In 2020 Romania announced that it would be introducing both SAF-T and E-Invoicing regulations. Through these mandatory transmissions of tax and accounting information, Romania aspires to establish more transparency and efficiency in its crusade against tax evasion. Romania’s VAT Gap has been a longstanding tribulation of the Eastern-European country. Commonly commanding the European Commission’s annual VAT Gap report, 2019 even found the country snatching the number one position in its ranking of countries suffering the largest gaps.
This blog post will provide more information on Romania’s E-Accounting and E-Invoicing obligations: who should comply, what deadlines are applicable, and what information should be provided? Moreover, we will give you the rundown on SAP’s solution for compliance.
What does SAF-T Romania entail?
Standard Audit File for Tax (commonly abbreviated to SAF-T) is the OECD’s standard for the electronic exchange of accounting data between organisations and their government. First emerging in Portugal, SAF-T has since taken root in a manifold of countries, which now includes Romania. Romania’s variant of the SAF-T format is called ‘Informative Declaration D406’ or simply D406.
Specifically for Romania, the SAF-T requirements include a monthly or quarterly report, an annual report, and a report delivered solely at the request of the Romanian tax authority. The first report’s frequency depends on the company’s bookkeeping method and covers, among other things, its general ledger accounts and entries, customers, suppliers, products and tax information. The annual report should, for instance, detail the general ledger accounts and asset transactions. The third or ‘stock information’ report should include data on the company’s products, physical stock, and movement types.
SAF-T reports should be supplied to the ANAF, the Romanian tax authority, as PDF files with an attached XML file.
Who should comply with SAF-T Romania?
The SAF-T requirements will be imposed on all Romanian companies and all foreign entities with a presence in Romania. The implementation will nonetheless occur in stages, first targeting large taxpayers (compulsory starting March 2022), then companies considered large taxpayers since 2022 (July 2022), medium taxpayers (January 2023) and finally small taxpayers (January 2025).
What does e-Factura Romania entail?
Also, in 2020, Romania made its first steps towards a national system of electronic invoicing, called ‘RO e-Factura’. Originally targeted at B2G transactions, the initial pilot programs were predominantly based on Italy’s E-Invoicing model. More specifically, according to RO e-Factura requirements, invoices converted to a pre-defined XML format should be issued to the central RO e-Factura system.
Here, the invoices will be verified and validated, and in case of success, they will be signed electronically by the Ministry of Finance. In case of errors, the invoice will need to be corrected and resubmitted. Next, the recipient of the invoice will be able to access and download the invoice via a portal, API or app. After sixty days, the invoice will be archived.
The B2G E-Invoicing model laid the foundation for the extension of the platform for further developments, e.g. toward B2B E-Invoicing. Concerning the latter, taxpayers can expect the same requirements to apply as for B2G E-Invoicing. However, various aspects still require clarification, such as the authentication and access process.
Who should comply with e-Factura Romania?
At the outset, any implementation of RO e-Factura was purely voluntarily. Participants solely had to be entered in the right Registers. An Emergency Ordinance in January 2022 nonetheless made the application compulsory for a selection of B2B suppliers who deal in so-called ‘high fiscal risk products’. A list of these products, which include vegetables, alcoholic beverages and clothing, was drawn up by the ANAF and will be updated frequently.
In the future, RO e-Factura is nonetheless expected to become obligatory across the board, according to some sources, even as soon as 2023.
What SAP solution can be expected?
At present, SAP’s focus is on the development of a solution for the SAF-T Romania requirements. The first phase of this development will be dedicated to SAF-T’s monthly or quarterly reports. Its conclusion is announced for the second quarter of 2022. The ECC solution will be available for Romanian resident companies, while the S/4HANA solution will fit both Romanian resident and non-resident companies. Both will be part of SAP Document & Reporting Compliance, an overall, integrated SAP solution which strives for long-term end-to-end compliance with various country-specific legal requirements all over the world (e.g. SII Spain, SDI Italy, CFDI Mexico, RTIR and EKAER Hungary). With SAP Document & Reporting Compliance and its central SAP eDocument Cockpit, the files required by the government will automatically be generated from the source information in your system.
As SAP is currently giving priority to its SAF-T E-Accounting solution, the investigations into RO e-Factura have been postponed to a later date. As soon as more information is available on this subject, this blog post will be updated.
How PIKON can help you
With our Competence Center for Legal Requirements, we are a strategic partner who ensures that your SAP system and business processes meet different country-specific legal requirements all over the world in the long run. We have a team of experts that combine SAP expertise and in-depth knowledge of the end-to-end legal process and technical requirements of the Romanian and many other E-Invoicing and E-Accounting regulations. We have gathered this experience through our many SAP Document & Reporting Compliance and local implementation projects all around the world. Some examples are SDI in Italy, SII in Spain, CFDI and Complemento de Pago in Mexico, RTIR and EKAER in Hungary, XRechnung in Germany, the different legal requirements in Turkey, etc. We have also developed our own compliance SAP Add-Ons e.g. MTD VAT in the UK and the VAT Whitelist in Poland. Furthermore, we always keep an eye on new and changing legal requirements and inform our customers when action is needed. This ensures that your company doesn’t need to follow up on all the legal requirements yourselves, and you can concentrate on your daily business.