What ANAF released in August 2026
On 26 August 2026, in press release 782, ANAF published two free tools on its SAF-T page:
- The D406 checker (tool 6 on the SAF-T page: AppVerifXML, as TestSaftW with a window or TestSaftT from the command line). It runs the consistency tests on the XML files in a folder and writes a CSV file listing the errors found and the test behind each one.
- The D406-to-D300 template (tool 7: D300_2026, version 2.0 updated on 18 September 2026). It reads the SAF-T file and builds a 300 VAT return, which you can export as PDF, XML or JSON.
ANAF says the checks run on the user’s computer and that no data is sent to ANAF at this stage. Both tools are in testing from September to November 2026, and feedback goes to saft@anaf.ro.
The press release also gives the reason. Of about 870,000 companies filing SAF-T, about 580,000 also file a VAT return. ANAF built the tools after a pilot phase in which it found files with errors and mismatches. In practice, ANAF already compares the two returns, and you can now run the same comparison before you file.
Why the two returns do not match
D406 and D300 do not measure the same thing. SAF-T reports what was booked in the month. The VAT return reports VAT that became chargeable in the period and the deduction exercised in the period (article 323(2) of the Tax Code). Most months the figures agree. When they do not, the cause is usually one of these:
| Cause | What the comparison shows | Legal basis | Error? |
|---|---|---|---|
| Purchase invoice received after the VAT return was filed, booked in the month of the service | Higher input VAT in SAF-T than in D300 | art. 301(2) Tax Code: deduction in a later return | No, if deducted in a later return |
| Error from another month corrected in the current return | D300 has amounts on the adjustment rows that the month’s SAF-T does not | art. 323(3) Tax Code | No |
| VAT cash accounting (yours or your supplier’s) | VAT booked to account 4428, chargeable or deductible only on collection or payment | art. 282(3), art. 297(2)–(3) Tax Code | No, if 4428 is reported correctly |
| Pro rata | The annual adjustment appears in the December return | art. 300(14) Tax Code | No |
| Wrong or missing tax code on a line with VAT | The transaction lands on another row or is missing from the D300 template | tests 1, 3, 7–11 of the second series | Yes, in SAF-T |
| Rate that does not match the base | SAF-T VAT differs from base × rate | tests 20–22 (first series), test 2 (second series) | Yes |
| Invoice missing from one of the returns | Base and VAT gap with no explanation | art. 337^1 Tax Procedure Code, if missing from SAF-T | Yes |
The first four rows are timing or mechanism differences that the Tax Code allows. You explain them; you do not correct them. The last three are errors. Errors in SAF-T are fixed with a corrective D406; errors in the VAT return are fixed through the adjustment rows of a later return.
What ANAF’s tests check
ANAF has published two series of D406 consistency tests. The first, on 9 March 2023, has 22 tests: mandatory fields in the header and master files, equal debit and credit balances, closing balances matching the next month’s opening balances, equal debit and credit turnover, and VAT on each invoice line. The second, on 19 August 2024, has 11 tests on journal entries with VAT (the General Ledger Entries section). These explain most gaps with the D300:
- a line has non-zero VAT but tax code 000000 (tests 1 and 3);
- the VAT on a line does not equal the base multiplied by the rate of its tax code (test 2);
- a line on an account starting with 4426, 4427 or 4428 has no tax information (tests 4–6);
- codes for exempt, non-taxable or reverse-charge supplies, which the VAT return reports on rows 1, 2, 3, 3.1, 4, 13, 14 and 15, carry non-zero VAT (test 8);
- reverse-charge purchases show zero VAT on lines outside accounts 4426 and 4427 (test 9);
- self-assessment journal entries do not carry codes 380001–380005, or carry zero VAT (test 11).
The D300 template maps SAF-T tax codes onto VAT return rows. A wrong code moves the transaction to another row or drops it from the calculation, even when the total payable comes out right.
Worked example: September 2026
A Romanian subsidiary of an Austrian group, filing VAT monthly, submitted its D300 for September 2026 on 26 October (25 October was a Sunday). Before the D406 deadline for September, 2 November 2026 (31 October is a Saturday), the finance team loads the file into D300_2026.
| D300 template from SAF-T | D300 filed | Difference | |
|---|---|---|---|
| Output VAT | RON 42,000 | RON 45,150 | +RON 3,150 |
| Input VAT | RON 32,100 | RON 30,000 | −RON 2,100 |
| VAT payable | RON 9,900 | RON 15,150 | +RON 5,250 |
The RON 5,250 gap in VAT payable comes from three transactions:
- A sales invoice dated 31 August, with RON 1,050 VAT, was in the August books and the August SAF-T but missing from the August VAT return. The company declared it in the September return, on the adjustment rows (article 323(3)). The September SAF-T has no reason to contain it. The RON 1,050 difference in output VAT is justified.
- An invoice for September maintenance, with RON 2,100 VAT, arrived on 28 October, after the return was filed. The accountant booked it in September, on the service date, so it shows as input VAT in SAF-T but not in D300. The company deducts it in the October return (article 301(2)). The RON 2,100 difference in input VAT is justified and closes in October.
- Consulting services from the parent company in Austria, under the reverse charge: RON 10,000 base and RON 2,100 VAT, declared as output and input VAT in the same return. The D300 is right. In SAF-T, the output VAT line of the self-assessment entry carries tax code 000000 (the case in tests 1 and 3) and the input line carries a domestic purchase code at 21%. The template misses RON 2,100 of output VAT and treats the deduction as a domestic purchase. This is an error in SAF-T: the real VAT payable does not change, but the file is incorrect.
The first two transactions need no correction, only a reconciliation note kept in the month’s file. The third needs a corrective D406 for September with the right self-assessment code. Article 337^1(3)(a) of the Tax Procedure Code does not fine a file corrected before the legal deadline of the next file, the D406 for October: 30 November 2026, moved to 2 December because 30 November and 1 December are public holidays. After that date, the fine for an incorrect file is RON 500 to 1,500.
To check late-payment interest on VAT declared late, use the ANAF interest and penalty calculator. It does not apply in this example: the VAT was declared and paid on time, and the differences are only in the reporting.
Calendar for autumn 2026
| Date | What happens | Legal basis |
|---|---|---|
| 26 August 2026 | ANAF publishes the D406 checker and the D300 template | ANAF press release 782 |
| 18 September 2026 | Version 2.0 of D300_2026 | ANAF SAF-T page, tool 7 |
| 26 October 2026 | D300 for September (25 October is a Sunday) | art. 323(1) Tax Code, art. 75 Tax Procedure Code |
| 2 November 2026 | D406 for September (31 October is a Saturday) | annex 4 to ANAF Order 1783/2021, art. 75 Tax Procedure Code |
| 25 November 2026 | D300 for October | art. 323(1) Tax Code |
| November 2026 | The testing period of the tools ends | ANAF press release 782 |
| 2 December 2026 | D406 for October (30 November and 1 December are public holidays); last day to correct the September D406 without a fine | annex 4, art. 337^1(3)(a) Tax Procedure Code |
The exact deadlines for your company, by VAT period and by the returns you file, are in the Romanian tax deadlines calendar.
Checklist before filing
This is the order we follow each month, after closing the books and before the D406 deadline:
- Run the D406 checker on the XML file and open the error CSV, if one was created.
- Generate the D300 template from the same file and compare it with the filed return row by row, not just on totals.
- For each difference, look for the cause in the table above: delayed deduction, adjustment, cash accounting, pro rata.
- Trace any difference without a cause back to the invoice and to its SAF-T tax code.
- Correct SAF-T with a corrective D406 before the next file is due, and the VAT return through adjustments in the next return.
- Keep a short reconciliation note for each month: amount, cause, the return in which it closes. It is the first document you will need if ANAF sends a non-compliance notice.
The comparison is most useful before the 25th, on a provisional SAF-T file for the month: an error found then is corrected directly in the VAT return before filing, without an adjustment.
Foreign companies registered for VAT in Romania
A company established abroad that only holds a Romanian VAT number files a reduced SAF-T: the header, the master tables and the sales and purchase invoices, with no accounts and no journal entries. We explain the structure in the article on SAF-T for non-resident companies. For reconciliation, this means the second series of tests concerns the General Ledger Entries section, which the reduced file does not contain, and the D300_2026 guide does not describe separate handling for this type of file.
For non-residents, the gaps come from other sources than for a Romanian company. Cash accounting is not one of them: article 282(3^1) of the Tax Code reserves it for taxable persons with their place of business in Romania. These are common instead:
- stock transfers from a warehouse in another member state, declared in D300 as intra-Community acquisitions but missing from SAF-T when the ERP issues no document for the transfer;
- invoices issued in euro and converted at one exchange rate in D406 and at another in the VAT return;
- purchase invoices from Romanian suppliers booked in the foreign ERP in a different month from the one in which the deduction is exercised.
For foreign companies, compare invoice by invoice: the SalesInvoices and PurchaseInvoices lists on one side, the D300 and D394 rows on the other. We build the D406 export from the client’s ERP and run this reconciliation every month as part of our Romanian VAT compliance service.
How we can help
We prepare and file the D406 and the VAT return in the same month, from the same records, with the reconciliation between them done before the deadline. The details are on our SAF-T (D406) and VAT return (D300) pages. If you have already received a SAF-T non-compliance notice, send us the file and the VAT return for the month in the notice and we will tell you what can be explained and what needs correcting.
