Almost all acts in a tax inspection now arrive through the Spațiul Privat Virtual (SPV), ANAF's online taxpayer account. Time limits do not run from the date you open the message, but from the date of communication. This chapter explains the rule, the difference between the provisions that govern it and what you do in practice so as not to miss a time limit.
The Tax Procedure Code states that an act transmitted electronically is deemed communicated on the date it is made available. An ANAF order from 2022 provides, in its original form, for a period of 15 days from the date the act is made available. The two texts do not say the same thing. Pending clarification, the prudent rule is simple: count the time limit from the date the act appeared in the SPV. If a longer period later turns out to apply, you have lost nothing; in the opposite case, you would have lost a right.
Hypothetical example. A tax assessment decision appears in the SPV account of the holder of a PFA (authorised self-employed individual) on 3 February, while he is on holiday. He opens it on 14 February. If he counts the time limit for the administrative appeal from 14 February, he risks filing it out of time, because the law links communication to the act being made available, not to the message being opened.
Law A tax administrative act issued in electronic form is communicated by electronic means of remote transmission and is deemed communicated on the date it is made available to the taxpayer (Article 47(15) of the Tax Procedure Code). ANAF President's Order No 705/2026, Article 5(4), applies the same rule to documents issued in the videoconference procedure, with an express reference to Article 47(15).
Law The procedure approved by ANAF President's Order No 1090/2022, unamended and in force, provides that acts made available in the SPV are deemed communicated within 15 days of the date they are made available, a period that runs from the following day (Article 20(1)(c)-(d) and Article 24(2)-(3)). The order is an instrument ranking below statute, and the statute says something different. That is why the prudent course is to count time limits from the date the act appears in the SPV.
Law An act not communicated in accordance with Article 47 cannot be relied on against the taxpayer and produces no effects (Article 48(2)). The tax authority initiates communication within no more than 10 working days of issue (Article 47(19)).
| Method | When the act is deemed communicated | Legal basis |
|---|---|---|
| SPV | on the date it is made available (Tax Procedure Code); see the note above for the ANAF order | Art. 47(15) TPC |
| Post, registered letter with acknowledgement of receipt | on the date shown on the acknowledgement of receipt | Art. 47(2)-(3) TPC |
| Hand delivery at the tax domicile, by employees of the tax authority | on the date of receipt; if you refuse, on the date the notice is posted; if you are not found, you may present yourself at the tax authority's office within 15 days, otherwise the act is deemed communicated when that period expires | Art. 47(8)-(12) TPC |
| Public notice (announcement at the tax office and on the ANAF website), after postal delivery has failed | 15 days after the announcement is posted | Art. 47(4)-(7) TPC |
Companies and PFAs are required to send documents to ANAF electronically. In a tax inspection and in an administrative appeal there is an exception: documents may also be filed by post, to the e-mail address indicated by the inspection body or by the appeal resolution body, or at the registry. The date of electronic filing is the one shown in the registration message.
Law Article 79(11)-(13) of the Tax Procedure Code: legal persons, associations, PFAs, individual enterprises and family enterprises send documents electronically, and documents filed on paper are not taken into account; the exception for tax inspections and administrative appeals is laid down in paragraph (13). Date of electronic filing: Article 79(2).
Law Time limits are calculated under the Civil Procedure Code, unless tax legislation provides otherwise (Article 75 of the Tax Procedure Code).
Informative material, updated on 16 October 2026. It does not constitute legal or tax advice; individual situations must be analysed case by case.
This chapter is part of the practical guide to tax inspections.
No. The Tax Procedure Code links communication to the date the act is made available, not to the date you open it.
No. The e-mail only announces that there is a message in the SPV. Communication takes place by the act being made available in the SPV.
Yes. Although companies and PFAs must, as a rule, file documents electronically, in a tax inspection and in an administrative appeal documents may also be filed by post, to the e-mail address indicated by the tax authority, or at the registry.
The date on which the act appeared in the SPV matters for time limits. Tell me which act it is and when it was made available; we will establish which procedure it belongs to and which time limit may be running.
What helps to have to hand: the act downloaded from the SPV, the date it appeared in your account, earlier SPV messages relating to the same procedure.
The initial message does not create a mandate and is not a consultation. Do not send documents through the form; I will ask for them after the first contact, through an appropriate channel.