes, in parallel with that ordinary invoicing. And it cannot ignore the system on the incoming side either: Romanian suppliers deliver their invoices to it through e-Factura, and those are the documents behind its input VAT. The wider picture is in the guide on VAT in Romania for foreign companies.

One practical point specific to the consumer flow: GEO 138/2024 confirmed that sellers are not obliged to collect the personal numeric code of an individual customer. Where the customer supplies no tax code, the B2C invoice carries a code formed of thirteen zeros. Customer masters built for a webshop are the usual place this rule gets discovered, at the first rejection.

The five-working-day deadline

The transmission term is five working days from the date the invoice is issued, and no later than five working days from the legal invoicing deadline set by the Fiscal Code. GEO 89/2025 introduced it from 1 January 2026, replacing a term counted in calendar days.

A worked example

An invoice is issued on Friday 6 March 2026. Counting working days only, and with no public holiday in between, the five days run Monday to Friday and the transmission deadline falls on Friday 13 March 2026.

Now take an invoice issued on Wednesday 29 April 2026, with 1 May a public holiday. The working days are 30 April, then 4, 5, 6 and 7 May: the deadline is Thursday 7 May 2026. A control written as “transmit within seven calendar days” would have reported the first invoice late and the second one early — which is exactly why a rule expressed in calendar days cannot stand in for one expressed in working days.

The deadline runs from issuance, which is a date you control. Where an ERP raises the document automatically at delivery, the clock starts then, not when the finance team notices. And under a five-day logic in either flavour, transmission is continuous rather than batched: an invoice dated the 28th has to be in the system in the first days of the following month, before anyone has reconciled anything.

What to do now

1. Confirm your status. Established, fixed establishment, or VAT number only. Everything else follows from that answer, and it should be documented rather than assumed.
2. Re-cut the deadline control for working days. A reminder set on a calendar-day rule is now wrong, and it is wrong silently.
3. Map which invoices are B2C. Sales to individuals, invoices issued on request to consumers, memberships, subscriptions, professional services to private clients. In many businesses this stream was never modelled separately in the ERP.
4. Check the customer data you hold. A B2C invoice still needs an identifiable recipient, with the thirteen-zero code where the individual gives no tax code.
5. Automate the transmission and keep the receipt. The response returned by the system is the proof that you met the deadline. Store it with the invoice, not in an inbox.
6. Align the accounting. The invoice register, the VAT return and e-Factura have to tell the same story. Where they do not, the difference is usually a timing convention rather than a real error, but it still has to be explainable. Our accounting service treats the two as one process rather than two.
7. Reconcile monthly. Count the invoices issued, count the invoices accepted by the system, investigate the difference. This single control catches most problems before they turn into fines.

Penalties

Under GEO 120/2021, the sanction for failing to transmit within the legal term is graduated by taxpayer category:

• RON 5,000 – 10,000 for large taxpayers;
• RON 2,500 – 5,000 for medium taxpayers;
• RON 1,000 – 2,500 for small taxpayers and for individuals carrying on a business.

Taken one at a time the amounts are moderate, and how they are applied in a given case depends on what the inspection establishes — the bands above are the sanction, not a forecast of the total. The risk is structural rather than nominal: a misconfigured interface does not produce one late invoice, it produces every invoice late, and the exposure scales with volume. There is a second effect on the recipient side as well, because an invoice that never entered the system is a weak document to rely on during an inspection.

The technical schema, the current status of the system and the official guidance are published by ANAF; consolidated legislative texts are available on legislatie.just.ro.

What goes wrong first

• Assuming B2C started in 2026. It started on 1 January 2025; what started in 2026 is the working-day clock. Companies that dated their first B2C control to 2026 have a twelve-month gap behind them.
• Treating the PDF as the original. Once the structured file is the legal document, the archive has to hold the XML and the system response, not a printout.
• Batching transmission monthly out of habit, which no five-day term supports.
• Consumer records that fail validation, because the customer master was built for a shop rather than for a tax filing.
• Credit notes forgotten. They are invoices too, they carry the same deadline, and they are the late transmissions we correct most often.
• Assuming the VAT number equals establishment. It does not, and the mistake runs in both directions. A fixed establishment issues through the system, B2C included; a company with only a VAT number reports its B2B invoices there alongside its ordinary invoicing and has no B2C obligation.

For companies that also file SAF-T, there is a useful side effect. The invoices transmitted through e-Factura and the invoices reported in the D406 come from the same population, so a monthly comparison between the two is the cheapest consistency check available. When the counts differ, the cause is almost always a document that exists in one system and not in the other, which is exactly the kind of difference ANAF can see automatically.

The obligation is a permanent part of the monthly cycle, not a project with an end date. The businesses that settle into it fastest are the ones that made transmission automatic and gave one person responsibility for the monthly reconciliation.