The compliance notice is, in most cases, the first official sign that ANAF has included you in a risk analysis and that your personal tax position is being viewed with suspicion. It is not yet an inspection and it does not establish any amount payable, but how you respond in the first 30 days can decide whether the file closes quietly or turns into a review of your personal tax position, with everything that entails.
The compliance notice is a document by which the tax authority informs you, before selecting you for an inspection, that the risk analysis has revealed possible discrepancies between the income estimated from the data it holds and the income you have declared. You are given the opportunity to review your tax position and, where appropriate, to file or correct your returns, within 30 days of communication.
For individuals, the mechanism is governed by Article 140¹ of Legea nr. 207/2015 on the Tax Procedure Code, inserted by Ordonanța Guvernului nr. 31/2022 and applied in practice by ANAF from 2023. There is, in parallel, also a compliance notice issued by the tax inspection body (Article 121¹ of the same Code, with the form approved by OPANAF nr. 420/2023), which is aimed mainly at taxpayers carrying on economic activities. This analysis concerns the notice addressed to individuals in connection with the review of an individual's tax position (VSFP).
Equally important is what the compliance notice is not:
The notice is not sent at random. It is the result of a risk analysis in which ANAF compares “uses of funds”, the money you have spent or placed, with declared income. According to material published by ANAF itself, the indicators monitored come mainly from the following sources:
From the returns filed by notaries public (D208) and by sellers (D209), plus individual reports concerning the construction of buildings.
The written notice is not the only channel through which the tax authority makes contact: there is also the telephone call, with its own rules.
From information-exchange protocols with the institutions that keep records of these assets.
Estimated from the interest reported by banks or from information on account balances in Romania or abroad, including under the protocol between ANAF and the Romanian Association of Banks.
The balances of accounts 455/462 in the balance sheets of companies in which you are a shareholder.
Increases in capital or acquisitions of shareholdings, data taken from the trade registry (registrul comerțului).
Investments in government securities, and losses reported in the Declarația unică.
The relevant threshold in the review procedure is the significant difference defined by Article 138 of the Tax Procedure Code: a difference between estimated and declared income of more than 10% of declared income, but not less than 50,000 lei.
The stakes have risen considerably: since 1 July 2024, income established by the tax authorities whose source has not been identified is taxed at a rate of 70% applied to the adjusted taxable base (Legea nr. 296/2023). And under OPANAF nr. 768/2026, published in the Official Gazette on 6 July 2026, the power to carry out the review of an individual's tax position was extended to inspectors of the General Anti-Fraud Directorate, a clear sign that the review of individuals is becoming an operational priority for ANAF in 2026.
The date of communication is not the date of issue. Communication is made under Article 47 of the Tax Procedure Code: through the Spațiul Privat Virtual (SPV), the tax authority's secure online portal, by post with acknowledgement of receipt, or by the other lawful means. Where communication is made by electronic means of remote transmission, the act is deemed communicated within 15 days of the date of transmission (Article 47(15)); it is therefore essential to check your SPV account constantly, because the time limit can run even if you have not opened the document.
Within the 30 days you are protected. The law expressly provides that, until the time limit expires, the tax authority takes no action to select you for the review of your tax position. It is, in practice, a window for dialogue.
Once the time limit expires, the rule reverses. Under Article 140¹(4) of the Tax Procedure Code, individuals with a high tax risk who have not remedied the risks for which they were notified are automatically subject to the review of their tax position. If it gets to that stage, you receive an inspection notification (communicated, as a rule, at least 15 days before the review begins), you may be asked for supporting documents and the declaration of assets and income, and the tax authority may reconstruct your income by indirect methods, over the limitation period, generally 5 years.
WARNING. The biggest risk is to ignore the notice. Silence does not “bury” the file; on the contrary, if the risk is classified as high, the review of your tax position becomes compulsory by operation of law. In such a review, the burden of justifying the source of the funds falls, in practice, on you, and amounts left unjustified can be taxed, since July 2024, at the rate of 70%, plus interest and penalties. The difference between a documented response sent within 30 days and no response at all can mean, financially, the difference between a reasonable correction and a tax assessment decision that affects your assets for years.
Confirm that the document genuinely comes from ANAF (in the SPV or by post, with a letterhead, a registration number and a contact person); fake messages do circulate. Note the exact date of communication: it is from this date that the 30-day time limit runs.
The notice sets out the tax and wealth indicators that generated the risk, and the periods concerned. Do not reply “in general”; reply point by point to what is stated.
For the periods indicated, list every source of funds: declared income, non-taxable or exempt income, loans received, sums from the sale of personal belongings, earlier savings, income from abroad.
Bank statements, sale or loan agreements, deeds of gift, evidence of transfers, documents relating to income from abroad, a certificate of tax residence if relevant. A statement with no document remains, for the tax authority, a mere statement.
The estimates in the risk analysis can contain errors: values estimated from open sources, shareholding percentages calculated wrongly, balances read as “uses of funds” when they are in fact turnover. You are entitled to show, with documents, that the uses of funds are smaller than estimated, or do not exist.
Three approaches, which can be combined: file or correct the Declarația unică (D212); submit documents on the non-taxable nature of the funds; submit a reasoned statement that the risks are not confirmed. Under ANAF's guidance, communication is addressed to the Directorate General for the Control of Individuals' Income, and in ANAF's practice this is done by e-mail to [email protected] or by post; always check the channel indicated in the notice you received.
Send your response before the 30 days are up, through a channel that gives you proof of sending, and keep a complete copy of the file. What you submit now will also be examined in any later review.
The most costly mistake: if the risk is classified as high, the review becomes compulsory by operation of law.
“I saved up over the years” clarifies nothing without documents. Contradictory explanations sent now can be used against you later.
Backdated loan agreements or receipts drawn up after the notice was received can attract criminal liability (forgery, use of a forged document) and turn a tax problem into a criminal one.
Done merely to cover the estimated difference, it creates payment obligations that are not actually owed and an inconsistent tax position that is difficult to put right.
Documents that were not requested and have not been reviewed beforehand can open up other lines of review.
ANAF states expressly that filing or correcting returns does not prevent selection for review if the risk persists. The content and consistency of the response matter just as much.
You can handle a simple notice yourself, for example, a one-off omission from a return that you correct through the Declarația unică. Involving a specialist becomes advisable, however, when:
The reasoning behind early involvement is simple: at the notice stage, the file is still flexible; you can correct, explain and document without the pressure of a formal review. Once the inspection notification is issued, the room for manoeuvre narrows, and every statement and document submitted is assessed within a strict procedural framework. A professionally prepared response within the 30 days is generally the most effective tax defence available.
No. The notice is a preliminary stage: if your response clarifies the risks flagged, selection for review can be avoided. The review does become compulsory, however, for people with a high risk rating who do not remedy the risks they were notified of.
The Tax Procedure Code makes no provision for extending this time limit. That is why it is essential to start your review immediately after communication, not in the last week.
Not automatically. Filing or correcting returns does not prevent selection for review if the risk of non-compliance persists. What matters is that the response coherently covers every risk flagged, with documents.
Not directly; the notice is not a tax administrative act and it does not establish any payment obligation. The defence is exercised through the documented response sent in time and, if the procedure continues, against the acts issued in the course of the review, including, ultimately, against the tax assessment decision.
Informative material, updated on 17 July 2026. It reflects the legal framework as at the date of writing; it does not constitute legal or tax advice and cannot replace an assessment of your specific situation by a professional.
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.