Newsletter no. 7 – July 2026

Note: Starting in 2026, Nowium Newsletters are published only in the web version (without PDF), in both Romanian and English.

Summary

1. The transaction volume, deadlines for preparation, content and conditions for requesting the transfer pricing file (Order 828/2026)
2. The new procedure for issuing and amending the advance pricing agreement (APA), including the possibility of issuing it for a prior period (Order 827/2026)
3. Approval of form F8000 DAC8/CRS for crypto-asset service providers (Order 750/2026)
4. The new template and content of the Fiscal Records Ledger (Order 808/2026)
5. Press Release of the Ministry of Finance on the elimination of half-year accounting reports for 2026 (MF Press Release, 29 June 2026)
6. Eligible expenses for the additional 50% deduction related to admission/maintenance of shares to trading (Order 804/2026)
7. Update of the procedure for redirecting corporate income tax for sponsorships and patronage acts (Order 773/2026)
8. New checks for granting the certificate for postponed VAT payment at customs (Order 814/2026)
9. Extension of the competence to verify personal tax status to the General Anti-Fraud Directorate as well (Order 768/2026)
10. Complementing the Classification of Occupations in Romania with five new occupations (Order 372/2026)
11. INFO – The minimum wage starting 1 July 2026
12. Month-end foreign exchange rates for July 2026
13. Social indicators

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Order 828/2026 on the volume of transactions, deadlines for preparation, content and conditions for requesting the transfer pricing file, and the procedure for adjusting/estimating transfer prices (Official Gazette 543/2026)

Summary

The Order brings important amendments regarding the volume of transactions, deadlines for preparation, content and conditions for requesting the transfer pricing file, and the procedure for adjusting/estimating transfer prices. It includes a series of significant changes, among which we recall the obligation for large taxpayers to submit the file electronically through the Virtual Private Space (SPV), within 30 working days from the legal deadline set for submitting the annual corporate income tax returns, for each fiscal year.

Details

Taxpayers should note that some of the amendments will apply to transactions carried out with related parties starting with 2026 and apply to administrative procedures initiated after 1 January 2027. Thus, the former Order No. 442 continues to produce effects for part of the procedures, with the two orders coexisting for an initial stage.

For more details, we invite you to read our dedicated article on this topic:

Transfer Pricing file: new rules 2026

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Order 827/2026 to approve Procedure for issuing and amending the advance pricing agreement, as well as the content of the request for issuing and amending the advance pricing agreement – the new APA procedure, including the possibility of issuing it for a prior period (Official Gazette 543/2026)

Summary

The Order approves the new Procedure for issuing and amending the advance pricing agreement (APA), as well as the content of the request and related documentation, replacing OPANAF 3735/2015. The most important novelty is the possibility of issuing an APA for a prior period (roll-back) of up to 5 completed fiscal years. At the same time, the procedure is fully digitalized, and the documentation requirements are aligned with the transfer pricing file standard regulated by Order 828/2026.

Details

1. APA for a prior period (roll-back) – the central novelty

• The possibility of issuing an APA for a prior period of up to 5 completed fiscal years, prior to the year of filing the request, if the transaction was also carried out before the period covered by the agreement for the future transaction, is introduced.
• Condition: fulfilment of similarity criteria – the same object and functional profile, the same related parties, contractual clauses that do not differ significantly.
• An APA for a prior period cannot be requested on a stand-alone basis: it implies the existence or request, for an agreement for the same transaction applicable for the future. In practice, the taxpayer files two separate requests, and the two agreements are issued through separate orders of the President of ANAF.
• Restriction: taxpayers who have been subject to a completed fiscal inspection regarding corporate income tax cannot request an APA for a prior period, for a common period.

2. Digitalization of the procedure

• The request and documentation are filed in electronic format (pdf and word), through SPV; submission by post, in three copies, remains an alternative.
• The annual report is filed exclusively through SPV, under the signature of the legal representative or the authorized proxy.

3. The conditions for rejecting the request, specifically regulated

The order of ANAF President provides 4 specific situations for rejection:

• non-compliant documentation, or documentation not completed within the 60-working-day deadline;
• the request for amendment (extension/revision) filed less than 30 days before the expiry of the agreement, under sanction of forfeiture;
• untrue information, proven by means of evidence;
• the request does not concern aspects that can be clarified through an APA.

For bilateral/multilateral agreements, the rejection is communicated only after consultation with, and the prior agreement of, the other tax administrations.

4. The documentation of the request

The documentation is aligned with the transfer pricing file standard: Master File-type information, the list of all intragroup transactions (according to standardized template in Annex No. 3, in excel and pdf format), organizational chart, relevant management positions and any reorganizations. Detailed requirements regarding the transaction are also requested – the contractual framework, invoicing flow, the year-end adjustment mechanism, functional analysis, proposed/applied method, justification of the tested party, the net margin and the cost base, pass-through costs, benchmarking adjustments – and benchmark study follows the same rules as for the transfer pricing file (the search hierarchy Romania → EU, including the UK → EMEA → international, the interquartile range, the presentation in excel of the accepted and rejected comparables).

A new transparency obligation is also introduced: the presentation of a summary of the unilateral or bilateral/multilateral agreements concluded by the related parties that are part to the transaction with other tax administrations. For an APA relating to a prior period, the applicant may submit a report of an independent auditor certifying the accuracy and correctness of the calculation of the net margin, for each year covered.

5. The period covered and the effects of the agreement

The agreement may be issued for a maximum of 5 years, without the specific exception previously kept for long-term contracts. Upon taxpayer’s request, the agreement may produce effects starting with the fiscal year in which the request was filed. One agreement is issued for each transaction carried out with a related party; multilateral contracts are an exception, where the agreement may cover all related parties that are part to the contract, if the transaction is carried out under the same terms.

6. The annual monitoring report

The minimum content of the report is specifically regulated (the value of the transaction, transfer pricing adjustments made, organizational/contractual changes, confirmation that the method was maintained, confirmation of the tested party and indicator, pass-through costs, the manner in which the critical assumptions materialized). Failure to file the report leads to the cancellation of the agreement for the period subsequent to the last reported year (a proportional sanction, not a full one, as previously). For an APA related to a prior period, the report is filed within 90 working days from the communication of the approval order, for each year covered.

7. Other procedural elements

The working meetings held during the procedure are formalized, with the written recording of the aspects discussed, the same requirement now also applying to the preliminary discussion. The suspension of the deadline for issuing/amending the agreement during the period between the tax authority’s request for clarifications and their communication by the taxpayer is specifically regulated. The content of the issued agreement is standardized (critical assumptions, requirements of the annual report, relation with the fiscal inspection, confidentiality and the language governing the agreement, for bilateral/multilateral agreements). A request for a bilateral/multilateral agreement may be converted at any time into a request for a unilateral agreement, with notification of the tax administrations involved.

The deadlines are clarified: 60 working days for transmitting the requested clarifications, 60 working days for expressing a position on the draft agreement, and 30 days for notifying disagreement (in which case the agreement does not produce effects). The issuance/amendment fee is paid in ANAF’s dedicated account; failure to pay the fee difference (upon classification into the category of large taxpayers) leads to the cancellation of the validity of the agreement.

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Order 750/2026 to approve template and content of the form used by Reporting Crypto-Asset Service Providers for fulfilling the obligations provided under Article 291^6 paragraph (1) of Law 207/2015 on the Fiscal Procedure Code – approval of form F8000 DAC8/CRS (Official Gazette 554/2026)

Summary

The Order approves template and content of form F8000 DAC8/CRS, which crypto-asset service providers with reporting obligations will use to transmit to ANAF, on an annual basis, information on cryptocurrency transactions carried out by taxpayers, starting with 2026 (the first reporting to be filed during 2027).

Details

• Form F8000 must be filed by crypto-asset service providers which, according to the Fiscal Procedure Code, are required to comply with the reporting and tax due diligence requirements applicable in Romania (Reporting Crypto-Asset Service Providers, according to sections I-III of Annex No. 6 to the Fiscal Procedure Code).
• The same obligation applies to providers which notify the competent authority in Romania that they fulfil their reporting and tax due diligence obligations under the legislation of another EU Member State or of a qualified jurisdiction outside the EU; they must confirm, within the form, that these requirements are fulfilled, except for situations where they have connections in Romania specifically provided by the Fiscal Procedure Code.
• The form is submitted even when the provider has no information to be reported.
• The reported information includes, for each user subject to reporting, identification data (name, address, state/jurisdiction of residence, fiscal identification no (NIF), date and place of birth), and, for entities, information on persons managing them; for each type of reported crypto-asset, the aggregate amounts paid/received, the aggregate number of units and transactions are transmitted, broken down by type of operation (acquisitions/sales in exchange for fiat currency or other crypto-assets, retail payment transactions, transfers).
• Submission is done through ANAF portal (the e-guvernare assistance programme), in the form of a PDF file with an attached XML, using a qualified digital certificate.
• Corrections to the transmitted information may be made upon the provider’s own initiative, as a result of a request from other partner jurisdictions (transmitted through ANAF), or as a result of measures ordered by ANAF following an inspection.

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Order 808/2026 on the Fiscal Records Ledger – new template and content of the ledger (Official Gazette 556/2026)

Summary

The Order updates the regulatory framework regarding the Fiscal Records Ledger, by approving a new template and content for it and by simplifying the rules for its preparation and keeping. On the date of entry into force, 7 July 2026, the former Order of the Minister of Public Finance 870/2005, which previously regulated this matter, is repealed.

Details

• Taxpayers subject to corporate income tax are required to prepare the Fiscal Records Ledger according to template and content provided in the annex to the order.
• The ledger includes, in chronological order, the information underlying the determination of the tax result (positive or negative) and the calculation of the declared corporate income tax.
• It is completed quarterly and/or annually, as well as for any other taxable period, as the case may be, so as to allow the identification and verification of the operations used in determining the tax result.
• The ledger may be kept in written or electronic format, in compliance with the template and content approved by the order.

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Press Release of the Ministry of Finance on the elimination of half-year accounting reports for 2026 (MF Press Release, 29 June 2026)

Summary

For 2026, the Ministry of Finance eliminates the obligation of economic operators to prepare and submit half-year accounting reports as at 30 June, without affecting the annual reporting obligations provided by law. The measure targets the entities within the regulatory scope of the Ministry of Finance and is part of an approach aimed to simplify and reduce the administrative burden for the business environment; it applies exclusively for 2026, with the need for half-year reporting to be reassessed by the authorities involved for subsequent years.

Details

• According to Accounting Law 82/1991, the Ministry of Finance may request accounting reports also for periods other than the annual one, during the financial year, from entities that recorded a turnover higher than the RON equivalent of EUR 1,000,000 at the end of the previous financial year.
• For 2026, this additional reporting is eliminated — the targeted entities no longer file the accounting report as at 30 June 2026.
• The annual reporting obligations (annual financial statements) remain unchanged.
• The elimination only concerns entities applying the accounting regulations issued by the Ministry of Finance (Order 1802/2014, respectively Order 2844/2016).
• The Financial Supervisory Authority (ASF) has clarified that entities in the insurance sector retain the obligation to prepare and submit half-year accounting reports, as before.
• Recommendation: check the accounting regulation applicable to your entity before considering the 30 June reporting obligation eliminated.

Source: Ministry of Finance press release, 29 June 2026 — https://mfinante.gov.ro/presa-comunicate-de-presa/-/asset_publisher/vMeOfqIFpa30/content/firmele-nu-vor-mai-depune-raport-c4-83ri-contabile-semestriale-pentru-anul-2026

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Order 804/2026 to establish the expenses related to the process of admission/maintenance to trading of shares on a regulated market and/or within a multilateral trading system, taken into account for the application of the additional deductions provided under Article 25 paragraph (14) of the Fiscal Code – the eligible expenses for the additional 50% deduction (Official Gazette 556/2026)

Summary

The Ministry of Finance has established the categories of eligible expenses for the application of the tax incentive granted to companies that list their shares on the stock exchange, as well as the conditions under which they can benefit from the additional 50% deduction in calculating the tax result, for the expenses related to the admission and maintenance to trading process, recorded in accounting and supported by documents.

Details

The following are considered eligible expenses, mainly:

• expenses with consultancy and intermediation services (for example, legal consultancy, valuation, communication and investor relations, promotion of the public offering);
• fees and tariffs charged by the competent authority for approving the prospectus and registering the securities;
• fees charged by the operator of the regulated market or of the multilateral trading system, including the file processing fee, the admission to trading fee and the annual maintenance fee;
• other expenses directly related to the admission or maintenance to trading process, such as those regarding the adaptation of internal processes, central depository services, financial audit and other similar services.

The additional deduction may be applied to expenses recorded from the approval of the decision to start the listing process (subsequent to 1 January 2026) by the end of the first fiscal year following the admission to trading. For listing processes already under way as at 1 January 2026, the incentive applies only to eligible expenses recorded starting with this date, and the maintenance-to-trading expenses are eligible only in the first fiscal year following the admission to trading.

The tax incentive does not apply to eligible expenses financed through state aid or de minimis aid schemes intended to cover the costs of listing on the stock exchange.

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Order 773/2026 to amend Order of the President of ANAF 3562/2024 approving the Procedure for redirecting corporate income tax, according to the law, for making sponsorships and/or patronage acts, as well as the template and content of certain forms – update of the corporate income tax redirection procedure (Official Gazette 546/2026)

Summary

The Order updates the procedure for redirecting corporate income tax for making sponsorships and/or patronage acts, approved by Order of the President of ANAF 3562/2024.

Details

• The template of the notification regarding the settlement of the redirection request (Annex No. 4) is adapted to also reflect the situations in which only part of the designated beneficiaries meet the legal conditions; the notification will specifically indicate the beneficiaries for whom the redirection cannot be approved.
• The rejection of the Corporate Income Tax Redirection Request (form 177) is established for the situation where, on the date of the verification carried out by the specialized department, the tax obligations representing the corporate income tax for the fiscal year for which the redirection is requested have not been paid. Unlike the previous procedure, which allowed the rejection of the request only after the expiry of a 45-day term from the payment date, the new provisions consider the verification of the situation right at the moment the request is analysed.
• The manner of verifying the settlement of the tax obligations related to the annual corporate income tax is clarified. It is specifically stated that this is carried out automatically, through the functionalities of the IT application made available by the specialized structure within the Ministry of Finance.

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Order 814/2026 to amend and complement the annex to the Order of the Minister of Finance 3225/2020 approving the Rules on the procedure for granting the certificate for postponed VAT payment at customs and for releasing the guarantee for imports of goods – new checks upon issuance and during the validity period of the certificate (Official Gazette 549/2026)

Summary

The Order amends the Rules on the procedure for granting the certificate for postponed VAT payment at customs, approved by Order of the Minister of Finance 3225/2020, by introducing additional checks both at the time of issuing the certificate and during its validity period, as well as by clarifying the revocation situations.

Details

• Upon issuing the certificate, the competent customs structures verify, among others: whether the applicant does not have outstanding tax liabilities administered by ANAF; whether it has filed the declaration on its own responsibility regarding the absence of outstanding budgetary obligations; whether, in the last 6 months prior to the request, it has carried out imports at the level provided by law; whether it does not have outstanding debts towards the customs authority; whether it has been registered for VAT purposes for at least 6 months; and whether it is not in insolvency, reorganization or judicial liquidation proceedings (verification carried out by consulting the RECOM database, for Romanian legal entities, respectively by a declaration on its own responsibility, for foreign legal entities).
• A new periodic verification obligation is introduced: during the validity period of the certificate, the competent customs structures verify whether the holder continues to meet the issuance conditions provided by the Fiscal Code.
• The situations for revoking the certificate are clarified: failure to meet one of the conditions underlying the issuance, cancellation of the VAT registration code, or the holder’s request. The revocation decision is communicated to the applicant through the DVN application – National Customs Decisions, together with the reasons that led to this measure.

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Order 768/2026 to amend and complement the Order of the President of ANAF 2778/2020 on the competence to exercise the verification of personal tax status and the preliminary activities thereof – extension of the competence to the General Anti-Fraud Directorate as well (Official Gazette 553/2026)

Summary

The Order complements the list of ANAF structures authorized to carry out verifications of taxpayers’ personal tax status, including, alongside the structures already competent, the General Anti-Fraud Directorate as well.

Details

Until this order, the competence to carry out verifications of personal tax status belonged to the General Directorate for Control of Individuals’ Income, to the tax verification services organized within the apparatus of the regional general directorates of public finance, as well as to the fiscal inspection structures for individuals within the units subordinated to these directorates. Through this order, the General Anti-Fraud Directorate within ANAF’s apparatus is specifically included among the structures competent to exercise this verification.

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Order 372/2026 on complementing the Classification of Occupations in Romania – occupation level (six characters), approved by Order 1832/856/2011 – five new occupations introduced in the list (Official Gazette 598/2026)

Summary

The Order complements the Classification of Occupations in Romania (COR) – occupation level (six characters) with five newly practiced occupations within the national economy.

Details

The following occupations and COR codes are introduced:

• pastoral assistant – 263649;
• circular economy expert – 242243;
• sustainable development specialist – 242242;
• circular economy specialist – 213313;
• gemologist technician – 311945.

Employers and human resources departments must check whether the occupations used in employment contracts and in tax returns (form 112) correspond to the updated list, in order to avoid discrepancies in reporting to the competent authorities.

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INFO – The minimum wage starting 1 July 2026

Summary

The increase of the gross minimum wage starting 1 July 2026 brings both new obligations for employers and changes to the tax incentive applicable to employees paid the minimum wage.

Details

According to GD No. 146/2026, starting 1 July 2026, the guaranteed gross minimum wage at national level increased from RON 4,050 to RON 4,325. Employers that have employees paid the minimum wage are required to update the salaries and to record the changes in Reges-Online no later than 28 July 2026. Failure to comply with the reporting deadline may be sanctioned with fines ranging between RON 5,000 and RON 8,000.

We recall that, starting 1 July 2026, the provisions on the minimum wage level in the agricultural and food industry sectors were repealed. Thus, this sector is also subject to the general rules on the minimum wage level. The only exception remaining in force is the construction sector, where the gross minimum wage level is RON 4,582.

Starting 1 July 2026, the amendments brought by GEO 89/2025 on the tax incentive applicable to the minimum wage also entered into force. The incentive is maintained in the second half of 2026 as well, but the amount exempt from income tax and mandatory social contributions was reduced from RON 300 to RON 200 per month. Thus, in 2026, the tax incentive applies differently:

• 1 January – 30 June 2026: the non-taxable amount was RON 300/month;
• 1 July – 31 December 2026: the non-taxable amount is RON 200/month.

The incentive applies if the following conditions are met:

• the base salary, excluding bonuses and other additions, is equal to the guaranteed gross minimum wage at national level, namely RON 4,325, starting 1 July 2026;
• the monthly gross income, excluding meal vouchers, holiday vouchers and food allowance, does not exceed RON 4,600;
• the base salary does not exceed the minimum wage level and cannot be reduced during the year.

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Month-end foreign exchange rates for July 2026

The foreign exchange rates communicated by the NBR, used at the July 2026 month-end closing for the valuation of monetary asset and liability items denominated in foreign currency (cash on hand, receivables, payables), as well as for the valuation of receivables and payables denominated in RON whose settlement depends on the exchange rate of a foreign currency, are:

1 EUR	1 USD	1 CHF	1 GBP
5.2473 RON	4.5595 RON	5.6420 RON	6.1332 RON

Please note that in the “Resources” section of our website you can find an Excel utility through which exchange rates are automatically retrieved from the NBR website and allocated to each validity date, in accordance with the accounting rules. The month-end closing rate is the foreign exchange rate communicated in the last foreign exchange session of the respective month.

Resources

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Social Indicators 2026

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