Romania SAF-T: Updated Guidance Released

In our last look at Romania SAF-T, we detailed the technical specifications released from Romania’s tax authority. Since then, additional guidance has been released including an official name for the SAF-T submission: D406.

Implementation timeline for mandatory submission of Romania SAF-T

• Large taxpayers (as designated by the Romanian tax authorities) – 1 January 2022
• Medium taxpayers – guidance indicates 2022, no official date released yet
• Small taxpayers – 2023

To alleviate taxpayer concerns due to the complexity of the report and difficulties with extraction, the tax authorities are introducing a voluntary testing period which is due to begin in the coming weeks. During this period, taxpayers may submit what is known as D406T which will contain test data that the authorities will not use in the future for audit purposes.

Submission deadlines for Romania SAF-T

The Romanian SAF-T, D406, is based on the OECD schema version 2.0 which contains five sections:

• General Ledger
• Accounts Receivable
• Accounts Payable</li<
• Fixed Assets
• Inventory

The submission deadlines are as follows:

• Periodically (until the last calendar day of the month following the reporting period) – for information on General Ledger, Accounts Receivable, and Accounts Payable
• Annually (until the deadline for submitting the financial statements for the financial year) – for information on Fixed Assets
• On Demand (within the term established by the fiscal body, which may not be less than 30 calendar days from the date of request) – for information on Inventory

Taxpayers must submit sections of D406 monthly or quarterly, following the applicable tax period for VAT return submission.

For the first report, tax authorities have announced a grace period for the first three months of submission. This is from the date when the deposit obligation becomes effective for that taxpayer, where non-filing or incorrect filing will not result in penalization if correct submissions are submitted once the grace period ends.

Submission information for Romania SAF-T

The D406 must be submitted electronically in PDF format, with an XML attachment and electronic signature. The size of the two files must not exceed 500 MB. If the file is larger than the maximum limit, the portal will not accept it and the file must be divided into segments according to details set out in the Romanian guidance.

The tax authorities have indicated that, should a taxpayer find errors in the original submission, a corrective statement may be submitted to rectify these errors. The taxpayer should submit a second full corrected file to replace the original file that contains errors. If a taxpayer submits a second D406 for the same period, it is automatically considered a corrective statement.