Status: In force. Romania’s staged rollout has reached large, medium and small taxpayers; the small-taxpayer and VAT-only non-resident reference date was 1 January 2025.
Verified on: 10 July 2026
Romania’s Standard Audit File for Tax is submitted through the informative declaration D406. It is an electronic audit-file obligation, not an e-invoice clearance channel. The Romanian model is based on OECD SAF-T 2.0 and uses an XML file generated from a taxpayer’s accounting, tax and operational records.
Who is in scope?
The reference dates in the consolidated ANAF order are:
- 1 January 2022: large taxpayers that were already in that category in 2021;
- 1 July 2022: taxpayers newly classified as large on 1 January 2022;
- 1 January 2023: medium taxpayers;
- 1 January 2025: small taxpayers and non-resident businesses registered only for Romanian VAT.
Newly registered or newly classified taxpayers generally enter from their effective registration or classification date once the reference date for their category has passed. The order lists both covered and excluded entity types. It includes, among others, Romanian companies, permanent establishments, certain non-profit entities using double-entry bookkeeping and VAT-only non-residents. It excludes specified categories such as public institutions, authorised natural persons and several regulated liberal-profession forms. Entity status must therefore be checked rather than inferred from VAT registration alone.
What does D406 contain?
The Romanian XML can include the header, master data, general-ledger entries and source documents. Reportable data spans accounts, customers, suppliers, tax codes, products, invoices, payments, inventory movements and fixed assets. The “Taxonomies” subsection shown in the OECD model is not reportable in D406.
Three reporting streams must not be collapsed into one deadline:
- Regular D406: filed monthly or quarterly, following the taxpayer’s Romanian VAT period. Taxpayers with a six-month or annual VAT period, and taxpayers not registered for VAT, file quarterly.
- Assets: prepared for the taxpayer’s financial year and filed once, by the deadline for the related annual financial statements.
- Stocks: filed only after a specific request from the central tax authority. The authority’s deadline cannot be shorter than 30 calendar days from the request.
For the regular monthly or quarterly file, the statutory deadline is the last calendar day of the month following the reporting period. The onboarding grace periods in the order applied to a taxpayer’s first reports; they are not a permanent extension of each recurring deadline.
Format, validation and submission channel
The taxpayer’s system generates SAF-T in XML. ANAF’s validator checks the structure and selected data correlations, then the D406 PDF is generated with the XML attached. The declaration must be signed with a qualified digital certificate. It is filed electronically through ANAF’s online declaration service or the e-guvernare.ro “Depunere declarații ANAF” service. A processing receipt is essential evidence of a successful filing; an upload index by itself is not the final confirmation.
Where volume exceeds the accepted file size, the order permits segmented reporting at subsection level. Each segment must be validated, and the complete submission must still contain all mandatory sections and fields for the period. A correction is a complete corrected declaration for the period, not a selective patch of individual records.
What this means for an SAP landscape
D406 readiness starts with data ownership, not with a transport route. An SAP assessment should identify the legal entities and VAT registrations in scope, their filing cadence and fiscal calendar, and the systems holding Romanian statutory data. Mapping normally reaches beyond the general ledger into business-partner master data, tax codes, sales and purchase documents, payments, materials, warehouses, inventory movements and asset accounting.
- Map Romanian accounts and tax codes to the current ANAF schema and nomenclatures.
- Reconcile source-document totals to the general ledger and VAT returns before XML generation.
- Test master-data completeness, including identifiers, addresses, units of measure and product classifications where required.
- Plan separate controls for regular, Assets and on-request Stocks files.
- Retain the generated XML, signed D406, validator output and final receipt under controlled access.
The appropriate extraction and submission architecture depends on the customer’s SAP releases, data volumes, surrounding systems and existing Romanian localisation. This page does not represent a claim that one generic SAP add-on or integration route fits every landscape.
Primary sources
- Romanian Legislative Portal — ANAF Order 1,783/2021, consolidated version
- ANAF — dedicated SAF-T / D406 resources
Regulatory information only; not tax or legal advice. Scope can depend on entity classification and individual facts. Confirm the current schema, instructions and filing position with ANAF and qualified Romanian advisers before submission.
If you are assessing D406 data readiness across SAP and connected systems, request a scoped readiness review.
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