Same month, same company, four filings: invoices in e-Factura, ledgers in SAF-T, tax in the VAT return, trading partners in Declarația 394. Four figures that should tell the same story and, most of the time, do not. The notice that asked you for explanations within 20 days disappeared in March 2026. The comparison did not.
The RO e-TVA system, set up by OUG nr. 70/2024, compared the return filed with one pre-filled from e-Factura, e-Transport and SAF-T, and sent a compliance notice (notificare de conformare) for differences of more than 20% and at least 5,000 lei, with an obligation to respond within 20 days. OUG nr. 89/2025 removed, from 1 January 2026, the obligation to respond and the penalties; OUG nr. 13/2026 removed, from 9 March 2026, the notice itself and the automatic selection for inspection.
What remains is the essential part: the four streams continue to be filed, SAF-T has become mandatory for all categories of taxpayers, and their data is compared in the general risk analysis under the Tax Procedure Code, which the 2026 ordinance left untouched, precisely because it duplicated it. A mismatch no longer produces a letter; it produces a score. And the score produces the inspection.
How you correct an incorrect invoice in the system is covered separately.
Every invoice issued to companies, institutions and individuals, in XML, sent within five working days of issue. It is the most granular and fastest stream: the tax authority has the invoice before it even reaches the accounts. It does not cover till receipts, imports, intra-Community acquisitions, or self-billed invoices in every case.
The standard audit file for tax purposes: sales and purchase ledgers, the journal register, invoices, payments, trading partners, products, at transaction level, extracted from the accounts. Monthly or quarterly, depending on the VAT period, by the last day of the following month; the assets section annually, the inventory section on request, within a minimum of 30 days. From 2026, all categories, with no grace period.
The taxable base and the tax, output and input, for the tax period, with adjustments, corrections, imports, intra-Community acquisitions and supplies, reverse charge, cash-based chargeability. It is the only stream that generates the payment obligation, due by the 25th of the following month. The pre-filled P300 return remains available in the Spațiul Privat Virtual (SPV), the tax authority's secure online portal, as an informative tool.
Domestic supplies and acquisitions, broken down by trading partner, with totals by VAT rate, filed together with the return. It is the stream through which the tax authority cross-checks the supplier against the customer: what one declared as sold against what the other declared as bought.
The four streams are not copies of the same register; each has its own scope, its own timing and its own aggregation rules. That is why part of the differences is structural. An invoice issued on the last day of the month and sent through e-Factura in the first days of the following month shows up in different periods. Till-receipt supplies to individuals are in the return but not in e-Factura. Intra-Community acquisitions are in the return and in the recapitulative statement, not in Declarația 394. Invoices from suppliers on the cash-based VAT system are deducted on payment, not on receipt. Base adjustments, storno entries and correction invoices may be recorded at a different time than the transmission.
Other differences are the signal the tax authority is looking for. Invoices in e-Factura that do not appear in the SAF-T ledgers: unrecorded income. Purchases deducted in the return with no matching entry in the supplier's e-Factura: invoices from outside the system, or suppliers who did not transmit. Supplies declared by the supplier in Declarația 394 that the customer does not declare: either the customer is hiding something, or the supplier is fabricating something. Large and persistent differences between the e-Factura total by rate and the base in the return: incomplete output tax. These are exactly the patterns described in the analyses on carousel fraud and on digital evidence in tax evasion cases, seen from the compliant company's side, not from the prosecution's.
What distinguishes the two categories is not the size but the explanation. A 30% difference documented by a list of invoices with deferred chargeability is a closed difference. A 5% difference with no explanation is an open question. The compliance notice, while it existed, asked for exactly this explanation; now nobody asks for it before an inspection, which means it has to already exist, in the company's own file.
June 2024: OUG nr. 70/2024 sets up RO e-TVA, with the pre-filled return, the compliance notice, the materiality threshold, the 20-day time limit and fines. 2024 and 2025: the penalties are postponed repeatedly, and the obligation to respond only comes into force from 1 July 2025. 1 January 2026: OUG nr. 89/2025 removes the obligation to respond and the penalties, on the grounds that the administration cannot process the volume of responses. 9 March 2026: OUG nr. 13/2026 removes the notice and the automatic selection for inspection based on e-TVA, as duplicating existing provisions of the Tax Procedure Code.
The correct reading of this timeline is not that the cross-checking failed, but that it was absorbed. The special mechanism, with its own time limits and fines, was replaced by the general mechanism of risk analysis, which uses the same data without giving notice any more. For the taxpayer, the only practical consequence is that the warning has been lost.
The pre-filled P300 return remains available monthly in the SPV. It creates no obligations, but it shows how the tax authority sees the company from the data it holds. It is the only place where the comparison can be made free of charge, beforehand, by both sides.
Every invoice sent through the system must exist in the SAF-T ledger, and vice versa. Timing differences are listed with the issue date and the transmission date; invoices missing from one side are the first finding of any inspection.
What suppliers sent through e-Factura against what was deducted. Invoices deducted with no matching entry in the system, from suppliers required to use it, are exposed deductions; they should be requested again or removed before the return.
The rate-by-rate totals in the ledgers must reconcile with the lines of the return, with an explicit list of items that do not come from the ledgers: imports, intra-Community transactions, reverse charge, adjustments, cash-based chargeability. That list is the explanation for the difference against e-Factura.
Domestic supplies and acquisitions by trading partner, aggregated, must be reflected in the return. Trading partners with an invalid code, and amounts declared by the supplier but not by the customer, are the risk signals of this stream.
The pre-filled return is downloaded monthly and compared with the one filed. The differences are explained in writing, for the company's own file, not for ANAF, which no longer asks for it. It is the warning the law withdrew, and one the company can give itself.
Differences that are errors are corrected at source: the invoice stornoed and reissued through the system, D406 refiled, a corrective VAT return, a corrective Declarația 394. Voluntary correction, before an inspection, is not an offence; a finding made during an inspection is.
For each period, a table of the four streams, the differences and the explanations, signed and dated. At the notice of tax inspection, it is the first document handed over; it moves the discussion from “why does it differ” to “here is why it differs”.
The notice is gone; the risk analysis remains, with the same data. You lost the warning, not the exposure.
SAF-T is the company's X-ray at transaction level, mandatory for everyone, with no grace period. What is in it is compared against everything else. A wrong SAF-T exposes you; a correct one defends you.
It is not the size that matters but the explanation. A small difference with no explanation is a question; a large one with an explanation is an answer.
Then it is the inspector who reconciles, with their own data and their own conclusions. A reconciliation done beforehand is yours.
No. OUG nr. 89/2025 removed, from 1 January 2026, the obligation to respond to the notice and the penalties for non-compliance, and OUG nr. 13/2026, in force from 9 March 2026, removed the notice itself and the provision on automatic selection for inspection based on e-TVA differences. The pre-filled P300 return remains available in the SPV, as an informative tool.
Because the data has not disappeared, only the notice has. e-Factura, SAF-T, the VAT return and Declarația 394 all reach the same databases and are compared in the general risk analysis under the Tax Procedure Code, which has not been repealed. Mismatches no longer generate a notice with a 20-day time limit; they generate, directly, a risk profile and, potentially, an inspection.
The informative return D406 files the standard audit file for tax purposes: sales and purchase ledgers, the journal register, invoices, payments, trading partners, products, at transaction level. It is filed monthly or quarterly, depending on the VAT tax period, by the last calendar day of the following month, with the assets section annually and the inventory section at ANAF's request. From 2026 it is mandatory for all categories of taxpayers, with no grace periods.
Because they report different things. e-Factura contains the invoices sent through the system; the return contains the taxable base and the tax for the tax period, including transactions with no invoice in the system, till receipts, imports, intra-Community acquisitions, reverse charge, adjustments, invoices with chargeability deferred to payment. An explainable difference is not an error; an unexplainable one is exactly what an inspection looks for.
For failing to file D406 on time, a fine of between 1,000 and 5,000 lei per reporting period, under the Tax Procedure Code, and the same fine for erroneous or incomplete data, together with the obligation to correct it. The more important consequence is not the fine, but that a missing or wrong SAF-T makes it impossible to reconcile the figures in your favour at inspection.
A monthly reconciliation, before filing, between the four streams: e-Factura totals against the SAF-T ledgers, the ledgers against the return, the return against D394, with a list of the differences and the explanation for each. It is exactly the analysis the tax authority carries out, done before it does and kept on file.
Informative material, updated on 18 September 2026. It does not constitute legal or tax advice; individual situations must be assessed on their own facts.
If your company has received a notification or has an inspection under way, the related analyses are grouped under tax inspection. For the assistance provided to companies, see corporate taxation.
An initial conversation establishes which differences are structural and which are signals, what needs correcting at source and what needs documenting, and how to build the reconciliation file that is handed over at the notice of tax inspection.