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Get a registration planWe prepare your company's VAT file and file the request with ANAF under your power of attorney. ANAF decides and analyses risk after registration.

RomaniaRegist prepares and files the VAT registration of Romanian companies run from abroad: a new SRL registering with the Trade Register, or an existing company that opts in or crosses the turnover ceiling. If the company does not exist yet, start with how to register a company in Romania as a non-resident; under the 2021 procedure, the VAT request goes to the tax office on the day of that filing.
A Romanian company registered for VAT under art. 316(1) is subject to a risk analysis by ANAF (Agenția Națională de Administrare Fiscală, the National Tax Administration Agency) after registration, under art. 316(9) Fiscal Code. We sell preparation, filing and liaison, never a code.
Seven parts, from the first intake to the point where our work stops.
We record the turnover the company expects against the 395,000 lei ceiling, or the decision to opt in below it, and whether a special code is the real need.
We list what the file needs and check it against the five Annex 6 groups ANAF applies after registration: office, staff, accounting, mismatches and tax residence.
We file the VAT request as împuternicit (authorised representative) under your power of attorney: for a new company on its Trade Register filing day (2021 procedure), for an existing one as a declaration of changes.
RomaniaRegist provides the registered-office address itself, as a trust and company service provider notified to ONPCSB, and states the Annex 6 points on the office plainly.
Books and returns stay with your own CECCAR accountant, opinions and ANAF procedures with a CCF tax consultant, and any bespoke deed with a partner Romanian lawyer.
A new company opens a payment account in Romania within 60 working days of incorporation (Law 70/2015 art. 1(12), inserted by Law 239/2025). We support the application; you sign with the bank.
No promised VAT code, no tax opinion, no answers to ANAF in a procedure, no appeals, no books or returns (OG 65/1994 art. 21(1)), no bespoke deeds (Law 51/1995).
The route for a new SRL. An existing company files a declaration of changes instead, at the tax office registry, by post or online, and at the latest on the day it crosses the ceiling (art. 310(6) Fiscal Code).
You decide: expected turnover above 395,000 lei, or opting in below it. Keep evidence of intention, such as costs or preparatory investments (VAT norms pt. 88(2)). An opinion on opting in is a CCF tax consultant's.
We assemble the file against the Annex 6 groups: the premises contract and its term, the accountant under contract, each administrator's tax residence and the share capital.
We file the Trade Register application with the fiscal registration request annexed (art. 126(1) Law 265/2022, 2022 text). Under Order 239/2021 (2021 text), the VAT request goes to the tax office that day.
The registrar decides on the registration within one working day. That is the statute's term (art. 105(1) Law 265/2022, 2022 text), not a time we promise.
ANAF assigns the Romanian tax identification number, checks the request once the Trade Register data arrive and communicates the certificate, never before the Trade Register certificate, on the term of art. 87(4) Fiscal Procedure Code.
After registration ANAF analyses risk and may cancel the code for high fiscal risk or a tax-record entry. A CCF tax consultant answers ANAF and contests a decision within 45 days (art. 270(1) Fiscal Procedure Code).
Open a payment account in Romania within 60 working days of incorporation. Without one the company is declared inactive (art. 92(12)(a) Fiscal Procedure Code, from 1 January 2026) and its VAT code is cancelled.
The VAT registration route of a new company, by actor
Client
RomaniaRegist
Partner Romanian lawyer
CECCAR accountant
CCF tax consultant
Registrar (ONRC)
ANAF
Every term shown is the statute's, never ours. An existing company files a declaration of changes instead, at the tax office registry, by post or online, and at the latest on the day it crosses the ceiling (art. 310(6) Fiscal Code).
Tell us the facts; we set out the conditions each route carries.

The rules a Romanian company meets around VAT registration, from the Fiscal Code consolidation ANAF publishes, 2026 text.
| Situation or rule | What the statute says | Date or term | Source |
|---|---|---|---|
| Who must apply before trading | A new company that declares turnover above the ceiling, or opts in below it | before trading starts | art. 316(1)(a) Fiscal Code |
| The exemption ceiling (plafon de scutire) | 395,000 lei of annual turnover; 300,000 lei until 31 August 2025 | 395,000 lei from 1 September 2025 | art. 310(1); GO 22/2025, ANAF Cluj-Napoca notice |
| Crossing the ceiling | Apply at the latest on the day the ceiling is exceeded; otherwise ANAF registers the company ex officio from that date and assesses the VAT due | the day the ceiling is exceeded | art. 310(6), (61)(a)-(b) |
| Effective date | With a Trade Register registration, the registration date; an opt-in made after trading has begun, the date of the request; an opt-in before any operations, the fiscal registration date | as the statute sets it | art. 316(11)(a), (c) |
| Special code for EU purchases and services | Obligatory before an intra-community acquisition whose value exceeds the acquisitions threshold, before receiving services from an EU supplier on which the company owes the VAT in Romania, or before supplying services to an EU customer who owes it there; optional below the threshold; does not make the company a normal VAT payer | acquisitions threshold EUR 10,000, that is 34,000 lei | art. 317(1)(a)-(c), (2), (10); norms to art. 268(4)(b) |
| Foreign business registering directly | A non-EU business must appoint a fiscal representative (reprezentant fiscal), an EU business may; this is not a Romanian SRL route and we refer it out | a condition of its registration | art. 316(7) |
| Payment account in Romania | Open within 60 working days of incorporation; with none, the company is declared inactive | inactivity ground from 1 January 2026 | Law 70/2015 art. 1(12), inserted by Law 239/2025; art. 92(12)(a) Fiscal Procedure Code |
| Lapse for missing returns | No return, or only nil returns, for 6 consecutive months or 2 consecutive quarters cancels the code | 6 months or 2 quarters | art. 316(11)(d), (e) |
| Returns and changes | Form 300 (decont de taxă) for each quarter or month, by the EUR 100,000 test (in the year of registration, on the expected turnover); changes to registration data notified | by the 25th of the next month; changes within 15 days | art. 323(1), 322(2)-(3), 316(18) |
| Contesting a tax act | An administrative appeal (contestație) against a tax decision | 45 days from communication | art. 270(1) Fiscal Procedure Code |
After a registration under art. 316(1), ANAF analyses risk (art. 316(9) Fiscal Code) and cancels the code of a company with high fiscal risk (art. 316(11)(h)) on the criteria of Annex 6 to the VAT norms.
| Group (Annex 6 point) | What the annex describes | What the file shows | Source |
|---|---|---|---|
| Registered office (pt. 1.1, 1.2) | An office at a lawyer's professional seat under a legal-assistance contract, or a comodat of one year or less, each with no secondary premises | the premises contract, its type and its term | Annex 6 pt. 1.1, 1.2 |
| Employees (pt. 2.1) | An average of fewer than 1 employee; an employee is declared for at least 20 hours actually worked in the month; the economic director and chief accountant are not counted | the declared headcount and hours | Annex 6 pt. 2.1 and its note |
| Accounting (pt. 3.1) | No person designated to run the accounts, including no service contract with an active CECCAR member where the accounts are outsourced | the accountant under contract | Annex 6 pt. 3.1 |
| Mismatches (pt. 4.1) | Significant inconsistencies between the company's own returns, or with its suppliers' and customers' returns | nothing to prepare at registration: an ongoing criterion | Annex 6 pt. 4.1 |
| Tax residence (pt. 5.1) | At least one administrator who is a foreign citizen without Romanian tax residence, and share capital below 45,000 lei; a newly formed SRL may be set up with as little as 500 lei, the legal minimum (art. VI(2) Law 239/2025), so an SRL formed with the minimum capital and such an administrator meets the criterion | each administrator's tax residence and the capital | Annex 6 pt. 5.1; Law 239/2025 art. VI(2) |
| Tax record (cazier fiscal), outside Annex 6 | Offences recorded for the majority or sole shareholder, the administrators or the company; a majority shareholder holds at least 50% of the capital | the holders and the administrators | art. 316(11)(c); norms pt. 88(18) |
Annex 6 does not state how the criteria combine, so this page never says that one is enough or that several are needed, and offers no way round any of them.
Source: Annex 6 to the VAT methodological norms, the criteria in force, and art. 316(11)(c) Fiscal Code for the tax record.
What a cancelled VAT code means
Cancellation of the VAT code
Grounds
High fiscal risk
On the Annex 6 groups (art. 316(11)(h))
Tax record
Art. 316(11)(c)
Inactivity and no returns
6 months or 2 quarters (art. 316(11)(a), (d), (e))
What it costs
The company
No input VAT deduction while output VAT is still owed (art. 11(8); art. 11(6) for inactivity); no use of the exemption ceiling (art. 316(14))
Its customers
They lose their deduction once the supplier is listed in the register of cancelled registrations, except purchases in an enforced sale or from a bankrupt supplier (art. 11(9); art. 11(7) for inactivity)
The register
The entry is made within at most 3 days of communicating the decision (art. 316(15))
Ways back
Art. 316(12)
The inactivity ends
The tax-record situation ends
Missing returns and a reasoned request
An affidavit after nil returns
Showing the high risk has ended
Five situations founders bring to us, with what the statute says and how the file handles each.

Annex 6 point 5.1 pairs a non-resident foreign administrator with capital below 45,000 lei, while a new SRL may hold 500 lei (Law 239/2025 art. VI). We build an honest file around that, with no workaround.
Annex 6 names a lawyer's professional seat and a comodat of one year or less, each without secondary premises. Whether a domiciliation contract counts as a comodat is not settled in the texts we rely on.
Annex 6 treats a company with no one running its accounts, or no contract with an active CECCAR member, as a risk. Arranging a CECCAR accountant before trading starts is the company's step; we can point you to one.
Since 1 January 2026 a company with no Romanian payment account is declared inactive; six months or two quarters without returns also cancel the code (art. 316(11)(d) Fiscal Code). We pass both dates to your accountant at intake.
The first refund claim after VAT registration is paid only after an advance tax audit (inspecție fiscală anticipată, art. 169(3)(d) Fiscal Procedure Code). See the VAT refund guide for the route.
We review the office, staff, accounting and residence points before ANAF sees the file. No outcome is promised.
Alexandra Neagu, VAT, customs and tax compliance lead, prepares the VAT files of foreign-owned Romanian companies.
We file; representing you before ANAF is tax consultancy (OG 71/2001 art. 3) and goes to a partner. RomaniaRegist is a trust and company service provider notified to ONPCSB (Law 129/2019 art. 2).
From our practice
Before filing, the intake checks the file against the Annex 6 groups, the premises contract and its term, and the accountant.
No. After registration ANAF analyses risk (art. 316(9) Fiscal Code), and it may cancel the code for high fiscal risk. RomaniaRegist prepares the file, files the request as authorised representative and works alongside the company's accountant, a CCF tax consultant and a partner Romanian lawyer. The decision on the VAT code stays with ANAF.
Every Romanian company registered for VAT under art. 316(1) is subject to a risk analysis after registration (art. 316(9) Fiscal Code), and ANAF cancels the registration of a company with high fiscal risk (art. 316(11)(h)). The criteria sit in Annex 6 to the VAT norms. Offences in the tax record are a separate ground.
Annex 6 point 5.1 pairs at least one foreign administrator without Romanian tax residence with share capital below 45,000 lei, and a newly formed SRL may have 500 lei of capital (art. VI Law 239/2025). ANAF applies the criteria in the risk analysis after registration (art. 316(9)); Annex 6 does not state how they combine, so no outcome is promised.
Annex 6 names a registered office at a lawyer's professional seat with no secondary premises, and a comodat (free-loan agreement) of one year or less with no secondary premises. Whether a domiciliation contract counts as a comodat is not settled in the texts we rely on. RomaniaRegist provides the address as a trust and company service provider notified to ONPCSB.
Art. 87(4) of the Fiscal Procedure Code applies the certificate rules of art. 87, including the 10-day term of art. 87(1), to the VAT registration certificate. That is a term for ANAF, not our promise. For a new company ANAF checks the request after the Trade Register data arrive and communicates the certificate no earlier than the Trade Register certificate.
Annex 6 lists, as a risk criterion, a company with no one running its accounts or, where they are outsourced, no contract with an active CECCAR member. Bookkeeping and tax returns within an accounting contract are reserved to CECCAR members (OG 65/1994 art. 6(a), 21(1)), and preparing tax declarations is tax consultancy (OG 71/2001 art. 3(1)(b)): partner work, not RomaniaRegist.
Yes, as a route. The fiscal registration request is an annex to the Trade Register application (art. 126(1) Law 265/2022, 2022 text), and VAT registration is valid from the date of Trade Register registration (art. 316(11)(a) Fiscal Code). Under Order 239/2021 (2021 text) the VAT request is a separate filing with the tax office on the day of that application.
Not on turnover alone. The exemption ceiling is 395,000 lei of annual turnover (art. 310(1) Fiscal Code), and a company below it may opt for normal VAT registration (art. 316(1)(a)). A special code is separate: required before an intra-community acquisition above EUR 10,000 (34,000 lei) or reverse-charged cross-border services with an EU business (art. 317(1)).
The company must apply at the latest on the day it exceeds the ceiling (art. 310(6) Fiscal Code). If it does not, ANAF registers it ex officio from that date and assesses the VAT due (art. 310(61)(a)-(b)). Filing the request is our part; any discussion with ANAF afterwards goes to a CCF tax consultant.
A company not registered for VAT needs a special code before an intra-community acquisition above EUR 10,000 (34,000 lei) or reverse-charged cross-border services with an EU business (art. 317(1) Fiscal Code); below the threshold it is optional (art. 317(2)). ANAF registers anyone who asks (art. 317(3)), and the code does not make the company a normal VAT payer (art. 317(10)).
Six consecutive months (monthly filers) or two consecutive quarters (quarterly filers) without a return cancel the code (art. 316(11)(d) Fiscal Code); nil returns have the same effect (art. 316(11)(e)). While cancelled, the company deducts no input VAT but still owes output VAT (art. 11(8)). Restoration takes the missing returns and a reasoned request, or an affidavit after nil returns.
No. Answering ANAF in a procedure and preparing appeals are tax consultancy (OG 71/2001 art. 3(1)(e), (f)), so a CCF tax consultant, a lawyer or your accountant within the accounting contract does that work. RomaniaRegist files the registration request as authorised representative (art. 18(1) Fiscal Procedure Code). An appeal is due within 45 days of communication (art. 270(1)).
Art. 316 of the Fiscal Code and Order 239/2021 name no state fee for the VAT registration request. Our fee depends on the route and on whether the work sits inside a company registration, so we quote it on request after the intake. It covers preparation, filing and liaison; returns and tax opinions are not part of it.
Search the company's fiscal code in ANAF's public VAT register, and check a VAT number from any Member State in VIES, the European Commission's validation service. The number format and the full checking routine are in our guide to the Romanian VAT number.
Form 300 (decont de taxă) is due by the 25th of the month after the period (art. 323(1) Fiscal Code). The period is the quarter if previous-year turnover stayed within EUR 100,000 with no intra-community acquisitions of goods, otherwise the month (art. 322(2)); a company registering mid-year uses its expected turnover for the months left (art. 322(3)). Your accountant files.
Send the company's facts; we reply with the route, the documents and the Annex 6 points to check.