Practical guide · Tax inspection · Updated on 16 October 2026

Practical guide to tax control: from the first ANAF communication to the administrative appeal.

From the first ANAF communications to preparing documents, to the findings and to the administrative appeal. With separate paths for individuals, PFAs (authorised self-employed individuals) and companies.

Current version: https://fhtaxlaw.ro/en/ghid-control-fiscal · version 1.0 of 16 October 2026

Who it is for

Who the guide is for and how to read it.

The guide is intended for readers with an average understanding of economic and tax matters: individuals, PFA holders, company directors and people who manage the relationship with the accountant. It does not assume legal training. The technical notes provide additional explanations and reference points for professionals.

Tax control is not a single procedure. The tax inspection is the best known, but not the only one. The compliance notice (notificare de conformare), the desk review (verificare documentară), the review of personal tax status (verificarea situației fiscale personale) and the anti-fraud inspection have different rules, time limits and consequences. That is why the guide uses the broader title and begins with identifying the document you have received.

Each topic has three levels: the short explanation, the practical application (“what I check, what I prepare, what I ask”) and the technical note, with the legal basis, the exceptions and the consequences. You can read only the first two; the technical note is for those who want to verify.

In the text, statements are marked according to their nature:

  • Law the rule follows from the legislation indicated;
  • Practice what usually happens in proceedings, observed, not guaranteed;
  • Recommendation what I recommend, with the reason.

The guide is general information. It does not replace an analysis of your documents and does not create a legal assistance relationship.

Chapter 4

What have you received? Identify the communication and the time limit.

In brief

The first thing to do is to find out what document you have; the answer comes after that. The title under the letterhead and the article of law in the first paragraph tell you which procedure it is. The time limit runs, as a rule, from the date on which the document was communicated to you, not from the date on which it was issued, nor from the date on which you read it.

What you receivedWhat it isWhat time limit may run, and from whenRead
A phone call or a message “from ANAF”, without any documentno formal procedureno time limit. Ask for the request to be sent to you in writingThe phone call from ANAF
Compliance noticean invitation to correct your returns before a possible selection for control; it is not, in itself, a control30 days from communication to file or correct your returnsThe compliance notice
Request for information or documents; summons to the premises of the tax authoritya request within a procedure or for an analysis; it must be in writing and state what is requestedthe time limit set in the document; it must be reasonable and may be extended for justified reasonsWhat documents ANAF may request
Notification of differences identified, with a request for documents and explanationsdesk review, carried out at the office, on the basis of the tax file30 days from communication for documents and explanationsThe desk review
Notice of tax inspection (aviz de inspecție fiscală)the announcement of a tax inspection, with the periods and taxes to be checkedthe inspection may not begin before the date in the notice; between communication and the start: 15 days (30 for large taxpayers). Until the start you may file or correct returns for the periods in the noticeThe notice of inspection
Notice of review of personal tax statusa review of an individual's income, by comparison with assets and expenditure60 days from communication for the documents requested, on pain of forfeiture; a single extension of 30 days. The notice also requests the declaration of assets and income: check the time limit stated in the noticeThe review of personal tax status
A control at your premises, without a notice, followed by an official report (proces-verbal)unannounced inspection or anti-fraud inspection; neither is a tax inspectionwritten position within 5 working days (Articles 135 and 1371 of the Tax Procedure Code); the date from which the time limit runs must be checked on the official reportControl without a notice
Notification in SPV (Spațiul Privat Virtual), ANAF's online taxpayer account, about a meeting by videoconferencethe offer to hold the meeting remotely2 working days to choose, on pain of forfeiture; the choice can no longer be changedThe videoconference
Draft inspection report, with the date of the final discussionthe proposed findings, before the decisionthe final discussion takes place at least 3 working days after communication (5 for large taxpayers); the written position: 5 working days from the end of the inspection (7 for large taxpayers)The draft report
Tax assessment decisionthe act that establishes the amounts payableadministrative appeal: 45 days from communication (3 months if the decision does not state the means of challenge, the time limit and the competent body). Payment: by the 5th or the 20th of the following month, depending on the date of communicationThe report and the decision
Decision suspending the inspection or decision ordering a re-inspectionacts issued in the course of the procedurethey can be challengedDuration and suspension, The re-inspection
Decision on the administrative appealthe response to the administrative appealan action before the administrative court, within 6 months of communication of the decision (Article 11(1)(a) of Law No 554/2004)Tax litigation
Payment demand, accompanied by an enforcement orderthe start of enforcement15 days from communication to pay or to notify your intention to seek mediation; appeal against enforcement: 15 daysThe appeal against enforcement
Garnishment of a bank account (learned of from the bank)an act of enforcementappeal against enforcement: 15 days from the date on which you became aware of itThe appeal against enforcement
What I check on the document
  • the issuer and the title of the document;
  • the addressee: the individual (CNP, personal identification number), the PFA or the company (CIF, tax identification number);
  • the article of law cited in the first paragraph;
  • the registration number and the date of issue;
  • the date of communication and the proof of it: the date in SPV, the acknowledgement of receipt, the date of signature on hand delivery;
  • the periods and taxes mentioned;
  • what is asked of you, by when, and which means of challenge is indicated.

The form to fill in is among the guide's worksheets.

Technical note

Law A tax administrative act produces effects from communication; an act not communicated in accordance with Article 47 of the Tax Procedure Code cannot be relied on against the taxpayer and produces no effects (Article 48 TPC). For an electronic act, the date of issue is the date on which the electronic signature is applied (Article 46(9)); the tax authority must initiate communication within no more than 10 working days of issue (Article 47(19)).

Law Time limits are calculated under the Civil Procedure Code, unless the tax legislation provides otherwise (Article 75 of the Tax Procedure Code).

Law Under the calculation rule in the Civil Procedure Code (Article 181), time limits expressed in days are counted in clear days, and a time limit that expires on a non-working day is extended to the first working day that follows. Time limits expressed in working days (for example those in Article 130 of the Tax Procedure Code) follow their own special rule.

Legal bases, in the order of the table: Articles 1211 and 1401 (the compliance notice); Articles 56, 58, 64, 6(3) and 76 (requests and time limits); Article 149 (the desk review); Article 122 (the notice of inspection); Article 138(5)-(6) (the notice of review); Articles 134-1371 (unannounced and anti-fraud inspections); ANAF President's Order No 705/2026 (the videoconference); Article 130 (the final discussion and the written position); Articles 270 and 156 (the administrative appeal and payment); Articles 127-128 (suspension and re-inspection); Article 281 TPC and Article 11 of Law No 554/2004 (the court); Articles 230, 2301 and 261 (the payment demand, mediation, the appeal against enforcement).

Situations in which the answer differs: in five cases the notice of inspection is communicated only when the inspection begins (Article 122(4)); the time limit for the administrative appeal becomes 3 months where the act does not state the means of challenge (Article 270(2)); an act communicated by public notice is deemed communicated 15 days after the notice is posted (Article 47(7)).

Paths

Three starting situations, three paths.

The document and the subject matter of the procedure determine the path. Below is what usually happens, depending on who you are.

Individual, without an accountant

Practice The first signal is, as a rule, a compliance notice or a request concerning your income or the source of certain amounts. A notice of review of personal tax status may follow.

What you prepare: bank statements, the returns filed, the documents that explain large amounts (gifts, loans, inheritances, sales).

Read: chapter 1, the review of personal tax status, communications in SPV.

If a family member or another person is helping you, the decision and the signature remain yours.

PFA or liberal profession

Practice The request may concern the activity (an inspection of the PFA), the person (the review of personal tax status) or both, in parallel.

What you prepare: the receipts and payments register, the single tax returns, contracts, invoices, statements of the account used for the activity.

Read: ANAF control of a PFA, reclassification of the activity.

Company

Practice The first signal comes from the accountant or via SPV: a notice of tax inspection, a request for documents, a discrepancy between returns. The point of contact may be the director, the chief financial officer or the accountant; the obligations and the contract belong to the company.

What you prepare: the notice, the returns and trial balances for the periods concerned, the list of sensitive transactions, a single person for communication with the inspectors.

Read: the notice of inspection, conduct during the control, who does what.

Chapter 1

Before the control: situations worth clarifying.

In brief

Many checks start from ordinary transactions: money received from family, an inheritance, a flat bought, payments received abroad, online sales. None of them is, in itself, a tax problem. It becomes one when the amount cannot be explained with documents. The difference between a question and a case file is, most of the time, what documents exist at the moment the question is asked.

The situation, as you describe itThe question that may ariseWhat changes the answerWhen the concern is, as a rule, unfoundedWhere to read
“My parents gave me money for a flat.”Is the amount a gift, a loan or income? How is its origin proven?bank transfer or cash; a document drawn up at the time; the source of the money on the parents' side; the size of the amount relative to declared incomea bank transfer from an account with a history, an amount consistent with the parents' income, a document from the time of the transferCash and bank transfers
“I borrowed money from a friend.”A genuine loan or an unjustified amount?a dated contract, transfers in both directions, repaymentsloan and repayments through the bankCash and bank transfers
“I inherited money and a house.”What document proves the origin?the certificate of inheritance, assets in another statesuccession formally settled, assets inventoriedThe declaration of assets
“I have savings built up over the years, kept at home.”How are old savings proven?income declared at the time, historical bank withdrawals, living expensesdocumented bank withdrawals, consistent with declared incomeThe expert in the wealth review
“I bought a house and a car this year.”Are the purchases covered by documented sources?the loan, the sale of an earlier asset, the spouse's contributionfull bank financingTaxation of individuals
“I move my money between accounts, including abroad.”Could my own transfers be mistaken for receipts?the holder of the accounts, complete statements, reports from other statescomplete statements for all accountsForeign accounts and CRS
“I sell things online” or “I sold two flats”.Personal assets or economic activity?the origin of the goods, purchase for resale, frequency, intentionthe sale of one's own used goods, of one's personal homeEconomic activities as an individual
“I have had a single client for years on my PFA.”Can the activity be reclassified as dependent?the independence criteria actually metown organisation, own risk, several clients over timeReclassification of the activity
“The shareholder put money into the company and is taking it back.”Loan, capital contribution, dividend?contract, resolutions, bank documents, the balance of the shareholder's accountcontract and documented repaymentsThe director who takes money out of the company
“We have consultancy invoices without much documentation.”Was the service actually provided?reports, correspondence, resultsdocumented provision of the serviceCompany expenses
What I check
  • for each significant amount: where it comes from, which account it passed through, which document explains it and whether the document dates from the time of the transaction;
  • whether the income declared in the years concerned covers the expenses and purchases of the same years;
  • whether statements for all accounts, including closed or foreign accounts, can still be obtained.

Hypothetical example. In 2025 Andrei buys a flat for RON 400,000. RON 250,000 comes from a loan, RON 100,000 from his parents by bank transfer, RON 50,000 from his own savings, withdrawn over time from his salary account. Without any document between him and his parents, the transfer can be explained through the statements of both accounts and a statement by the parents; a document drawn up at the time (for example, the gift contract, in the form required by the Civil Code) would have been stronger than one drawn up after a notification. The savings are documented by the withdrawals from the salary account. In this example, there is no amount without an explanation.

Technical note

A transfer is not income merely because it exists. The tax question arises when the tax authority compares assets and expenditure with declared income and finds a difference. In the review of personal tax status, the explanation for the difference must be supported by documents; amounts whose source is not identified may be taxed separately. The legal basis and the calculation rules are in the chapter on the review of personal tax status.

The situations in the table are not an exhaustive list. They are the most frequent ones among the questions received.

Chapter 7

Who does what: the client, the accountant, the lawyer, the expert.

In brief

Several people usually take part in a control. Each has a role that the others cannot fully take over. Problems arise when the roles get mixed up: the accountant ends up explaining a legal classification to the inspectors, or the client answers orally questions that should have been answered in writing.

WhoWhat they doWhat they do not do
The client (the individual, the PFA holder, the company director)decides, signs, takes responsibility for the answers, consents to documents being sentdoes not give unprepared oral explanations about legal classifications
The accountantkeeps the books, files the returns, carries out the reconciliations, explains the entriesdoes not represent the client in court; is not obliged to formulate the legal position
The lawyeranalyses the procedure and the time limits, drafts the written communications, the written position, the administrative appeal, represents the client in courtdoes not keep the accounting records and does not prepare the returns
The party-appointed tax expertredoes the calculation and checks the tax authority's method, in the procedure or in courtdoes not represent the party; in the same case, the same person is not both lawyer and expert
What I prepare
  • a single person for communication with the inspectors;
  • the rule: everything that goes to the tax authority passes through a single point and is recorded (the register of requests);
  • a three-way discussion (client, accountant, lawyer) at the start of the procedure.
Technical note

Law The taxpayer is entitled to specialist or legal assistance throughout the inspection (Article 124(3) of the Tax Procedure Code), and representation before the tax authority is through an authorised representative (Article 18 TPC). For a lawyer, the right to act derives from the legal assistance contract.

Recommendation The capacities of lawyer, tax consultant and judicial tax expert are exercised separately. The capacity in which the professional acts is established in the contract, and the capacities are not combined in the same case.

Chapter 8: video conference

Meetings with ANAF by video conference.

In brief

Since 17 June 2026, some meetings with the central tax authority can be held by video conference: the start, the conduct and the final discussion in a tax inspection and in a review of personal tax status, hearings (including in a desk review), audiences with officials and mediation. Video conference is an option for the taxpayer, not an obligation. Not every meeting can be held remotely, and the rules are strict.

What I check
  • the notification appears in your SPV (Spațiul Privat Virtual), ANAF's online taxpayer account; you have 2 working days to opt for it, also through the SPV. If you do not opt, the meeting is held in person. Once you have opted, the format can no longer be changed;
  • you communicate through the SPV the participants and, if a representative takes part, the power of attorney, signed electronically with a qualified certificate or with the certificate of the electronic identity card;
  • changes to the participants are communicated at least 3 working days in advance; the link arrives one working day in advance;
  • you connect up to 10 minutes beforehand. Lateness means that you did not attend;
  • the meeting is recorded by ANAF; you are not allowed to record or take photographs. You receive minutes through the SPV.
Technical note

Law ANAF President's Order No 705 of 5 June 2026, in force since 17 June 2026, issued under Article 342(1) of the Tax Procedure Code. It applies only to the central tax authority and only to taxpayers registered in the SPV. The list of procedures is in the annex to the order (Article 2) and may be supplemented by publication on the ANAF portal. The administrative appeal (oral presentation) and the anti-fraud inspection do not appear on the list.

Recommendation Treat the connection time as you would the time of a meeting at the authority's premises: the order provides that lateness makes participation impossible. For a hearing, failure to appear on two consecutive dates means that the hearing is deemed to have taken place (Article 9(3) of the Tax Procedure Code).

Recommendation Choose video conference only if you have a stable connection, a space where you can be alone and the documents to hand. For the final discussion of an inspection involving large amounts, attending in person remains, as a rule, the safer option.

Chapter 16

The tax inspection report and the tax assessment decision: what you receive and what can be challenged.

In brief

At the end of the inspection you receive two different documents. The tax inspection report sets out the findings and responds, with reasons, to your written position. The tax assessment decision is the act that establishes the amounts and that is appealed. The report is the basis of the decision, and the decision is issued within no more than 25 working days of the end of the inspection.

DocumentIts roleWhat you do with it
Draft inspection reportthe proposed findings, before the final discussionyou prepare the written position; it is the last opportunity to change the findings before the decision
Tax inspection reportthe final findings and the inspectors' opinion on your written positionyou check it: has it answered every argument? You use it as the basis of the administrative appeal
Tax assessment decisionthe title of claim: it establishes the amounts; it also serves as a payment notificationthe administrative appeal, within 45 days of communication; separately, the options for payment or suspension. A decision not to amend the tax base establishes no amounts, but it can be appealed (Article 268 of the Tax Procedure Code)
Report referring the matter to the criminal investigation bodiesdrawn up when the inspectors find facts that may constitute criminal offencesit is not a tax administrative act (Article 150(1) of the Tax Procedure Code); the inspection ends for the obligations and periods referred (Article 132)
What I check
  • the date on which the decision was communicated: the appeal period and the payment deadline run from it;
  • whether the decision states the remedy, the time limit and the competent authority; if not, the time limit for the appeal is 3 months;
  • whether the report responded to the written position submitted;
  • the amounts, broken down by each tax and period, and the ancillary charges (accesorii), which may come in separate decisions.

Hypothetical example. A company is communicated the tax assessment decision on 10 March. The payment deadline is 5 April. The administrative appeal can be filed until 25 April: 45 days counted in free days, extended to the first working day if 25 April is not a working day. The appeal does not stop enforcement. If the amount puts the business at risk, the application for suspension to the court must be prepared in parallel with the appeal, not afterwards.

Technical note

Law The inspection report contains the reasoned opinion on the taxpayer's written position and is the basis of the tax assessment decision, the decision not to amend the tax base or the decision amending the tax bases, issued within no more than 25 working days of the end of the inspection (Article 131 of the Tax Procedure Code). The tax assessment decision also serves as a payment notification (Article 95(6)). During the inspection, the taxpayer may request a provisional tax assessment decision (Article 133).

Law The administrative appeal is an administrative remedy against the title of claim; the tax base and the claim are appealed together; decisions not to amend the tax base can also be appealed (Article 268 of the Tax Procedure Code). It is filed in writing with the issuing tax authority, no stamp duty is payable (Article 269) and, for acts of the central tax authority, it is decided by the specialised structure within the Ministry of Finance (Article 272). The time limit: 45 days from communication, on pain of forfeiture, or 3 months if the act does not contain the information on the remedy (Article 270). The report referring the matter for criminal investigation is not a tax administrative act (Article 150(1)).

Law The administrative appeal does not suspend enforcement (Article 278(1) of the Tax Procedure Code). Suspension is requested from the administrative court, against a security calculated in bands (Article 278(2)). If the appeal is not decided within 6 months of filing, you can go directly to court (Article 281(5)).

Chapter 20

After the inspection: closing the file and archiving.

In brief

The inspection ends with the decision, but the file does not. The time limits for the appeal and for payment, and the limitation period, continue to run, and the same period can be checked again only in limited cases. What you keep now determines what you can prove in a few years' time.

What I keep
  • the notice, the report, the decision and proof of the date on which each was communicated;
  • the register of requests and the indexes of the documents handed over;
  • the written position submitted and proof of filing;
  • the minutes of the video conference meetings, if there were any;
  • the statement given at the end on the provision and return of documents;
  • the records for the period checked, at least for the duration of the limitation period and of the statutory archiving periods.
Technical note

Law An inspection is carried out only once for each type of claim and period (Article 118(3) of the Tax Procedure Code). The exceptions: re-inspection, if additional data emerge that were unknown (Article 128); redoing the inspection, if the decision was set aside on administrative appeal (Article 129); resumption after termination or after a criminal referral has been closed (Article 126(2), Article 132(5)). After an inspection completed with a report and a decision, the reservation of subsequent verification is cancelled (Article 94(3)), and the tax returns for that period can no longer be corrected, subject to the exceptions in Article 105(6).

Law Limitation period for the right to establish tax obligations: 5 years, from 1 July of the year following the one for which the obligation is due (Article 110(1)-(2) of the Tax Procedure Code); 10 years for claims arising from acts provided for by criminal law, punished as such by a final court judgment (Article 110(3)-(4)).

Chapter 24

The review of personal tax status.

In brief

This is a review of an individual, not of a company or of a PFA (authorised self-employed individual). ANAF compares declared income with income estimated on the basis of assets, expenditure and money flows. If the difference is not explained with documents, tax is assessed on the income considered unjustified. The procedure concerns income tax only.

How it unfolds
  1. Risk analysis. A risk exists when the difference between estimated and declared income exceeds 10% of declared income and is at least RON 50,000.
  2. The compliance notice. 30 days to correct the tax returns. Correcting them does not guarantee that a review will not follow.
  3. The notice of review (aviz de verificare). It states the period, the start date, the documents requested and the request for the statement of assets and income.
  4. The documents. 60 days from communication of the notice, on pain of forfeiture; a single extension of 30 days. The statement of assets and income is filed as set out in the notice.
  5. The review. No more than 270 days from the start, excluding the periods allowed for documents. ANAF uses indirect methods: source and use of funds, cash flows, net worth.
  6. Conclusions and hearing. A written position within 5 working days of the conclusions being presented.
  7. The decision. A tax assessment decision, or a decision terminating the procedure if the base is not adjusted.
What I prepare
  • an inventory of the sources of money for each year reviewed: salaries, dividends, sales, loans, gifts, inheritances;
  • proof of each source, dating from the time of the transaction;
  • complete statements for all accounts, including those abroad;
  • the request for the review to be conducted at the professional office of the lawyer or of the tax consultant, if you wish: it is filed before the start date.
Technical note

Law Articles 138-147 of the Tax Procedure Code. Risk threshold: Article 138(2)(a). Compliance notice: Article 1401. Notice and statement of assets: Article 138(5)-(7) and Article 141. The 60-day time limit and the extension: Article 138(6); if the documents are not filed, the review is carried out on the basis of the information held by the tax authority (Article 138(10)). Duration: Article 140(6)-(7). Place: Article 140(3)-(51). Conclusions and written position: Article 145. Decision: Article 146. Indirect methods: ANAF President's Order No 675/2018, as amended, among others, by Order No 91/2026.

Law Competence lies with the General Directorate for the Control of Individuals' Income and with the tax review services; since July 2026, ANAF President's Order No 768/2026 also includes the General Directorate for Tax Anti-Fraud. For the taxation of income whose source is not identified, see the analysis on the expert in wealth reviews.

Situations in which the answer differs: through the cross-reference in Article 147 of the Tax Procedure Code to the inspection rules, exceeding twice the statutory duration leads to termination (Article 126(2)), and acts issued after termination are null and void (Article 49(1)(f)); how the duration is calculated in this procedure is not settled; a new review of the same period is possible only if additional data emerge (Article 144).

Contents

The chapters of the guide.

The chapters are on this page or in separate analyses, linked below. Those marked “in preparation” are not yet published; until then, the link leads to the closest analysis, if there is one.

  1. 1. Before the inspection: situations worth clarifyingon this page
  2. 2. The phone call from ANAF or from your accountantanalysis
  3. 3. Communications in the SPV and calculating the time limitchapter
  4. 4. Which procedure is it, in fact?on this page
  5. 5. The notice and the subject matter of the inspectionanalysis
  6. 6. Preparing the documentsanalysis and worksheets
  7. 7. Who does what: client, accountant, lawyer, experton this page
  8. 8. The start of the inspection and the timetableanalyses: duration, video conference
  9. 9. Document requests and their registerworksheet
  10. 10. Explanations and repliesanalysis
  11. 11. Evidence and proving that the transactions are genuinein preparation
  12. 12. Access to the administrative filein preparation
  13. 13. Findings and disagreementanalysis
  14. 14. The draft inspection reportanalysis
  15. 15. The final discussion and the written positionanalysis
  16. 16. The report and the tax assessment decisionon this page
  17. 17. The administrative appealanalysis
  18. 18. Payment, enforcement, suspension, guaranteesanalyses: suspension, enforcement
  19. 19. Litigationanalyses
  20. 20. Closing and archivingon this page
  21. 21. Specific points for individualson this page and on the dedicated page
  22. 22. Specific points for PFAsdedicated page
  23. 23. The desk reviewchapter
  24. 24. The review of personal tax statuson this page
  25. 25. Anti-fraud and other related proceduresanalyses: the criminal threshold
  26. 26. Glossary, checklists and worksheetson this page and in the worksheets
Glossary

The terms used in the guide.

Tax administrative act (act administrativ fiscal)
The act issued by the tax authority that produces legal effects in tax matters, for example the tax assessment decision. It takes effect from communication.
Notice of tax inspection (aviz de inspecție fiscală)
The document by which the tax authority announces the inspection: the legal basis, the start date, the taxes and the periods checked.
Notice of review of personal tax status (aviz de verificare)
The document that opens the review of an individual and requests the documents and the statement of assets and income.
Communication
Bringing the act to the addressee's attention, through the SPV, by post, by hand delivery or by public notice. Time limits run, as a rule, from communication.
Administrative appeal (contestație)
The administrative remedy against the tax assessment decision and other tax administrative acts, which is exercised before going to court; if it is not decided within 6 months of filing, you can go to court (Article 281(5) of the Tax Procedure Code).
Appeal against enforcement (contestație la executare)
An application to the court against an unlawful enforcement act, for example a garnishment.
Anti-fraud inspection
An operational inspection by the General Directorate for Tax Anti-Fraud, without prior notice, concluded with an official report (proces-verbal). It is not a tax inspection.
Unannounced inspection (control inopinat)
An inspection without prior notice, lasting no more than 30 days, concluded with an official report. It is not a tax inspection.
Tax assessment decision (decizie de impunere)
The act that establishes or amends tax obligations and the amounts payable. It is a title of claim and it is the act that is appealed.
Final discussion
The meeting at the end of the inspection at which the draft inspection report is discussed. Its date is, as a rule, the date on which the inspection ends.
Administrative file
The documents of the inspection, which the tax authority makes available at the taxpayer's written request.
Tax inspection
The check of tax returns and tax obligations for certain periods, either general (all obligations) or partial (some obligations).
Indirect methods
The methods by which ANAF estimates an individual's income in a review of personal tax status: source and use of funds, cash flows, net worth.
Compliance notice (notificare de conformare)
The invitation to correct tax returns within 30 days, before a possible selection for inspection.
Limitation period (prescripție)
The period within which the tax authority can establish obligations: as a rule, 5 years from 1 July of the following year.
Draft inspection report
The proposed findings of the inspection, communicated before the final discussion.
Written position (punct de vedere)
The taxpayer's written response to the findings, filed within the statutory time limit; the report must respond to it with reasons.
Tax inspection report
The final findings of the inspection, on the basis of which the decision is issued.
Redoing the inspection (refacere)
Taking up the inspection again after the decision has been set aside on administrative appeal, strictly within the limits of the decision on the appeal.
Re-inspection (reverificare)
Checking again a period that has already been inspected, possible only if additional data emerge that were previously unknown.
Reservation of subsequent verification
The rule under which declared obligations can be checked later; it is cancelled after an inspection concluded with a report and a decision, or when the limitation period expires.
SPV (Spațiul Privat Virtual)
The electronic system through which ANAF communicates acts and through which the taxpayer submits documents.
Suspension of enforcement
The temporary halting, by the court, of the effects of the tax assessment decision, conditional on the deposit of a security.
Enforceable title (titlu executoriu)
The title of claim that has become enforceable on the payment deadline, on the basis of which enforcement can be carried out.
Desk review (verificare documentară)
The analysis of the tax position carried out at the tax authority's office, on the basis of the tax file and of information from third parties.
Legal sources and updates

The legislation used and the date of verification.

The guide is based on the consolidated text of the Tax Procedure Code (Law No 207/2015) published by ANAF (last amendment indicated: Law No 170/2026), consulted on 16 October 2026, and on ANAF President's Orders No 705/2026 (video conference), No 420/2023 (the compliance notice in inspections), No 675/2018, as amended (indirect methods), No 768/2026 (competence in the review of personal tax status) and No 1090/2022 (communication through the SPV). The references to Law No 554/2004 on administrative court proceedings and to the Civil Procedure Code, for calculating time limits, were checked in the version in force on 17 October 2026, as was Order No 1090/2022. The articles are cited in the technical notes of each chapter.

Author and legal review: Florin Hrițuliac. Date of verification: 16 October 2026.

The guide is reviewed quarterly and after every relevant amendment to the Tax Procedure Code or to the ANAF orders on inspections.

Change log

Information material, updated on 16 October 2026. It does not constitute legal or tax advice; individual situations must be analysed case by case.

Questions

The guide, in brief.

Does the guide replace a consultation?

No. The guide explains the procedures and time limits in general terms. A consultation analyses your documents and tells you what applies in your specific case.

I have received a document and I do not know what it is. Where do I start?

With chapter 4: the title of the document, the issuing body and the article of law in the first paragraph indicate the procedure. The time limit runs, as a rule, from communication, not from issue.

Are the tax inspection and the review of personal tax status the same thing?

No. The inspection concerns a taxpayer's tax obligations for certain periods. The review of personal tax status concerns only individuals and only income tax, by comparing declared income with assets and expenditure.

How often is the guide updated?

Quarterly and after every relevant amendment to the Tax Procedure Code or to the ANAF orders on inspections. The date of the last verification and the change log are at the end of the page.

Contact

Has someone from ANAF called you, or has your accountant let you know?

A phone call does not start any time limits. A communicated act does. Tell me what document exists, or whether there is none; we will establish what procedure it is and what comes next.

Useful to have to hand: the name of the institution and of the person who called, the date, what you were asked for, any message received in the SPV.

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.

E-mailrolegal@pm.me
Phone+40 799 597 410
AvailabilityNational and international · office in Brașov
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