SAF-T reporting process in Romania: Automatic notifications for taxpayers who fail to submit their declarations

SAF-T (Standard Audit File for Tax), created by the Organisation for Economic Cooperation and Development (OECD) in 2005 and updated in 2020, is an international standard for the electronic exchange of accounting data between companies and tax authorities. SAF-T reporting process in Romania was implemented through Government Ordinance No. 11/2021, which mandates the phased submission of the declaration starting from 1^st January 2022. Initially, large taxpayers were required to submit, followed by medium-sized taxpayers, with the final phase set to begin on 1^st January 2025, when small taxpayers and non-residents registered for VAT purposes in Romania will also need to prepare and submit their reports.

How the notification mechanism works for the SAF-T reporting process in Romania

To ensure the accuracy of reported data, ANAF (the National Agency for Fiscal Administration) has recently implemented an automatic notification mechanism for taxpayers who have failed to submit, have submitted incorrectly, or have submitted incomplete D406 (SAF-T) declarations. This initiative is part of an effort to enhance the analysis of data collected through SAF-T, which serves as an international standard for the electronic exchange of accounting data between companies and tax authorities.

On 20^th August 2024, ANAF sent over 15,000 notifications to taxpayers who did not fulfill their legal obligations regarding SAF-T reporting for June 2024.

Taxpayers who received these notifications have access to detailed reports of non-compliant transactions included in the enclosed PDF documents. Companies that incorrectly submitted D406 have been notified to correct their errors by 30^th September 2024, to avoid additional penalties. Those who did not submit D406 at all have a 30-day deadline to rectify this.

Errors in the declarations were identified through consistency tests published on ANAF’s website, specifically targeting the “General Ledger Entries” section. According to experts from Accace Romania, the following issues were identified:

• Verification of consistency between the tax amount and the corresponding tax code. The error may involve an inaccurate tax code, an incorrect tax amount, or the erroneous declaration of the tax on a partner account.
• Verification of a non-zero tax amount when no tax code is present. The error could be due to incorrect entry of either the tax amount or the tax code.
• Verification of an erroneous tax amount on an entry related to one of the following accounting accounts: 4426, 4427, 4428.
• Verification of the absence of the General Ledger Entries section or incomplete submission of the declaration.

The notification also includes an email address for taxpayers to contact if they encounter uncertainties or notice inaccuracies in the provided analysis. In cases of non-submission, the notification mentions several contacts within the Fiscal Administration for large or medium-sized taxpayers, depending on the case, who can be approached for further information.

Risks of not complying with SAF-T reporting requirements

Reporting errors or delays are often perceived by tax authorities as indicators of irregularities or potential tax evasion, triggering detailed inspections of a company’s entire financial activity.

Failure to submit the D406 Informative Declaration within the legal deadlines, or incorrect or incomplete submissions, can result in penalties:

• Fines ranging from 1,000 lei to 5,000 lei for failing to submit the declaration within the legal deadlines.
• Fines ranging from 500 lei to 1,500 lei for submitting incorrect or incomplete declarations.

Companies looking to optimize their SAF-T reporting process in Romania can benefit from technological solutions developed by the Romanian Accace specialists.