Tax record and fiscal inactivity in Romania: Key changes for taxpayers | News Flash

The recent amendments introduced by Law no. 175/2025 clarify and simplify how fiscal inactivity and taxpayer registration in the tax record (fiscal record) are managed in Romania. The purpose of the new regulation is to differentiate between minor administrative non-compliance and serious breaches of tax legislation, eliminating unfair penalties that previously affected all inactive taxpayers, regardless of the cause.

What is changing in practice?

Until the publication of Law no. 175/2025, all taxpayers declared inactive were automatically recorded in the fiscal record for three months after reactivation, regardless of the reason for their inactivity.

This rule applied even in minor administrative situations, such as:

• late submission of tax returns;
• missing statutory documents;
• expiry of the registered office validity period.

Even when the issue was corrected quickly and without intent to defraud, the taxpayer still remained temporarily registered in the fiscal record. This situation often restricted participation in public tenders, the issuance of permits, or access to bank loans and financing.

A new approach: differentiated treatment based on the cause of inactivity

Law no. 175/2025 introduces a differentiated approach, depending on the underlying cause of inactivity:

• Immediate removal from the fiscal record upon reactivation, for administrative non-compliance.
   Examples: late submission of tax returns, expired registered office validity, lack of statutory representatives.
• Retention for three months after reactivation, for serious breaches.
   Examples: avoiding tax inspections, not operating at the declared headquarters.

This change ensures fairness among taxpayers and removes a common administrative bottleneck.

Impact on legal representatives and insolvency practitioners

Fiscal inactivity in Romania is recorded both in the fiscal record of the legal entity and that of its legal representatives. If new representatives are appointed during the inactivity period and the inactivity lasts for more than six months, the registration extends to them as well.

However, the law introduces exceptions for insolvency practitioners. Cases where the taxpayer is under simplified insolvency proceedings, bankruptcy, or has been dissolved by court decision will not be registered in the practitioner’s fiscal record. In these cases, the deletion of information from the fiscal record is carried out by the competent tax authority, upon the practitioner’s request.

Benefits of the updated legal framework on tax record and fiscal inactivity in Romania

• differentiated treatment based on the severity of the reason that caused inactivity;
• reduced administrative barriers;
• stimulation of economic activity;
• improved clarity for accountants, tax advisors, and taxpayers.

In an increasingly dynamic tax environment, this legislative update represents a natural step toward a more efficient tax administration and a more predictable business climate. Curious how Accace Romania can support your fiscal and accounting activities? Contact us now.

Lorena Decu

Senior Accountant | Accace Romania

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