D394 Romania: the domestic listing that ANAF matches against your customers

What the D394 is and why ANAF relies on it

The D394 is Romania’s informative declaration on supplies, services and acquisitions carried out on national territory. It is not a tax return: no tax is assessed or paid with it. It is a listing — a line for each Romanian counterparty, with tax identification number, taxable base and VAT, split by rate and by transaction type.

Its purpose is matching. Your supplier declares that it invoiced you RON 100,000 plus VAT in March; you declare that you were invoiced RON 100,000 plus VAT in March. ANAF compares the two automatically, at national scale. Where the two sides disagree, the system produces a mismatch, and the mismatch produces a letter.

That mechanism explains why the D394 punches above its weight. It carries no payment, yet it is the filing that most reliably tells the tax authority where to look. Together with the D300 VAT return and the SAF-T D406 file, it forms a triangle that has to close.

Who has to file the D394

The obligation attaches to persons registered for VAT purposes in Romania under art. 316 of the Fiscal Code who carry out transactions on Romanian territory. For a company established in Romania, the Romanian VAT registration is the test. For a non-established company the test is narrower: it files only where it carries out domestic transactions with persons registered for VAT in Romania.

For foreign companies the practical question is narrower than it looks. A warehouse in Romania that only serves dispatches to other member states generates D390 lines, not D394 lines. The moment the same warehouse serves a Romanian VAT-registered customer, or a Romanian VAT-registered logistics provider invoices local VAT on its services, the D394 becomes live. Without transactions of that kind, there is no D394 to file. Full context on the surrounding obligations is in the guide to VAT in Romania for foreign companies.

What the return contains

The D394 is structured in sections, and the sections matter more than the totals because each one is matched differently.

• Transactions with persons registered for VAT in Romania. The core of the return: supplies and acquisitions listed by counterparty tax identification number, with taxable base and VAT split by rate and by type of operation, including domestic reverse-charge transactions.
• Transactions with persons not registered for VAT, including taxable persons below the threshold and public institutions, reported in aggregate rather than name by name.
• Transactions with non-taxable persons — individuals. Reported in aggregate, with additional detail for certain categories of goods.
• Information from electronic fiscal cash registers, so retail turnover is visible even where no nominal invoice exists.
• Summary data on the number of invoices issued and received, and totals by VAT rate, used as a sanity check against the D300.

Since the rate change of 1 August 2025, the split by rate has to use 21% and 11%. A return still built on 19% and 9% columns will not reconcile with either the VAT return or the counterparty listings.

Deadlines

The D394 follows the VAT fiscal period and is due by the 30th of the month following the reporting period. The one systematic exception is the January period, reported by the last day of February — 28 or 29 depending on the year. Where the 30th falls on a weekend or public holiday, the deadline moves to the next working day.

The practical consequence of the 30th is that the D394 is prepared after the VAT return for the same period, which was due on the 25th. That five-day gap is often used to make the D394 agree with a D300 that has already been filed, which is the wrong order: the two should be produced from the same extract at the same moment. The full deadline map sits in the Romanian tax calendar.

Penalties and the real exposure

Failure to submit an informative declaration within the deadline is sanctioned with a fine under the Fiscal Procedure Code (Law 207/2015), in bands that depend on the taxpayer’s category. The consolidated text is published by ANAF.

The fine is not the point. The exposure that matters is what a missing or inconsistent D394 does to your position:

• Mismatch letters. Every unmatched line generates a request for clarification with a short response deadline.
• Deduction risk. Where a supplier did not declare an invoice you deducted, the burden of demonstrating the transaction moves to you.
• Inspection selection. Persistent mismatches are one of the strongest signals in the risk model that decides who receives a tax inspection.

How we prepare and file your D394

We treat the D394 and the D300 as one job with two outputs, produced from the same extract, on the same day.

1. We receive the period’s data — an ERP export, sales and purchase journals, or listings in Excel. Format is not a constraint; our generator builds Romanian declarations directly from structured data.
2. We validate the counterparty master data. Romanian tax identification numbers are checked for format and validity, and partners without a valid code are separated out before the return is built, because they belong in a different section.
3. We reconcile in three directions. D394 totals against the D300 boxes for the same period, domestic lines against the SAF-T source documents, and — where the volume justifies it — high-value counterparties against their own reporting behaviour in previous periods.
4. We file through the Virtual Private Space with our qualified digital certificate, under a written mandate, and return the ANAF receipt with a short reconciliation note.

Where mismatch letters arrive for earlier periods, we handle the response: identify the line, produce the invoice evidence, and answer within the deadline. The filing itself stays with us throughout: your team supplies the data, and never has to work through the Romanian return specifications.

Specific situations

Foreign companies with a Romanian warehouse. The distinction between a domestic supply and an intra-Community dispatch decides whether a transaction lands in the D394 or the D390 EC Sales List. Getting the flow types tagged correctly in the source system is worth more than any amount of correction later.

Marketplace sellers. Platform exports usually aggregate. The D394 needs counterparty-level detail for Romanian business customers and rate-level detail for sales to individuals, which means the export has to be specified accordingly at the start of the engagement.

Companies with high volumes of small invoices. Retail and hospitality generate a large cash-register section and a small nominal section. The reconciliation runs against the daily fiscal reports and, since 1 January 2025, also against B2C invoices transmitted through RO e-Factura.

Dormant Romanian VAT numbers. For a company established in Romania, no transactions still means the period has to be observed — a five-minute filing that prevents a wholly avoidable fine. A non-established company with no domestic transactions with Romanian VAT-registered persons files no D394.

The errors we see most often

• Nil periods skipped by companies established in Romania, on the assumption that a listing with no lines does not need to be sent.
• Counterparty codes written differently in the D394 and in the SAF-T file, so the two filings no longer reconcile even though both are individually correct.
• Credit notes recorded in a different period from the counterparty, which produces a mismatch that is real but harmless — and still has to be answered.
• Intra-Community acquisitions dropped into the domestic section, or the reverse, usually because the flow type was never tagged in the source system.
• The D394 rebuilt from a second extract after the D300 was filed, so the two are close but not equal.
• Old VAT rate columns left in place after August 2025.