Last updated at
June 24, 2026
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Book NowRomania operates one of the most advanced mandatory e-invoicing frameworks in the European Union, covering B2B, B2C, and B2G transactions through a single centralised clearance platform called RO e-Factura. Every domestic invoice issued by a taxable person in Romania must pass through this government-operated system, receive a Ministry of Finance digital seal, and be archived in its original XML form. This blog explains the legal framework, transaction scope, technical requirements, compliance deadlines, penalties, and the 2026 changes under OUG 89/2025.
RO e-Factura is Romania's national electronic invoicing platform, operated by the Ministry of Finance through the National Center for Financial Information (NCFI) and administered by ANAF (Agenția Națională de Administrare Fiscală). It functions as a Continuous Transaction Controls (CTC) clearance system, where every invoice must be submitted, validated, and digitally sealed before it holds legal validity for VAT purposes.
The system launched in November 2021 on a voluntary basis and became progressively mandatory for B2G, B2B, and B2C transactions between 2022 and 2025. Romania is one of the few EU member states operating a full clearance model at this scale, comparable to Italy's Sistema di Interscambio (SdI).
Romania's e-invoicing mandate is governed by a series of laws, government ordinances, and ministerial orders issued between 2021 and 2025. The key instruments that define the system, establish mandatory obligations, and set penalties are listed below:
Government Emergency Ordinance 120/2021 (OUG 120/2021): The foundational legal act, published on 4 October 2021, established the operational framework, defined the structure of electronic invoices, and created the national e-Invoice register.
Government Emergency Ordinance 130/2021: Published on 17 December 2021, it introduced mandatory B2B e-invoicing for high fiscal risk product categories, effective from 1 July 2022.
Law 139/2022: Published on 17 May 2022, it approved and amended OUG 120/2021, making B2G e-invoicing mandatory for all public administrations from 1 July 2022.
Law 296/2023: Established mandatory B2B e-invoicing for all taxable persons established in Romania, effective from 1 January 2024, extended the mandate to non-established VAT-registered entities, and introduced the 15% penalty framework.
EU Council Implementing Decision (EU) 2023/1553 of 25 July 2023: Authorised Romania to derogate from Articles 218 and 232 of EU VAT Directive 2006/112/EC, permitting mandatory clearance-based e-invoicing until 31 December 2026.
Government Emergency Ordinance 138/2024: Introduced the place of supply criterion for B2B, mandated B2C e-invoicing from 1 January 2025, brought simplified invoices into scope, and required CPV codes on all B2G invoices.
Government Emergency Ordinance 89/2025: Published on 23 December 2025, effective from 1 January 2026. It standardised the transmission deadline to 5 working days, extended the obligation to CNP-identified individuals, and clarified rules for non-established VAT-registered buyers.
Minister of Finance Order 1366/2021: Approved the RO_CIUS technical specifications, defining the national invoice structure in alignment with the European standard EN 16931.
The obligation to use RO e-Factura applies to different categories of taxpayers based on establishment status, VAT registration, and transaction type. The categories below determine who is required to issue, transmit, or retrieve invoices through the platform:
All taxable persons established in Romania must issue and transmit electronic invoices through RO e-Factura for domestic B2B and B2C transactions. This applies regardless of VAT registration status, including non-VAT-registered businesses issuing invoices to other Romanian-established persons.
Taxable persons not established in Romania but registered for Romanian VAT must transmit invoices for domestic transactions through RO e-Factura. These entities are subject to e-reporting obligations rather than the full clearance mandate.
From 1 January 2026, individuals conducting economic activities under their personal identification number (CNP), including consultants, photographers, and influencers, must register in the RO e-Invoice Register before commencing activity. All invoices must be transmitted through the platform immediately upon issuance.
Romanian-established businesses receiving B2B invoices must retrieve them from the platform within 60 calendar days. Recording an invoice not transmitted through RO e-Factura exposes the buyer to a 15% penalty and loss of VAT deduction rights on that transaction.
The RO e-Factura mandate applies to domestic transactions where the place of supply is Romania. The transaction types below are subject to mandatory e-invoicing or e-reporting obligations under Romanian law:
B2B Transactions Between Romanian-Established Entities: All domestic supplies of goods and services between Romanian-established businesses fall under mandatory clearance e-invoicing, effective since 1 July 2024.
B2G Transactions: All transactions between Romanian economic operators and public institutions or contracting authorities must use RO e-Factura, mandatory since 1 July 2022. All B2G invoices must include CPV codes as required by OUG 138/2024.
B2C Transactions: From 1 January 2025, all Romanian-established taxable persons issuing invoices to final consumers for domestic supplies must report them through RO e-Factura. The invoice must also be delivered directly to the consumer, where the consumer's personal identification number is not collected, suppliers may enter 13 zeros in the buyer identification field.
B2B Invoices Issued to Non-Established VAT-Registered Buyers: From 1 January 2026, domestic B2B invoices issued to buyers holding a Romanian VAT number but without a fixed establishment must be transmitted through RO e-Factura and also delivered through conventional means.
Simplified Invoices: From 1 January 2025, simplified invoices in B2B and B2C contexts have been brought within scope, with only those issued through certified electronic fiscal cash registers remaining excluded.
High Fiscal Risk Products (B2B): Since 1 July 2022, mandatory e-invoicing applies to B2B transactions involving: fruits and vegetables, alcoholic beverages, mineral and construction products, and clothing and footwear.
Not all invoices issued by Romanian taxable persons fall under the RO e-Factura mandate. The categories below are explicitly excluded and remain governed by separate EU VAT reporting obligations:
Intra-Community Supplies and Exports: Invoices for goods supplied to VAT-registered buyers in other EU member states, or exported outside the EU, are not subject to the mandate. These fall under existing EU VAT reporting obligations such as EC Sales Lists and SAF-T declarations.
Cross-Border Services: B2B invoices for services where the place of supply falls outside Romania under EU place of supply rules are not in scope.
Simplified Invoices via Electronic Fiscal Cash Registers: Simplified invoices issued through certified electronic fiscal cash registers and recorded via a fiscal receipt are exempt from the mandate.
Operations Not Requiring an Invoice: Transactions that do not legally require an invoice under Article 319 of Romania's Fiscal Code (Law 227/2015) are outside the scope of RO e-Factura.
Every invoice submitted to RO e-Factura follows a defined clearance process before reaching the recipient. The six steps below explain how an invoice moves through the system, from when the supplier creates it to when the recipient receives the legally valid document:
Step 1: Generate the Invoice in XML Format: The supplier generates the invoice in UBL 2.1 XML format according to the RO_CIUS specification, with all mandatory fields required under Romanian fiscal law included.
Step 2: Submit the Invoice to RO e-Factura: The XML invoice is submitted through the SPV (Serviciul Spațiul Privat Virtual) web interface or via API within 5 working days of issuance.
Step 3: Validate Against RO_CIUS Schema: ANAF's system performs semantic, structural, and syntactic checks against the RO_CIUS schema and verifies the issuer's identity.
Step 4: Error Notification or Approval: If errors are found, a rejection message is issued and the supplier must correct and resubmit. If all checks pass, the Ministry of Finance applies its electronic seal.
Step 5: Invoice Becomes Legally Valid: The invoice acquires legal validity for VAT purposes only after the Ministry of Finance seal is applied. The date the recipient can download the invoice is treated as the date of communication.
Step 6: Recipient Retrieves the Invoice: For B2B and B2G transactions, the recipient retrieves the sealed invoice through their SPV account within 60 calendar days, while for B2C transactions, the supplier must also deliver the invoice directly to the consumer.
Compliance with RO e-Factura depends on meeting specific technical standards for invoice format, platform access, and submission method. The requirements below cover the invoice format, registration steps, submission channels, deadlines, and B2C data handling rules:
Invoice Format: Invoices must use UBL 2.1 XML format structured according to RO_CIUS, Romania's implementation of EN 16931, approved by Minister of Finance Order 1366/2021. The sealed XML file is the legally valid original invoice, while PDFs and printed copies are not considered legally valid.
SPV Registration: All businesses and individuals in scope must register on ANAF's Virtual Private Space (SPV) using a qualified digital certificate and submit Form 084 to activate participation in the RO e-Invoice Register.
Submission Methods:
API (Web Service): For automated, high-volume submissions directly from ERP or accounting software.
Web Upload: For manual submission of individual XML files through the SPV interface.
Submission Deadline: From 1 January 2026, the deadline is 5 working days from the date of issuance for both B2B and B2C invoices.
B2C Buyer Privacy: Where the consumer's personal identification number is not collected, suppliers may enter 13 zeros in the buyer identification field to comply with data protection requirements.
Romania's e-invoicing mandate expanded in phases across four years, covering B2G, high-risk B2B, all B2B, and B2C transactions progressively. The table below tracks every key milestone from the system's launch through the 2026 enforcement deadline:
| Date | Milestone |
| October 2021 | OUG 120/2021 published; RO e-Factura legal framework established |
| November 2021 | Voluntary B2G e-invoicing phase begins |
| December 2021 | OUG 130/2021 published; high fiscal risk B2B mandate introduced |
| July 2022 | Mandatory B2B e-invoicing for high fiscal risk products; mandatory B2G e-invoicing for all public administrations |
| January 2024 | Mandatory B2B e-reporting for all established and VAT-registered entities; 5 calendar day deadline applies |
| January to May 2024 | Grace period: no penalties for late submission |
| July 2024 | Full B2B clearance model activates; paper invoices no longer acceptable |
| July 2024 | Voluntary B2C e-reporting becomes available |
| January 2025 | Mandatory B2C e-reporting begins; simplified invoices enter scope |
| January 2026 | OUG 89/2025 in effect: 5 working day deadline, CNP individuals in scope, non-established VAT-registered buyers included |
| July 2026 | Full enforcement for SMEs with annual turnover below EUR 500,000 |
Penalties for Non-Compliance
Romania enforces the RO e-Factura mandate through a structured penalty framework that applies to both issuers and recipients. Non-compliance carries financial penalties and, in certain cases, the denial of VAT deduction rights.
Failure to Issue Through RO e-Factura: From 1 July 2024, failure to transmit an invoice through the system results in a fine equal to 15% of the total invoice value, applying to both the issuer and any recipient who records a non-compliant invoice.
Late Submission: Submitting an invoice after the five-working-day deadline constitutes a separate compliance violation, with fines applied based on the taxpayer's classification:
Large taxpayers: RON 5,000 to RON 10,000 (approximately EUR 1,000 to EUR 2,000)
Medium taxpayers: RON 2,500 to RON 5,000 (approximately EUR 500 to EUR 1,000)
Small taxpayers and individuals: RON 1,000 to RON 2,500 (approximately EUR 200 to EUR 500)
Loss of VAT Deduction Rights: Buyers who record an invoice not issued through RO e-Factura lose the right to deduct input VAT on that transaction.
Penalties for Individual Entrepreneurs (CNP Holders): From 1 January 2026, individuals identified by a CNP who fail to register or transmit invoices through the system, as well as business partners who record such invoices, face penalties.
The legally valid original is the XML file bearing the Ministry of Finance's electronic seal and timestamp, while PDF copies and printed versions do not meet the archiving requirements. Businesses must therefore retain the sealed XML file in its original form for compliance purposes. The minimum retention period is five years from the end of the fiscal year of issuance, although tax practitioners often recommend ten years given Romanian audit risk profiles. Archives must preserve the invoice in its original signed XML format, with the electronic signature and timestamp intact, and the document must be available for production upon ANAF request during a tax audit.
Government Emergency Ordinance 89/2025, published on 23 December 2025 and effective from 1 January 2026, is the key update to Romania's e-invoicing mandate for 2026, clarifying existing obligations without introducing new burdens for taxpayers already in scope.
Unified Transmission Deadline of 5 Working Days: OUG 89/2025 establishes a single deadline of 5 working days from the date of issuance for both B2B and B2C invoices, replacing the previous 5 calendar day rule for B2B and the absence of any defined deadline for B2C.
Invoices Issued to Non-Established VAT-Registered Buyers: Domestic B2B invoices issued to buyers who are VAT-registered in Romania but do not have a fixed establishment must be submitted through RO e-Factura and delivered through conventional means, while intra-community transactions remain excluded.
Mandatory Registration for CNP-Identified Individuals: Individual entrepreneurs identified by a CNP must register in the RO e-Invoice Register before commencing economic activity and transmit all invoices through the system upon registration, while ANAF is required to update the registration procedure by 15 January 2026.
Suspension of RO e-TVA Provisions: Several articles of OUG 70/2024 governing the pre-filled VAT return system were repealed or modified. Taxpayers on the VAT cash accounting system are exempt from Articles 5 and 8 of OUG 70/2024 until 30 September 2026.
Romania's RO e-Factura system covers all domestic B2B, B2G, and B2C transactions under a real-time clearance model with strict financial penalties, including a 15% invoice value fine and denial of VAT deduction rights. The 2026 updates under OUG 89/2025 expand the scope, standardise the transmission deadline to 5 working days, and bring individual entrepreneurs fully into the mandate. Every domestic invoice in Romania must pass through the platform, receive the Ministry of Finance's digital seal, and be archived in its original XML form.
For queries on RO e-Factura compliance or a certified Peppol-compliant e-invoicing solution, contact sales@flick.network.
What is the RO e-Factura system?
RO e-Factura is Romania's national e-invoicing clearance platform where invoices are validated and digitally sealed by the Ministry of Finance before they hold legal validity for VAT purposes.
What is the submission deadline under RO e-Factura?
From 1 January 2026, invoices must be transmitted within 5 working days of issuance for both B2B and B2C transactions under OUG 89/2025.
What are the penalties for non-compliance?
Non-transmission attracts a 15% fine on the invoice value for both issuer and recipient. Late submission fines range from RON 1,000 to RON 10,000 by taxpayer classification, and recipients lose VAT deduction rights on non-compliant invoices.
Do non-Romanian companies need to use RO e-Factura?
Non-established entities registered for Romanian VAT must report domestic invoices through RO e-Factura under e-reporting obligations. Intra-community supplies and cross-border services outside Romania's place of supply remain out of scope.
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