SAF-T and e-Factura Compliance in Romania
The D406 file an SRL owes, monthly or quarterly, idle or trading.
dormant company accounting
An idle Romanian SRL kept lawful and off ANAF's inactive register, with the way back to trading, a sale or closure kept open.

No trading does not mean no filings: the calendar keeps running.
A company that stops trading keeps its filings. A return is due even when nothing is payable (art. 101(3)(c) Fiscal Procedure Code), and a calendar half-year without one is a ground of fiscal inactivity (art. 92(1)(a)). Our CECCAR-registered accountants keep the company filing or take it into a registered suspension; the year end runs through our annual financial statements service.
It is for foreign owners of an SRL kept for later, a paused project, a company bought and not yet used, or one waiting for a sale or closure. The ANAF side of it runs from abroad: electronic filings (OMF 2.036/2025 pt. 1.8(1)) and a power of attorney before ANAF (art. 18(1)).
English has one word for it. Romanian law has three situations and one penalty, and each files differently.
| Situation | What decides it | What it files | What to watch |
|---|---|---|---|
| Never traded (declarație de inactivitate, form S1046) | no activity from incorporation to the end of the financial year | the S1046 declaration of no activity instead of statements, within 60 days of the year end (OMF 2.036/2025 Annex 1 pt. 3.3(1), (5)); every return in its fiscal vector | no time limit attaches to the declaration; the route is open only to a company that has never traded |
| Idle after trading | it traded at some point and now has no transactions | full annual statements by 31 May inclusive of the following year, or the next working day (OMF 2.036/2025 pt. 3.1(1)(a), 3.1(3)); every return in its fiscal vector, nil where nothing is payable | a calendar half-year with no required return is a ground of inactivity (art. 92(1)(a) Fiscal Procedure Code) |
| Suspended (inactivitate temporară, temporary inactivity) | a members' decision and a Trade Register entry, for at most 3 years (art. 237^2(1)(b) Law 31/1990) | no tax returns from the 1st of the month after the entry (art. 101(4^1) Fiscal Procedure Code); returns for the period before it stay due | the company is fiscally inactive by law for the whole suspension (art. 92(1)(d)) |
| Fiscally inactive (contribuabil inactiv, the penalty) | one of the grounds of art. 92 Fiscal Procedure Code, the suspension included | every missing return and statement, to be reactivated (art. 92(5)) | listed in ANAF's public register (art. 92(11)); dissolved if not reactivated within one year (art. 92(4^1)) |
The service follows the company's situation, not a fixed monthly tier.
We read ANAF's inactive register, six years of Ministry of Finance balance sheets and arrears, and the fiscal vector; then you choose the route.
Form 700 for any change to the returns the company files; micro-enterprise or profit tax settled on the employee condition; the VAT code decided before nil returns cancel it.
The VAT return each period while VAT-registered (art. 323(1) Fiscal Code), the micro-enterprise return, the annual profit-tax return of a profit-tax payer, and the D406 SAF-T file an SRL owes.
The trial balance (art. 22 Law 82/1991), then the S1046 declaration or full statements in the micro-entity format, approved by the members and filed on www.e-guvernare.ro with a qualified certificate.
ANAF's notices and their 15-day and 30-day clocks, the inactive register, the payment account, the administrator's mandate and the registered-office term.
The returns owed up to the entry filed first, then a written warning: fiscally inactive by law, VAT code cancelled, and no returns until resumption or 3 years.
Every missing return and statement filed, arrears paid by you, the account opened. The clock is one year from the inactivity decision (art. 92(4^1) Fiscal Procedure Code).
Resumption by the standard Trade Register declaration; a micro-enterprise stays in the regime from that entry and needs its employee (art. 48(3^2) Fiscal Code).
Not included: taxes and arrears (we file, you pay), a registered office, a local director, stand-alone tax advice, and bespoke legal drafting, which goes to a lawyer partner.
Steps 1, 2, 3, 7 and 8 have no official time published; the others follow the law's own terms.
law a statutory term
every route
Status check and route
Our CECCAR-registered accountant, with the owner
Engagement
The owner and a CECCAR member: contract, power of attorney
route A: idle and filing
Fiscal vector aligned
Our accountant files form 700; ANAF registers it
Period filings, nil where nothing is payable
Our accountant; ANAF
Monitoring ANAF notices
Our accountant; ANAF
Year end
Our accountant drafts, the administrator signs, the members approve
route B: suspension
Suspension registered
The members and the lawyer partner; the Trade Register
Leaving dormancy
The owner decides; the Trade Register records the resumption
Route C: close or sell the company
Our CECCAR-registered accountant, with you: the ANAF inactive register, the account, the bodies, the address term, the capital. Then route A (idle), B (suspend) or C: the accounts, tax clearance and ONRC steps that end a Romanian SRL, or a sale through the detailed ready-made companies page.
An accounting services contract with a CECCAR member (art. 10(3) Law 82/1991), a power of attorney for ANAF, and the administrator's qualified electronic signature.
The accountant files form 700 and ANAF registers it, in a time it does not publish. Micro or profit tax is settled, and the VAT code decided before nil returns cancel it.
Through ANAF's electronic channels, nil where nothing is payable: the VAT return, the micro return, and D406 by the last calendar day of the month after the period.
The accountant answers ANAF's notices inside their clocks: 15 days on the half-year ground, 30 days on the bodies or the address (art. 92(2), (3)). Capital and net assets are checked against the 2027 rules.
The accountant drafts, the administrator signs, the members approve: form S1046 within 60 days, or statements by 31 May. Five months late, statements trigger inactivity: the financial statements filing deadline in Romania.
The members decide, a lawyer partner drafts any bespoke resolution, and the company files the standard declaration, for at most 3 years (art. 237^2 Law 31/1990). Earlier returns are filed first.
You decide; the Trade Register records the resumption. Returns are due again (art. 101(4^3)), and the books restart: how many documents a month your SRL produces and how they are booked.
The status check settles it before any filing, and the route follows from it.
Request a dormant-company check · or start the onboarding form

Written for an owner or administrator abroad.
The texts behind these filings ask for no apostille or translation; for a Trade Register filing, we confirm ONRC's rules for a foreign signatory first.
We found no state fee for these filings in the texts we read; missing them carries fines and, from 1 January 2026, two more inactivity grounds (art. VII(1) Law 239/2025).
| Filing or duty | Who | Deadline | State cost, sanction or rule | Source |
|---|---|---|---|---|
| S1046 declaration of no activity | company that never traded | within 60 days of the year end | no state fee found; the Ministry of Finance software is free; not filing is sanctioned under art. 42 Law 82/1991 | OMF 2.036/2025 Annex 1 pt. 3.3(1), (3), (5), 3.4 |
| Annual financial statements | company that traded, idle or not | 31 May inclusive of the following year; the next working day where 31 May is not one | no state fee found; filed online; five months late is a ground of inactivity from 1 January 2026 | OMF 2.036/2025 pt. 3.1(1)(a), 3.1(3), 1.8(1); art. 92(1^2)(b) Fiscal Procedure Code |
| Trial balance | every company | at the close of the financial year, at least once a year | kept in the archive for 10 years | art. 22, 25(1) Law 82/1991 |
| VAT return | VAT-registered company | each tax period | six months of returns with no purchases and no supplies cancel the VAT code | art. 323(1), 316(11)(e) Fiscal Code |
| Micro-enterprise income tax return | micro-enterprise | by the payment deadline of the tax | fined as any late return (row below) | art. 56(2) Fiscal Code |
| D406 (SAF-T) | SRL; small taxpayers from 1 January 2025 | last calendar day of the month after the period; quarterly if not VAT-registered | fine 1,000 to 5,000 lei if late | OPANAF 1783/2021 Annex 4 pt. 1, 3, Annex 5 pt. 1, 3; art. 337^1 Fiscal Procedure Code |
| Any required return, filed late | every company not suspended | as each article sets | fine 500 to 1,000 lei for a small company; 1,000 to 5,000 lei for medium and large taxpayers | art. 336(1)(b), (2)(d) Fiscal Procedure Code |
| Payment account in Romania | every company; at least one account throughout its activity | from 1 January 2026; a new company within 60 working days of incorporation | fine 3,000 to 10,000 lei; a ground of inactivity | art. 1(12)-(13), 12(4) Law 70/2015, inserted by Law 239/2025 |
| Share capital of at least 500 lei | SRL formed with less | by 18 December 2027 | Monitorul Oficial Part IV fee for this increase halved until 31 December 2026 | art. VI(2), (6), (7) Law 239/2025 |
| Net assets restored to at least half the capital in time | every SRL | from 2027 | fine 10,000 to 200,000 lei | art. 153^24(4^1), (4^5) Law 31/1990, as amended by Law 239/2025 |
The routine exists so that a rescue is never needed.
Not so. A return is due with nothing payable, and a half-year without one is a ground of inactivity. Only a registered suspension lifts the tax-return duty (art. 101(4^1)).
Half true. The company is fiscally inactive by law and loses its VAT code (art. 316(11)(a) Fiscal Code). It gains no returns, a kept micro regime, and no dissolution request until the 3-year term ends.
Required since 1 January 2026 (art. 1(12) Law 70/2015, inserted by Law 239/2025). Without one: a ground of inactivity and a fine of 3,000 to 10,000 lei. We recommend an account at a bank in Romania.
With no employee and no administrator paid at least the gross minimum wage under a mandate, an idle SRL is as a rule a profit-tax payer (art. 47(1)(g), 51(4)(b) Fiscal Code), unless it is suspended.
Six consecutive months of returns with no purchases and no supplies cancel the code (art. 316(11)(e) Fiscal Code). Trading again: when a Romanian company must register for VAT and how long ANAF takes.
Once the company is listed as inactive, its customers lose the deduction of expenses and VAT on its invoices, and it loses its own (art. 11(6)-(7) Fiscal Code). Reactivation is the way back.
Idle and filing, or suspended?
Idle and filing
every return in the fiscal vector
Suspended
Trade Register entry, at most 3 years
The reactivation clock runs one year from the inactivity decision; send us the notice and its date.
Request a dormant-company check · or start the onboarding form
The accounts are kept by CECCAR-registered accountants under the accounting contract (art. 10(3) Law 82/1991); the administrator stays responsible for them (art. 10(1)).
From our practice
Every idle company gets the status check before its first filing, the half-year rule on its calendar, and the suspension trade-off in writing.
Accounting and reporting client lead, Bucharest. Runs each idle company's filing calendar with the CECCAR-registered accountant who performs the contract.
Because the filings do not stop with the trading. A return is due even when nothing is payable, a calendar half-year without a required return is a ground of fiscal inactivity, and each late return is fined. A company left inactive for a year without reactivation is dissolved. Our fee is quoted on request, after the status check.
No. Every return in the company's fiscal vector stays due, nil where nothing is payable (art. 101(3)(c) Fiscal Procedure Code). After a 15-day non-filing notice, a calendar half-year without any required return makes the company fiscally inactive. Only temporary inactivity registered at the Trade Register lifts the tax-return duty, from the 1st of the following month.
It trades one risk for another. A registered suspension makes the company fiscally inactive by law and cancels its VAT code (art. 92(1)(d) Fiscal Procedure Code). In return, no tax returns are due until resumption or for up to 3 years, a micro-enterprise keeps its regime, and ANAF asks for dissolution only if the term ends without resumption.
Yes. From 1 January 2026 every company must hold a payment account in Romania or at the State Treasury, and keep at least one throughout its activity (Law 70/2015, as amended by Law 239/2025). Having none is a ground of fiscal inactivity and is fined 3,000 to 10,000 lei. We recommend an account at a bank in Romania.
A company with no activity from incorporation to the end of the financial year files the S1046 declaration of no activity with ANAF instead of annual statements, electronically, in the free Ministry of Finance software, within 60 days of the year end (OMF 2.036/2025 pt. 3.3). Every return in its fiscal vector stays due as well.
No. The S1046 declaration is only for a company with no activity since incorporation. A company that traded files full annual statements by 31 May inclusive of the following year, or the next working day, approved by its members. The order does not define when small costs, such as bank fees, end 'no activity': the accountant decides case by case.
A nil return is a return filed for a period with nothing to pay (art. 101(3)(c) Fiscal Procedure Code). Which ones are due depends on the company's fiscal vector: the VAT return each period while VAT-registered, the micro-enterprise return for a micro-enterprise, the annual profit-tax return for a profit-tax payer, and the D406 SAF-T file.
Not by filing nil returns. The VAT code is cancelled where no VAT return was filed for six consecutive months, or where the returns for that span show no purchases and no supplies (art. 316(11)(d)-(e) Fiscal Code). A decision declaring the company fiscally inactive cancels the code from the date of the decision.
Only with at least one employee, or an administrator under a management or mandate contract paid at least the gross minimum wage, and with its statements filed on time where due (art. 47(1)(g), (i), 51(4)(b) Fiscal Code). Without either, it is as a rule a profit-tax payer. A micro-enterprise in registered temporary inactivity keeps the regime (art. 48(2^3)).
Each late return is fined. The company becomes fiscally inactive after a calendar half-year without returns or, from 1 January 2026, when its statements are five months late; then it and its customers lose deductions. A year without reactivation means dissolution; with no arrears, it is struck off if no one asks for a liquidator within 20 days.
Yes, within one year of the inactivity decision (art. 92(4^1) Fiscal Procedure Code). Every missing return and statement is filed and arrears cleared; for the 2026 grounds, the account is opened or the statements filed; a registered suspension must have ended. The decision enters the public register within 5 days and binds third parties the next day.
The administrator. Art. 10(1) of Accounting Law 82/1991 places the responsibility for organising and keeping the accounts on the administrator, who also signs the declaration of no activity and the annual statements. The CECCAR member who keeps the accounts under a service contract does the work; the administrator's responsibility stays in place.
Yes, if it was formed with less: it reaches 500 lei by 18 December 2027 (art. VI Law 239/2025), and the Monitorul Oficial fee for that increase is halved until 31 December 2026. From 2027, net assets below half the share capital and not restored in time are fined 10,000 to 200,000 lei; the accountant checks them each year end.
SRLs are among the taxpayers who file D406, small taxpayers from 1 January 2025 (OPANAF 1783/2021 Annex 5). A company not registered for VAT files it quarterly, by the last calendar day of the month after the quarter, and late filing is fined 1,000 to 5,000 lei. We treat no suspended company as exempt without a text that says so.
For the ANAF side, yes. The statements, the declaration of no activity and the tax returns are filed electronically, the administrator signs with a qualified electronic signature, and representation before ANAF needs only a power of attorney (art. 18(1) Fiscal Procedure Code). For a Trade Register filing, we confirm ONRC's rules for a foreign signatory first.
Tell us the company and where it stands; we reply with the route and the filings it owes.
Request a dormant-company check · or start the onboarding form