The notice of tax inspection is not a sanction and does not mean that ANAF, Romania's national tax administration, has already “found” something. It is, however, a procedural act that starts a clock: 15 days for most taxpayers, 30 days for large taxpayers. How you use this interval affects the final outcome at least as much as the discussions held during the inspection itself.
Under Article 122 of the Tax Procedure Code (Legea nr. 207/2015), before carrying out the tax inspection the tax authority must notify you in writing, by serving a notice of inspection. The notice must contain four mandatory elements.
The legal provisions under which the tax inspection is carried out.
The moment from which the procedure begins to run, and from which corrective returns (declarații rectificative) no longer produce any effect.
The tax obligations, other obligations laid down by tax and accounting legislation, and the periods to be covered by the inspection.
The right to request, once only, for justified reasons, that the start date be postponed.
Read the notice with the utmost care. It sets out exactly what is being examined (for example: VAT for the period 2022-2024 and corporate income tax for 2021-2024) and, by implication, what is not covered by the inspection. Any subsequent extension to other periods or other tax claims requires a separate notification.
The notice is communicated before the inspection begins as follows (Article 122(2) CPF): 30 days in advance, for large taxpayers; 15 days in advance, for other taxpayers/payers (medium-sized and small taxpayers, PFA (persoană fizică autorizată), liberal professions).
Communication is usually made through the Spațiul Privat Virtual (SPV), the tax authority's secure online portal, where the act is deemed communicated on the date it is made available, or by post with acknowledgement of receipt. Check the SPV constantly: the time limit does not run from the date you actually opened the document. The law also allows you to waive the benefit of the time limit, in which case the inspection may begin earlier; do this only if there is a concrete interest in doing so (for example, the rapid release of a VAT refund).
The notice is communicated only on the date the inspection begins in three situations: the taxpayer is subject to insolvency proceedings; the inspection must start immediately because of findings from a surprise inspection; or the inspection is extended to additional periods or tax claims beyond the original notice. The notice is not required at all for the surprise inspection and the anti-fraud inspection, for redoing the inspection ordered by the decision resolving an administrative appeal (contestație), or for fact-finding steps connected with resolving a taxpayer's requests.
The notice also informs you about the Charter of Taxpayer Rights and Obligations during the Tax Inspection (Carta drepturilor și obligațiilor contribuabilului pe perioada desfășurării inspecției fiscale), approved by OMFP nr. 713/2004 and reflected in ANAF's Guide to Tax Inspection. The document sets out the rights available to you: the right to be informed, the right to be assisted by a lawyer or tax adviser, the right to state your position, and the right to confidentiality. Read it in full: it is a working tool, not a formality.
A frequent and dangerous confusion. The notice of inspection (Article 122 CPF) generally concerns economic activity, companies, PFA, liberal professions, and the tax obligations connected with that activity. The verification notice (Article 141 CPF) opens a separate procedure: the review of personal tax status (verificarea situației fiscale personale, VSFP), applicable to individuals, in which the tax authority compares declared income against financial flows and actual assets.
The law targets significant differences between the income estimated by the tax authority and the income declared, of more than 10% of declared income, but not less than 50,000 lei (Article 138 CPF).
Before the review, the individual receives a compliance notice (Article 140¹ CPF), with a 30-day period in which they may file or correct their returns; until it expires, no steps are taken to select them for review.
It contains the legal basis, the start date, the period under review and the possibility of requesting a postponement, once only, for justified reasons, with the request resolved within 5 days at most. Between the date the notice is communicated and the date the review begins there must be an interval of at least 15 days (Article 141 CPF).
The review may not exceed 270 days (Article 140 CPF, as amended by Legea nr. 295/2020), and at the tax authority's request you may be asked to file a statement of assets and income (declarație de patrimoniu și de venituri).
Income whose source cannot be identified is taxed at 70% (Article 117 of the Tax Code, a rate applicable from 1 July 2024, introduced by Legea nr. 296/2023).
Under OPANAF nr. 768/2026 (Monitorul Oficial of 6 July 2026, an order amending OPANAF nr. 2.778/2020), the review of personal tax status may now also be carried out by inspectors from the General Anti-Fraud Directorate, who may impose the 70% tax including within documentary reviews.
WARNING: If the document you received is titled “aviz de verificare”, not “aviz de inspecție fiscală”, you are in the procedure for reviewing personal tax status, with different rules, time limits and stakes, including the 70% tax on amounts that remain unsubstantiated. Do not treat the two procedures under the same playbook, and do not respond to requests before understanding which one you are in.
The tax inspection is carried out within the limitation period (prescripție) for the tax authority's right to assess tax claims, 5 years, which as a rule begin to run from 1 July of the year following the one for which the obligation is owed (Article 110 CPF). In July 2026, therefore, the obligations for the last five fiscal years that are not yet time-barred can, in principle, be examined. Always check whether the periods in the notice include years for which the limitation period has expired: this is a defence that must be raised, it is not applied automatically.
The uniqueness rule protects you: the inspection is carried out only once for each type of tax claim and each period subject to taxation (Article 118 CPF). Reverification is possible only in restrictive circumstances, and redoing the inspection only on the basis of a decision resolving an appeal.
The duration of the inspection is capped by Article 126 CPF: at most 180 days for large taxpayers and those with secondary offices, 90 days for medium-sized taxpayers and 45 days for the rest. If the inspection is not completed within a period equal to double these limits, it ceases automatically, without a tax inspection report (raport de inspecție fiscală) and without a tax assessment decision (decizie de impunere).
After receiving the notice you may request, once only, for justified reasons, that the start date be postponed (Article 122 CPF). The tax authority approves or rejects the request by decision; if approved, the decision also states the date to which the inspection has been rescheduled.
The request is made immediately after receiving the notice, not the day before the start date.
An objective inability to ensure the presence of the legal representative or of the person who knows the records, medical situations, natural disasters, or an archive temporarily unavailable at a third party's premises.
“Heavy workload” risks rejection, and it uses up your one chance for a postponement.
Sometimes a few extra weeks of preparation are worth a great deal; at other times a postponement merely prolongs the uncertainty.
Note down the periods, the taxes, the legal basis. Check the issuing authority's competence and any possible time-bar. Any defect should be raised in writing, at the appropriate procedural stage.
Trial balances, ledgers, VAT journals, the returns filed (D300, D394, D112, D101, SAF-T/D406), relevant contracts, procurement files, supporting documents for significant expenses, the transfer pricing file (dosarul prețurilor de transfer) if you have transactions with affiliates. Identify now what is missing, not on the day it is requested.
In 2026, the inspection team arrives with the discrepancies already listed: D394 against D300, e-Factura (the national electronic invoicing system) against the sales journals, SAF-T against the trial balance. Run these comparisons before the inspection team does, and prepare documented explanations for every difference.
The deductibility of intra-group or management service costs, VAT deducted from suppliers with a problematic tax history, transactions with related parties, the risk of reclassification of certain legal relationships (including PFA activity or dependent collaborations). An honest assessment of your exposure dictates the strategy.
Corrective returns for the periods and obligations covered by the inspection, filed after it begins, are no longer taken into account (Article 105(8) CPF). Filed before it begins, they take effect: an obligation correctly declared attracts only interest of 0.02% per day and late-payment penalties of 0.01% per day, whereas undeclared obligations, established through a tax assessment decision, attract the non-declaration penalty of 0.08% per day (Article 181 CPF), reduced by 75% on timely payment but doubled where evasion practices are found. Only file corrective returns, however, after a rigorous technical review.
Appoint a single point of contact (the finance director, the chief accountant), prepare the powers of attorney for the tax adviser or lawyer, and set up an internal circuit for requests: everything that goes to the inspection team passes through a single point, with an exact record of the documents handed over.
Not after the first findings. Running a mock inspection on the sensitive areas, during the 15/30-day interval, allows for corrections and a coherent strategy. Once the inspection has begun, your options narrow.
WARNING: Do not “tidy up” your archive. Concealing or destroying accounting documents, or altering the records, can constitute the elements of tax evasion offences (Article 9 of Legea nr. 241/2005). A file with errors can be defended; a “cleaned up” file turns into evidence of bad faith and, frequently, into a criminal file.
Since OUG nr. 188/2022, the rule has been reversed: the tax inspection is carried out, as a rule, at the premises of the inspection authority, based on documents submitted (increasingly often electronically). At the tax authority's initiative or at the taxpayer's reasoned request, it may be carried out at the taxpayer's own premises, in which case suitable space and the necessary logistics must be provided; the review generally takes place during working hours. When the inspection is carried out at the tax authority's premises, the start date is the date set out in the notice; when it is carried out at the taxpayer's premises, what matters is the entry made in the single inspection register (registrul unic de control).
The legal representative or an authorised representative takes part, advisably assisted from day one by a tax adviser and/or a lawyer. The right to be assisted by a specialist is expressly recognised. Brief your staff: requests for documents and explanations are channelled through the designated point of contact, and answers are given on a documented basis, not from memory.
During the inspection, about the findings made and their tax consequences.
Documents, explanations and points of view throughout the review.
The inspection authority sends you the draft tax inspection report, and you may submit a written position within 5 working days at most (7 working days for large taxpayers), a period that may be extended for justified reasons (Article 130 CPF).
The tax assessment decision is issued within 25 working days at most of the end of the inspection (Article 131 CPF).
Challenge the tax assessment decision within 45 days of communication (Articles 268 to 270 CPF); the appeal is a mandatory prior procedure and does not suspend enforcement.
It is requested from the administrative court (Articles 14 and 15 of Legea nr. 554/2004), upon payment of a bond, an essential tool when the amounts assessed are large and enforcement would seriously harm the business.
No. The inspection is a legal procedure you must submit to, and refusing to present documents or to cooperate constitutes an administrative offence (contravenție) and opens the way for the tax authority to estimate the tax base, almost always to your disadvantage. What you can do is check the lawfulness of the procedure (the notice, competence, periods, limitation), exercise your rights at every step, and build a documented defence in good time.
As a rule, yes: corrective returns filed after receiving the notice do not cancel an inspection that has already started. Their effect is nonetheless financially significant: obligations declared before the inspection begins fall outside the scope of the 0.08% per day non-declaration penalty. After the start date, corrective returns for the periods and obligations under review are no longer taken into account (Article 105(8) CPF).
Yes. If, during the inspection, facts are found that could constitute the elements of an offence, the inspection authority must refer the matter to the criminal investigation bodies (Article 132 CPF). This is one of the reasons why positions expressed during the inspection, explanatory notes, points of view, must be drafted with specialist assistance: they can become evidence.
The draft report (before the closing discussion), then the tax inspection report and, if differences are established, the tax assessment decision, issued within 25 working days at most of the end of the inspection. The 45-day time limit for the appeal runs from the date the decision is communicated. The timetable is tight and does not forgive inaction: prepare your appeal as early as the closing discussion stage, not after the decision is communicated.
For a tax inspection: 30 days before it begins for large taxpayers, and 15 days before for other taxpayers (Article 122(2) CPF). For the review of personal tax status, there must be an interval of at least 15 days between the communication of the verification notice and the date the review begins (Article 141 CPF). There are also situations in which the notice is communicated on the start date itself, insolvency, a prior surprise inspection, an extension, or in which it is not required at all, such as the surprise inspection or the anti-fraud inspection.
Informative material, updated on 17 July 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.
If you have an inspection under way or have just received a notification, the related analyses are grouped under tax inspection and the review of individuals. For how such matters are handled, see tax assistance.
Time limits run from the date of communication. A first conversation clarifies what is being alleged, what you need to substantiate and how the defence is built, before an estimate becomes a tax assessment decision.