SAF-T – What is it and who will be required to file an SAF-T declaration from 2025?
There have been many changes over the years to the way company data is verified and reported internationally. One of these changes, which became a legal requirement in 2022, is SAF-T reporting. SAF-T is an instrument designed to facilitate the digitalisation and transparency of the tax process with a view to combatting tax evasion and boosting tax yields.
Find out all you need to know about SAF-T (Informative Statement D406) and the terms and conditions for submitting SAF-T declarations for small taxpayers below.
What is SAF-T?
SAF-T (short for Standard Audit File for Tax) is an international standard that was developed to facilitate the submission to tax administrations by taxpayers of accounting, tax and management data, thereby facilitating more effective oversight by the authorities.
The ANAF introduced this reporting system in Romania in 2022, initially only for certain types of company, but with submission of SAF-T files becoming mandatory for all taxpayers in 2025. The declaration process is digitalised, allowing for smooth submissions and communication with the authorities, as well as detailed checks with a view to reducing fraud.
SAF-T – The legal framework
The filing of SAF-T declarations in Romania is legislated for under ANAF Order 1783/2021 and the Fiscal Procedure Code, which together create the legal framework for obligatory submissions of D406 declarations.
- The fiscal procedure code, as approved by Law 207/2015, sets out the rights and fiscal obligations taxpayers have when filing tax declarations, paying taxes owed to the state, as well as providing inspection bodies with the data they request. The aforementioned law also stipulates the fines that may be imposed for late submissions, the level of interest and penalties that apply in the case of non-payment or late payment of tax, and the sanctions imposed for failure to provide supporting documents in the event of an inspection
- ANAF Order 1783/2021 creates the obligation to submit Informative Statement D406, in electronic format, thereby facilitating the inspection of information of a financial and economic nature (payments, stocks, deliveries, purchases, etc.)
- Sanctions: failure to submit an SAF-T declaration will attract sanctions in the form of fines (ranging from 1,000 to 5,000 lei), while submissions of incomplete declarations will attract fines ranging between 500 and 1,500 lei.
What does SAF-T reporting involve?
SAF-T reporting involves the declaration, in digital format, of information related to the company’s activity, namely financial and accounting data, information about the company’s assets, information about stocks, deliveries and purchases, as well as other relevant details.
Financial and accounting, tax and management data
Because the obligatory submission of the SAF-T declaration is mainly intended to facilitate the inspection of tax data and, therefore, a reduction in cases of tax evasion, the document submitted needs to contain detailed information about accounting accounts, information about clients and suppliers, records of sales and purchases, payments and receipts, information about VAT and tax codes, etc. All of this data must be declared in a standard format based on the nomenclature published in the document describing the SAF-T file structure.
Detailed information about assets
The SAF-T reporting for assets requires the declaration of detailed information about fixed assets. Data must be provided for each fixed asset owned, such as inventory number, classification code, amortisation period, value at start of period, increases or decreases in value, amortisations and value at end of the period.
Information about stocks
The SAF-T reporting file for stocks contains detailed information about all goods a company holds and for which they are obliged to keep records of quantities and values. Information must be provided about units of measurement, the owners of stocks, quantities at the beginning and end of the period, quantities entering and leaving the company. The declaration on stocks is obligatory for taxpayers who trade in goods and who hold stock, with the information declared helping the tax authorities to monitor flows of goods and to identify discrepancies between accounting records and the physical reality determined through inspections.
How do you file an SAF-T declaration in Romania?
SAF-T reporting follows a mandatory procedure consisting of the submission of three separate declarations during different time intervals: a monthly or quarterly declaration, a fixed assets declaration and a stock declaration.
- The monthly or quarterly D406 declaration
SAF-T reporting is performed monthly by taxpayers registered for VAT purposes who use a month as their tax period. All VAT payers who use a quarter or year as their tax period and all non-VAT payers must submit their SAF-T declarations quarterly.
- D406 declaration for fixed assets
The declaration for assets is to be submitted annually by the same submissions deadline as for annual financial statements. For firms whose financial year is different than the calendar year, their chosen financial year will be taken into account.
- D406 declaration for stocks
The declaration for stocks is to submitted to the tax authorities upon request. The ANAF will stipulate in its request a reporting period and submissions deadline, which must be at least 30 days.
D406 declaration submissions process
The different stages of the D406 declaration submissions process are as follows:
- Preparation of the XML file: extraction and generation of the file by the software used by the taxpayer and based on the data in the taxpayer’s accounting, tax and management records
- Verification of the structure of the XML file and correlations between data using the Validator Soft J software provided by the ANAF
- Generation of the D406 Informative Statement as an electronic document in PDF format, with the XML file attached (provided it has passed the verification stage) and signed electronically with the taxpayer’s certified digital signature or that of their tax representative
- Submission of the D406 Informative Statement online, in electronic format, via the ANAF public digital platform (Online Services/Submission of Declarations) or the website www.e-guvernare.ro (Submission of ANAF Statements)
- Receipt of certificate of error-free submission, i.e. confirmation of correct submission
Although not mentioned, in the legislation, an important step in preparing an SAF-T declaration is that of verification prior to submission. This can be done by transforming the XML file into an Excel format or importing the XML file into an external tool and performing various tests (the consistency tests suggested by the ANAF as well as other supplementary tests). Some accounting software programs have already integrated some of the tests suggested by the ANAF for use in verifying declarations.
SAF-T – Objectives
SAF-T reporting has some specific objectives that every taxpayer needs to know in order to understand why it is so important to submit D406 declarations.
Increased efficiency of inspections
SAF-T reporting allows the tax authorities to perform far more efficient and faster inspections of the economic activity carried out by taxpayers. Submitting accounting and tax documents in digital format reduces the time required to perform inspections and facilitates the rapid identification of potential tax irregularities, helping prevent tax evasion.
High level of transparency
SAF-T reporting via the D406 declaration has the advantage of higher transparency, making it easier to prevent cases of fraud or tax evasion and to closely monitor any firms under suspicion.
For which categories of taxpayer is SAF-T reporting mandatory from 2025?
As of 2025, with only a few exceptions, all small taxpayers are legally obliged to prepare and submit SAF-T declarations. The taxpayer categories for whom the submission of SAF-T declarations is mandatory are listed under point 3 of Appendix 5 to ANAF Order 1783/2021. These include: autonomous regies, all forms of commercial business as legislated for under the Companies Law, craft, consumer and credit cooperative organisations, for-profit and not-for-profit associations, collective investment undertakings, the branch offices/dealerships/permanent headquarters of non-residents, non-residents registered in Romania for VAT purposes.
Romanian legal persons
With only a few exceptions, as listed in point 3 of Appendix 5 to ANAF Order 1783/2021, every legal person registered in Romania will need to submit a D406 Informative Statement from 2025.
Associations and foundations
Entities carrying out in the form of associations and foundations are also obliged to submit D406 declarations from 2025.
Non-residents
Entities without legal personality in Romania belonging to legal persons established abroad (branch offices, dealerships), foreign legal persons who conduct business through a permanent headquarters in Romania and foreign legal persons with a place of effective management in Romania are also obliged to submit SAF-T declarations.
Non-resident companies registered in Romania for VAT purposes (taxpayers registered through direct registration, taxpayers registered through a tax representative, permanent headquarters) will submit simplified SAF-T declarations.
Which taxpayer categories are exempted from SAF-T reporting?
The submission of D406 declarations and SAF-T reporting is mandatory from 2025. However, there are a few entities that are exempted from this process, meaning they will not be obliged to submit nor be fined for not submitting declarations.
Self-employed persons (PFA)
Self-employed persons are not obliged to submit SAF-T declarations. However, they will be subject to inspections through, for example, the single tax declaration.
Individual/family entrepreneurships
Similar to the self-employed model, and because they are subject to a simplified tax regime, individual and family entrepreneurships do not need to submit SAF-T declarations.
Public institutions and administrative authorities
Public institutions and administrative authorities, regardless of the source of their financing or the taxpayer category they fall under, do not need to submit D406 declarations.
What is the risk for companies that fail to submit SAF-T declarations?
Where companies fail to submit a D406 Informative Statement (SAF-T file), they run the risk of being fined or subject to tax inspections. Penalties also apply in the case of incomplete or incorrectly submitted declarations.
Failure to meet reporting obligations may result in the following fines:
- between 1,000 and 5,000 lei for failure to submit the D406 declaration on time
- between 500 and 1,500 lei for the submission of incorrect or incomplete declarations
No penalties apply where an incorrect declaration is corrected before the next reporting deadline or is corrected because of actions that cannot be attributed to the taxable person.
Who is responsible for submitting SAF-T declarations?
SAF-T declarations may be submitted by accountants. However, the legal responsibility for this declaration normally falls to the company administrator. It is therefore important that the administrator is aware of the ANAF requirements, in order to avoid any legally imposable penalties in the event of a failure to submit the declaration and so as to be able to ensure that the declaration is submitted correctly and on time.
Frequently asked questions about SAF-T
What is the role of tax reporting?
SAF-T reporting is important for tax transparency, helping with digitalisation and, above all, the standardisation of the system for declaring information relating to the fiscal activity of taxpayers.
Do small taxpayers need to submit SAF-T declarations from 2025?
While prior to 2025 the obligation to submit D406 declarations only applied to a certain subsection of firms, from this year the obligation to submit these declarations also applies to small taxpayers.
How can a D406 declaration be corrected if errors are identified?
The required corrections in the event of an incorrectly filed D406 declaration are submitted in the form of a rectifying declaration, which replaces the original declaration and which should contain all of the original sections and subsections, even if only some of the information has been corrected.
What are the deadlines for submitting D406 declarations?
The SAF-T declaration must be submitted monthly by VAT taxpayers who use a month as their tax period. All other taxpayers, including non-VAT taxpayers, are to submit their declarations quarterly. Reporting on assets is performed annually (by the same submissions deadline as for annual financial statements), and reporting for stocks only upon the request of the ANAF (within a deadline of at least 30 days).
