What changed for small taxpayers
SAF-T for small taxpayers in Romania is no longer a future obligation with a comfortable deferral attached to it. Since 1 January 2025 the D406 file has covered small taxpayers, newly incorporated companies and non-residents registered for Romanian VAT purposes. A grace period was granted for the first submissions only — six months for a first monthly report, three for a first quarterly one — and for taxpayers who entered on 1 January 2025 it expired during 2025.
In 2026 there is nothing left to wait for. Every period carries its ordinary deadline, and a taxpayer who never started is holding a backlog rather than a deferral: several periods to produce at once, using a mapping that has never been tested against a real file.
The full mechanics of the file, section by section, are on our page about the SAF-T D406 declaration. This article is about the transition itself.
Who is in scope
The obligation was phased in by taxpayer category and now reaches effectively everyone keeping double-entry accounts.
| Taxpayer category | In scope since |
|---|---|
| Large taxpayers | 1 January 2022 |
| Medium taxpayers | 1 January 2023 |
| Small taxpayers, including newly incorporated companies | 1 January 2025 |
| Non-residents registered for Romanian VAT | 1 January 2025, simplified file |
There is no turnover threshold. A company with three invoices a month files, a company with three thousand files, and a company with none files a nil report. The criterion is the accounting system, not the size of the business. Outside the scope are authorised individuals and family enterprises keeping single-entry accounts, and non-profit entities carrying on no economic activity.
Two categories deserve a word of their own.
Newly incorporated companies. The obligation starts with the company, not after a settling-in year. The grace period applies from the moment the obligation begins, which for a company incorporated in the middle of the year means a later, individual expiry date.
Non-residents. A company established abroad that holds a Romanian VAT number and nothing else files a simplified file. It reports the transactions carried out under that VAT number rather than the accounting records of the parent entity. If registration itself is still open on your side, the sequence is covered on the page about VAT registration for non-residents.
Deadlines, and what the grace period was worth
The ordinary deadline is the last calendar day of the month following the reporting period. Monthly VAT period means a monthly D406; quarterly VAT period, or no VAT registration, means a quarterly D406.
The grace applied to the first submissions only: six months for a first monthly report and three months for a first quarterly report, counted from the start of the obligation. For a company that entered on 1 January 2025 with monthly reporting, the earliest files fell due in the summer of 2025; after that, every period carried its own ordinary deadline again. A company whose obligation starts later — one incorporated during a year, or a foreign company registering for Romanian VAT now — still gets the grace, counted from its own start date.
The consequence is worth stating plainly. The grace period never reduced the number of files. It only moved them. A monthly filer who used the full deferral still owed one file per month for the whole of 2025, and by 2026 owes one for every month since. Anyone who has not started should assume the work is bunched, not spread.
The rest of the recurring calendar is mapped in the guide to the Romanian tax calendar.
Nil filings
A company with no activity in a period still files. This is the single most misunderstood point for small taxpayers, and it is misunderstood in a specific way: people assume that “nothing happened” means “nothing to send”.
A nil D406 is not an empty document. It contains the header with the identification data and the reporting period, and it contains the master data the file always needs, with the general ledger and source document sections empty. Producing it is quick once the mapping exists, which is exactly why the first nil file is not quick: the mapping has to be built before it can be reused.
Dormant companies, companies between projects, and non-residents whose Romanian VAT number was quiet for a quarter all fall here. Skipping the period does not go unnoticed, because the absence of a file is visible in the tax authority’s records at the same moment the deadline passes.
What to do now
- Establish your reporting frequency. It follows the VAT period. Companies that switched from quarterly to monthly during the year have to switch the D406 rhythm at the same point, and this is a frequent source of wrong-period filings.
- Build the mapping once, carefully. Transposing your accounts onto the reference chart, your VAT rates onto the codes in the official nomenclature, and your document types onto the required categories is the whole job. A mapping error propagates into every file that follows it.
- Update the VAT codes. Since 1 August 2025 the rates are 21% and 11%, under Law 141/2025. Files covering periods on either side of that date use different codes from the official nomenclature, and a nomenclature configured before the change will not carry them.
- Validate before submitting. The official validator rejects structural errors; it does not catch a coherent file built on the wrong mapping. Check the trial balance against the journal and the invoice totals against the VAT return before the file leaves.
- Do not skip nil periods. Generate them, validate them, submit them.
- Keep the receipts. The submission receipt is the only proof that a period was covered, and reconstructing it later is more work than storing it now.
Penalties
Article 337^1 of the Fiscal Procedure Code provides RON 1,000 – 5,000 for failing to submit the D406 within the deadline and RON 500 – 1,500 for an incorrect or incomplete file. The consolidated Fiscal Procedure Code is published by ANAF, and the technical documentation together with the official validator is published by ANAF.
The fine is charged per missing file, which is what makes a backlog expensive rather than merely late. A small taxpayer on a monthly VAT period that entered the obligation on 1 January 2025 and has filed nothing has, by September 2026, nineteen overdue monthly files — January 2025 through July 2026, the last of which fell due on 31 August 2026. At the minimum of RON 1,000 each that is RON 19,000, and at the maximum RON 95,000, before any separate sanction for an incorrect file among them.
Even so, the fine is not the main reason to take this seriously. SAF-T is the most detailed picture the tax authority holds of a business, and it is compared automatically against what counterparties report. A late file is a flag; an inconsistent file is an invitation.
The errors we see in the first submissions
- Unmapped analytical accounts, which pass validation but show balances on accounts that do not exist in the reference chart.
- VAT rates written as percentages instead of the codes from the official nomenclature.
- Partners without a tax identification number, or written differently from the identifier used in other filings, so the reports no longer reconcile.
- Wrong reporting period after a change of VAT period during the year.
- Skipped nil months by companies with no activity.
- Corrective files sent as partial updates. A correction replaces the original file in full, so it has to be complete rather than a difference.
None of these are difficult problems. They are all cheaper to solve before the first file than after the first rejection — and for anyone still outside the system, cheaper than the accumulating per-file fine that is now the alternative.
