Romania: ANAF Puts Out for Consultation on July 21, 2026 a Draft Order Amending the Mandatory RO e-Factura Register Procedure and Form 082, Adding a De-Registration Route

Country Update — Romania  |  11 August 2026  |  Topic: E-Invoicing / Tax Procedure

On July 21, 2026, the National Agency for Fiscal Administration published for public consultation, with ten calendar days for comments, a draft order amending ANAF President Order No. 3789/2024, which approves the procedure for the organization of and enrollment in the mandatory RO e-Factura Register and the model, content, and completion instructions for form 082.

The most concrete change visible in the draft is in the form’s own title: the current form covers enrollment in the register, while the draft form covers enrollment in and removal from the register. No final order has been issued, no order number exists, and nothing has been published in the Official Gazette. This is a consultation-stage development and should be planned for as such.

Background

Romania operates the highest-velocity indirect tax reporting environment in the European Union, running mandatory electronic invoicing through RO e-Factura, transport reporting through RO e-Transport, and standard audit file reporting through the D406 declaration, with frequent legislative and technical change across all three.

Form 082 is the instrument by which certain suppliers enroll in the mandatory RO e-Factura Register, and ANAF President Order No. 3789/2024, published in the Official Gazette No. 734 of July 26, 2024, approves both the enrollment procedure and the form.

The form has been amended twice in 2026 before this draft. ANAF President Order No. 59 of January 19, 2026, published in the Official Gazette No. 42 of January 20, 2026, amended Order No. 3789/2024 to bring within scope suppliers identified by personal numerical code, by reference to the relevant articles of Government Emergency Ordinance No. 120/2021, and invoking a transitional provision of Government Emergency Ordinance No. 89/2025 with a cut-off of January 15, 2026.

A further version of the form was annexed to ANAF President Order No. 378/2026; the official form document references Article IX of Government Ordinance No. 6/2026 and carries a registration effective date of June 1, 2026 and a filing deadline of May 26, 2026, and it introduced a new section allowing suppliers identified by personal numerical code to request removal from the register.

That history matters for reading the current draft, because it shows the direction of travel: the register is being reshaped from a one-way enrollment list into a list with a managed exit. The draft of July 21, 2026 appears to generalize the de-registration route that Order No. 378/2026 introduced for a specific population.

One correction of attribution belongs here. This development has been reported as an ANAF order updating the registration forms under Law No. 88/2026, with dates of July 24 and July 29, 2026. That does not match the official record.

There is no order; there is a draft order. The consultation opened on July 21, 2026, not July 24. And the June 1, 2026, registration date that has been associated with Law No. 88/2026 is attributed in the official form document to Article IX of Government Ordinance No. 6/2026.

KGT reported separately on Law No. 88/2026, which narrows the RO e-Factura scope and clarifies the business-to-consumer position, and that remains a distinct development from this draft order.

The Legislative Change

This is a legislative change in prospect rather than in force. What exists is a draft order — a proiect de ordin — published for public consultation on ANAF’s decisional transparency listing on July 21, 2026, with ten calendar days allowed for comments in accordance with ANAF’s own notice. There is no order number, no signature date and no Official Gazette citation, and none had appeared by the date of this update. Organizations should therefore not implement against it.

The draft is titled as a draft order amending ANAF President Order No. 3789/2024 approving the procedure concerning the organization of and enrollment in the mandatory RO e-Factura Register, and the model, content and completion instructions for form 082.

The clearest substantive indication available on primary sources is in the title of the form itself. The current form title covers enrollment in the register. The draft form title covers enrollment in and removal from the register. That is direct primary-source evidence that a de-registration function is being added to the general procedure, rather than existing only as the narrower facility that Order No. 378/2026 introduced for suppliers identified by personal numerical code.

Beyond that, the detail of the draft cannot be verified. ANAF distributes consultation packages only as compressed archives, and the contents of the July 21 package, including its explanatory memorandum, could not be read.

Commentary circulating in the market attributes to the draft the removal of farmers under the special regime and of suppliers identified by personal numerical code from form 082, and refers to a companion draft concerning form 081 and the optional RO e-Factura Register. Neither is confirmed on a primary source and neither should be relied on.

It is worth stating plainly what a de-registration route means in practice, because the change is administratively small and operationally useful. A supplier enrolled in the mandatory register is expected to issue through RO e-Factura.

A supplier whose circumstances change — who ceases the activity that brought it into scope, or who was enrolled on a basis that no longer applies — has until now had limited means of exiting the register through the general procedure. A managed exit reduces the risk of a supplier being treated as in scope after it has ceased to be, and reduces the corresponding risk for its customers.

Scope

The draft order concerns form 082 and the mandatory RO e-Factura Register procedure. Its scope is therefore the population required to enroll in that register, which under the 2026 amendments includes suppliers identified by personal numerical code.

The de-registration route, if adopted as the form title indicates, would extend the ability to request removal from the register beyond the narrower category for which Order No. 378/2026 provided it.

The draft does not concern RO e-Transport or the D406 standard audit file declaration, and no normative item on either was identified in the period covered by this update.

Because the instrument is a draft, its scope may change before adoption. Consultation on Romanian tax procedural orders does frequently result in amendment, and the ten-day comment period closed at the beginning of August 2026.

Three further draft ANAF orders were published for consultation in the same window and are noted here for completeness, since they concern value added tax procedure and may be relevant to organizations monitoring Romanian developments: on August 3, 2026 a draft order approving the procedure for ex officio assessment of value added tax where the value added tax return has not been filed, together with new form models; on August 4, 2026 a draft order amending the mediation procedure order; and on August 10, 2026 a draft order amending the order governing settlement of negative value added tax returns with a refund option.

Timeline

• July 26, 2024 — ANAF President Order No. 3789/2024 published in the Official Gazette No. 734, approving the mandatory RO e-Factura Register procedure and form 082.
• January 19, 2026 — ANAF President Order No. 59 signed; published in the Official Gazette No. 42 of January 20, 2026, bringing suppliers identified by personal numerical code within scope, with a cut-off of January 15, 2026.
• 2026 — ANAF President Order No. 378/2026 annexes a further version of form 082, referencing Article IX of Government Ordinance No. 6/2026, with a registration effective date of June 1, 2026 and a filing deadline of May 26, 2026, and introducing a section allowing suppliers identified by personal numerical code to request removal from the register.
• May 29, 2026 — Law No. 88/2026, which narrows the RO e-Factura scope and clarifies the business-to-consumer position, is dated. Reported as published in the Official Gazette No. 459 of the same date; that citation could not be verified because the national legislative portal returned no readable content.
• July 21, 2026 — ANAF publishes the draft order amending Order No. 3789/2024 and form 082 for public consultation, with ten calendar days for comments. The draft form title adds removal from the register.
• Early August 2026 — the ten-day comment period closes.
• August 3, 4 and 10, 2026 — three further draft ANAF orders published for consultation on value added tax procedure matters.
• As at the date of this update — no final order has been issued, no order number exists, and nothing has been published in the Official Gazette.

Businesses Affected

Suppliers enrolled or required to enroll in the mandatory RO e-Factura Register are the directly affected population, and in particular those whose circumstances have changed since enrollment and who would benefit from a route out of the register.

Suppliers identified by personal numerical code, brought into scope by Order No. 59 of January 2026 and given a narrow removal facility by Order No. 378/2026, are affected by the apparent generalization of that facility.

Businesses purchasing from Romanian suppliers are affected indirectly. Whether a supplier is in the mandatory register determines how it must invoice, and a supplier’s incorrect register status is a common cause of invoice acceptance problems in RO e-Factura. A managed de-registration route should reduce the incidence of suppliers being recorded as in scope after they have ceased to be, which is a practical benefit on the buy side.

Multinationals with Romanian entities should read this development principally as a signal about monitoring cadence rather than as an action item. ANAF published four draft orders touching value added tax procedure within three weeks. An organization whose Romanian monitoring consists of reviewing the Official Gazette will see none of them until they are final, by which time the comment period has closed and the implementation window has begun.

Organizations relying on secondary reporting of Romanian developments are affected in a different way. The reported version of this development — a finalized order, dated July 24 and July 29, made under Law No. 88/2026 — is wrong in three particulars, and a change request raised on that basis would have been raised against an instrument that does not exist.

Required Actions

• Do not implement against the draft. There is no final order, no order number and no Official Gazette publication. Note the direction of travel and wait for the adopted text.
• Review whether any of your Romanian entities is enrolled in the mandatory RO e-Factura Register on a basis that no longer applies. If a de-registration route is adopted, those are the entities that will want to use it, and identifying them now shortens the eventual exercise.
• Confirm which version of form 082 your Romanian entities most recently filed, and against which order. The form has been amended at least twice in 2026 and organizations frequently hold a superseded version.
• On the buy side, add supplier RO e-Factura register status to your Romanian supplier master verification, and treat a status mismatch as the likely cause where invoices are being rejected or where a supplier is invoicing outside the expected channel.
• Establish or improve monitoring of the ANAF decisional transparency listing, not only the Official Gazette. Four relevant draft orders appeared there in three weeks, with comment periods measured in days.
• Note the three further draft orders of August 3, 4 and 10, 2026 on ex officio value added tax assessment where a return has not been filed, on the mediation procedure, and on settlement of negative value added tax returns with a refund option. The first in particular is worth reviewing by any organization with a history of late Romanian filings.
• Treat currently circulating detail on the draft’s content — including the reported removal of farmers under the special regime and of suppliers identified by personal numerical code from form 082, and the reported companion draft on form 081 — as unconfirmed.
• Separately, verify your position under Law No. 88/2026 on RO e-Factura scope and the business-to-consumer treatment, which is a distinct development from this draft order.

Practical Implications

The substantive change here is modest and sensible. Registers that admit entrants but do not readily release them accumulate entries that no longer reflect reality, and in a mandatory electronic invoicing regime an inaccurate register produces invoicing failures for parties who have done nothing wrong.

Adding a general de-registration route to form 082 addresses that, and it should reduce friction for both suppliers and their customers.

The more useful implication concerns how Romanian change should be monitored. Romania legislates and re-legislates its indirect tax reporting obligations at a pace no other member state matches, and it does so substantially through ANAF president orders rather than through primary legislation.

Those orders appear first on the decisional transparency listing with comment periods of ten days, sometimes fewer. An organization that monitors only the Official Gazette is structurally unable to influence them and will consistently learn about them after the design is fixed.

There is also a lesson about the reliability of secondary reporting on Romania specifically. The version of this development circulating in the market described a finalized order, gave two dates neither of which is the consultation date, and attributed the change to the wrong instrument.

The volume of Romanian change is high enough that aggregators struggle to keep the chain of instruments straight, and the chain matters: Order No. 3789/2024 as amended by Order No. 59 of January 2026 and by Order No. 378/2026, against a legislative background of Government Emergency Ordinance No. 120/2021, Government Emergency Ordinance No. 89/2025, Government Ordinance No. 6/2026 and Law No. 88/2026, is not a chain that can be summarized safely at a distance.

A practical constraint is worth recording for anyone attempting their own verification. The Romanian national legislative portal returns empty responses to automated retrieval, so the text of Law No. 88/2026 and of Government Ordinance No. 6/2026 could not be read directly, and ANAF distributes consultation packages only as compressed archives whose contents could not be extracted. Where a Romanian position matters, it should be verified by someone able to open those sources directly.

Finally, this is a good example of a development that is worth knowing about and not worth acting on yet. The right response to a draft order in a ten-day consultation is to read it, comment if it affects you, and prepare the analysis — not to raise a change request.

Expected Next Steps

A final ANAF president order amending Order No. 3789/2024 and form 082 should be expected, following the close of the comment period at the beginning of August 2026, with publication in the Official Gazette. Organizations should watch for the order number and the Official Gazette citation, and should expect the form title to confirm or contradict the de-registration route indicated in the draft.

A companion instrument concerning form 081 and the optional RO e-Factura Register has been reported and should be watched for, though it is not confirmed on a primary source.

The three further draft orders of August 3, 4 and 10, 2026 should be expected to proceed to final orders, and the draft on ex officio value added tax assessment where a return has not been filed is the most consequential of them.

Given Romania’s cadence, further draft orders on RO e-Factura, RO e-Transport and the D406 declaration should be expected through the autumn of 2026, and organizations should assume that their Romanian configuration will require at least one further change before year end.

KGT will report separately when the final order amending form 082 is published, on the outcome of the companion form 081 instrument if it materializes, and on further RO e-Factura, RO e-Transport and SAF-T developments.

How Can KGT Support You?

KGT is a specialist indirect tax technology firm. Our SAP-integrated e-invoicing and e-reporting add-ons generate, validate and transmit country-compliant structured documents directly from SAP ECC and SAP S/4HANA, keeping tax determination, document mapping, status handling and the audit trail inside the system of record rather than in a downstream converter. Because the add-ons validate against the current national schemas, schematrons and code lists before transmission, a change of specification version becomes a configuration and regression-test exercise rather than a redesign.

We also deliver SAP Document and Reporting Compliance (DRC) services end to end: fit-gap assessment against the national mandate, activation and configuration of the relevant country versions, eDocument and eStatement setup, interface and connectivity design, master and transactional data remediation, test strategy including negative testing against the authority’s own validation artifacts, and post-go-live monitoring of rejections and status reconciliation. If you would like a readiness review against the developments described above, or an impact assessment for your SAP landscape, we would be glad to help.

Official sources

• ANAF, decisional transparency listing (draft order of July 21, 2026 amending Order No. 3789/2024 and form 082): View source
• ANAF, consultation package for the draft order on form 082, July 21, 2026: View source
• ANAF, President Order No. 59 of January 19, 2026 amending Order No. 3789/2024: View source
• ANAF, form 082 as annexed to President Order No. 378/2026: View source
• ANAF, RO e-Factura information pages: View source
• Romanian national legislative portal, Law No. 88 of May 29, 2026: View source
• Monitorul Oficial al României: View source

This publication is provided for general informational purposes only and does not constitute tax, legal, or professional advice. Please consult your advisor before acting on any information contained in this update.