Form 800 in Romania: A new declaration to help correct discrepancies in reporting through the e-Invoice system | News Flash

What is Form 800 in Romania, the non-receipt declaration for invoices in the e-Invoice system and why must it be submitted if you don’t receive the invoice in e-Invoice system in 5 calendar days from the invoice issuance date?

Starting September 30 2025, ANAF Order no. 2.229/2025, published in the Official Gazette no. 895/2025, introduced Form 800 in Romania – “Notification regarding invoices for the supply of goods/provision of services paid at the time of delivery/performance, not transmitted through the RO e-Invoice system within the deadline stipulated in Article 10(7) of GEO no. 120/2021.”

Who is required to submit Notification Form 800 in Romania?

The recipient (taxable person) must submit Form 800 to declare that they have not received the invoice issued through the RO e-Invoice system within the legal timeframe (i.e., 5 calendar days from the invoice issuance date, but no later than 5 calendar days from the legal deadline for issuing the invoice, as per Article 319(16) of the Fiscal Code) for transactions where payment was made at the time of delivery or performance.

Form 800 is not required if the payment was made in advance, prior to delivery / performance, according to Article 10(7) of GEO 120/2021.

What are the obligations of the issuer who failed to transmit the invoice in SPV?

Upon receiving the notification from the recipient, ANAF sends an official message via the Virtual Private Space (known as SPV in Romanian) to the issuer, informing them of the obligation to upload the missing invoice into the system.

The issuer must comply no later than the day following receipt of the message and must also complete the upload index provided within the RO e-Invoice system after transmitting the invoice.

Once the message is sent, the notified issuer is automatically registered in a special electronic registry managed by ANAF. Taxpayers listed in this registry are subject to fiscal risk analysis, and depending on the outcome, may be subject to appropriate legal measures, including audits or penalties.

Penalties for late submission

The ANAF Order 2.229/2025 does not explicitly specify penalties for failing to submit Form 800 in Romania.

However, non-compliance with reporting obligations may result in sanctions under the Fiscal Procedure Code, including fines for failure to declare, rejection of fiscal documents, or initiation of a tax audit. Timely compliance is strongly recommended to avoid administrative and fiscal risks.

Practical recommendations:

• Regularly verify that all invoices for transactions paid at delivery are received via the RO e-Invoice system.
• If an invoice is missing, submit Form 800.
• Update internal procedures and train accounting staff.
• Ensure proper archiving of submitted notifications and supporting documents.
• Monitor any additional clarifications published by ANAF.

Form 800 introduces a new compliance obligation aimed at correcting discrepancies in reporting through the RO e-Invoice system.

Even though the order does not detail specific penalties, compliance is essential to avoid fiscal and administrative issues.

We recommend prompt implementation of internal procedures to ensure accurate and timely submission.

For assistance with internal procedure implementation, accounting system configuration, or other reviews support, our Accace Romania team is at your disposal.

Nicoleta Dumitriu

Accountant | Accace Romania

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