Romania Narrows the Scope of RO e-Factura: Law No. 88/2026 Exempts CNP-Only Individuals and Clarifies B2C Invoicing Rules
Through Law No. 88/2026, published in Official Gazette No. 459 of May 29, 2026, the Romanian Parliament approved Government Emergency Ordinance No. 128/2024 and, in doing so, removed an RO e-Factura obligation for certain categories of individuals that had been scheduled to enter into force on June 1, 2026. The law also formally clarifies when a transaction is treated as B2C in the e-invoicing system and introduces a simplified deregistration procedure from the RO e-Factura registers.
Background
Romania operates one of the most extensive continuous transaction control frameworks in the EU: mandatory B2B e-invoicing through the RO e-Factura platform since July 2024 (preceded by mandatory B2B e-reporting into RO e-Factura from January 2024), mandatory B2C e-reporting since January 2025, alongside SAF-T (D406) reporting, e-Transport, and e-VAT pre-filled returns.
The framework has been adjusted repeatedly, and GEO 128/2024 was one of the ordinances that recalibrated scope, deadlines, and registration mechanics. Under the rules as they stood, individuals identified for tax purposes solely through their personal identification number (CNP) — such as professionals earning copyright royalties — were due to be drawn into mandatory use of the system from June 1, 2026.
Note, however, that the June 1, 2026, obligation for CNP-identified individuals did not originate in GEO 128/2024: the RO e-Factura framework's legal base is GEO/OUG 120/2021, the CNP obligation was introduced by OUG 89/2025 and postponed to June 1, 2026, by OUG 6/2026, while GEO 128/2024 is the broader Fiscal Code digitalization ordinance that Law 88/2026 approves with amendments.
The Legislative Change
Law No. 88/2026 approves GEO 128/2024 with amendments and entered into force before the June 1, 2026 deadline it eliminates. The key changes are:
- Removal of the mandatory RO e-Factura obligation for individuals identified for tax purposes only through their CNP — the main beneficiaries are professionals with income from copyright royalties and independent activities, including journalists, writers, translators, artists, content creators, and influencers.
- Individual farmers applying the special VAT scheme remain outside the scope of mandatory electronic reporting.
- Foreign cultural institutes and cultural centers operating in Romania under intergovernmental agreements are also exempted.
- Transactions with individuals who provide no tax identification code, or who communicate only their CNP, are formally classified as B2C operations; in such cases the invoice must use a standard placeholder code consisting of thirteen zeros instead of a tax identification number.
- Exempted persons may continue to use the system voluntarily by registering in the optional RO e-Factura Register, which is public and can be consulted on the ANAF website; use of RO e-Factura toward individuals is possible only where the individual has voluntarily registered.
- A simplified deregistration procedure: taxpayers that no longer fall within the mandatory scope may request removal from the register, effective from the first day of the month following the request.
Scope
The relief targets natural persons and special categories at the edge of the system; it does not change the core obligations of companies. Established businesses remain subject to mandatory B2B e-invoicing and B2C e-reporting through RO e-Factura. What changes for companies is counterparty handling: invoices issued to CNP-only individuals follow the clarified B2C treatment (thirteen-zeros placeholder) unless the individual appears in the optional register.
Timeline
- May 29, 2026 – Law No. 88/2026 published in Official Gazette No. 459; the June 1, 2026, extension of mandatory use to CNP-only individuals is eliminated before taking effect.
- June 2026 onward – Optional RO e-Factura Register available for voluntary participants; deregistration requests take effect the first day of the following month.
Businesses Affected
Individuals working because of their CNP (copyright royalties, independent professions), special-scheme farmers, and foreign cultural institutes benefit directly. Companies purchasing from, or invoicing to, these categories — including publishers, media groups, platforms working with content creators, and agricultural buyers — must adjust their accounts payable and receivable processes and counterparty master data to apply the correct B2C classification and placeholder coding.
Required Actions
- Review counterparty master data to identify individuals recorded with a CNP or without any tax identification code, and apply the B2C treatment with the thirteen-zeros placeholder where required.
- Implement a check of ANAF’s optional RO e-Factura Register before routing invoices to individuals through the system.
- Individuals previously registered who are no longer obligated should assess whether to remain registered voluntarily or to request deregistration.
- Ensure ERP and e-invoicing middleware validations do not reject B2C invoices carrying the placeholder code.
- Monitor ANAF communications, as Romania continues to adjust the e-Factura, e-Transport, SAF-T, and e-VAT frameworks at high frequency.
Practical Implications
The law is a welcome simplification for freelancers and micro-scale actors, and it resolves a recurring classification question for companies: whether a CNP-identified customer must be treated as B2B or B2C in the e-invoicing system. Standardizing on B2C treatment with a placeholder code reduces rejection risk but requires consistent master data discipline. For multinationals, the change is another reminder that Romania’s digital reporting rules evolve quickly and that compliance logic should be configurable rather than hard-coded.
Expected Next Steps
With the grace periods of the broader e-invoicing framework behind it, ANAF is expected to focus increasingly on enforcement and data cross-checking between RO e-Factura, SAF-T (D406), e-Transport, and the e-VAT pre-filled return. Businesses should also note that the reporting deadline for the RO e-Factura framework has been shortened to five working days and that penalties apply for issuing in-scope B2B invoices outside the platform, so the narrower personal scope does not lessen enforcement pressure on transactions that remain in scope. Further implementing guidance on the optional register and B2C edge cases is expected from ANAF and the Ministry of Finance.
How Can KGT Support You?
KGT specializes in SAP-integrated e-invoicing and digital reporting solutions for Romania, including RO e-Factura and SAF-T (D406). KGT builds certified SAP add-ons where SAP Document and Reporting Compliance (SAP DRC) does not provide native coverage, and supports implementation, configuration, testing, and training. If you need to align your SAP environment with Romania’s latest e-Factura rules, we are happy to arrange a demonstration and answer your questions.
Official sources
- Law No. 88/2026 approving GEO No. 128/2024 – full text (Lege5) – View source
- ANAF – National Agency for Fiscal Administration (RO e-Factura) – View source
This publication is provided for general information purposes only and does not constitute tax, legal, or other professional advice.
