PFAs and liberal professions · ANAF inspection

ANAF inspection of a PFA: prepare your records and the explanations requested.

As the holder of a PFA (authorised self-employed individual) or as a person practising a liberal profession, you are two things at once in the eyes of ANAF: a person carrying on an activity and an individual with income and assets. A request may concern the activity, the person, or both. The first thing to establish is which of them.

Legal service · Lawyer

The legal services described on this page are provided by lawyer Florin Hrițuliac, Brașov Bar, as part of his personal clientele; the work is carried out through the Mihai Guran Law Office (Cabinet de avocat Mihai Guran). This page is for information only.

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First step

Which procedure it is, based on the document received.

Read the heading and the first paragraph: who issues the document, under which article and whom it concerns. Your activity has its own tax identification number; the person has a personal numeric code (CNP). The document tells you which of the two it is aimed at.

What you receivedWhat it usually concernsWhere to read further
Compliance noticediscrepancies identified in the risk analysis; an invitation to correct your returns before a possible selection for inspectionThe compliance notice
Notice of tax inspection, addressed to the PFAthe activity: income tax, contributions, VAT, for the periods stated in the noticeThe notice of tax inspection
Request for information or documentsmay concern the activity or transactions with third parties; it is not, in itself, an inspectionWhat documents ANAF may request
Notice of review of personal tax statusthe person: income and assets, including those unrelated to the PFAThe review of personal tax status
Unannounced or anti-fraud inspectionthe activity, without prior noticeThe first hours of an inspection without notice
You do not know what it is-The identification sheet in the guide
What is checked

The topics that often come up for PFAs.

The list is not exhaustive and does not mean that every topic applies to you. It is what is worth checking first, in your own records, before giving any response.

Receipts compared with returns

The amounts received into your account, including into your personal account, compared with the income shown in your single tax returns (declarația unică).

Deducted expenses

The link between each expense and the activity, especially for assets also used privately: the car, the phone, the home.

VAT and clients in other states

The special VAT code for services supplied to clients in other Member States, and the exemption threshold. The VAT threshold

Independence of the activity

Whether the relationship with a client has, in fact, the features of an employment relationship. Recharacterisation of the activity

Earlier periods

Suspending or ending the activity does not close the periods in which you worked. What matters is the limitation period. The tax limitation period

e-Factura and records

The invoices issued through the system, the receipts and payments register, and their reconciliation with bank statements. e-Factura for PFAs

Preparation

What to prepare before your first response.

  • the receipts and payments register and the inventory register, for the periods concerned;
  • the single tax returns filed and their filing receipts;
  • the contracts with clients and the invoices issued;
  • the invoices and expense documents, with an explanation of how each item was used;
  • the statements of the account used for the activity and, if receipts went into your personal account, of that account as well;
  • proof of your VAT code, if you invoiced clients in other states.

The activity and the person: two levels

If professional receipts also went into your personal account, or if you bought significant assets in the same period, questions may arise at both levels. Separating the flows, with a documented explanation, is the first thing we build.

The accountant and the consultation

The accountant keeps the records and files the returns. A consultation is useful when there is a communication with a time limit, when earlier periods are requested or when the risk concerns how the activity is classified. We can work together: we prepare the list of documents and the responses, and the accountant provides the records.

The service

What we can do, depending on the stage.

Communication received

Consultation on the document

Which procedure it is, which time limit is running, which documents must be prepared and whether you should correct your returns.

Notice received

Preparing for the inspection

The list of documents, the sensitive areas, the rules of communication and a log of the requests, before the start date.

Inspection under way

Assistance during the procedure

The written responses and the written position on the draft inspection report. The administrative appeal is agreed separately.

Each stage has its own scope, documents and limits. Details on the How I work page.

Informative material, updated on 16 October 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.

Questions

What PFA holders ask.

I have suspended my activity. Can ANAF still review earlier periods?

Suspending or ending the activity does not close the periods in which you carried on the activity. What matters is the limitation period for the right to assess tax liabilities. Keep the registers and documents for the duration of the legal retention periods.

ANAF is asking me for documents as an individual, even though I have a PFA. Is that wrong?

Not necessarily. The review of personal tax status concerns the person, not the activity. Read the issuer, the legal basis and the subject matter stated in the document.

I have only one client. Am I at risk of recharacterisation?

The risk depends on the independence criteria actually met, not on the number of clients taken in isolation. See the analysis on recharacterisation of the activity.

My accountant does not deal with inspections. What do I do?

The accountant remains responsible for the records. For the procedure, we can work together: we prepare the list of documents and the responses, and the accountant provides the records.

Contact

Do you have a PFA or practise a liberal profession, and have you received a request from ANAF?

First we establish whether the procedure concerns the activity, the person, or both. Then we look at which periods are concerned and what records exist.

What helps to have to hand: the communication received, the receipts and payments register, the single tax returns filed.

The initial message does not create a mandate and is not a consultation. Do not send documents through the form; I will ask you for them after the first contact, through an appropriate channel.

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