Key changes at a glance

• Share transfers in SRLs – a tighter procedure with cross‑checks between ANAF and the Trade Registry (ONRC)

A share transfer—regardless of which shareholder is involved—becomes opposable to the tax authority only if it is reported to ANAF within 15 days and, where the company has outstanding tax liabilities, guarantees must be provided to cover the amounts shown on the fiscal attestation certificate. At registration, ONRC will request the necessary confirmations directly from ANAF, including the approval regarding the guarantees.

• RO e‑VAT – removal of the automatic discrepancy notification

The obligation regarding the automatic notification of discrepancies between the pre‑completed RO e‑VAT return and the taxpayer’s filed return has been repealed. Companies remain fully responsible for accurate reporting and for ensuring that internal records align with declared amounts.

• Tax‑risk class – communication suspended until 31 December 2026

ANAF will not provide, upon request, the tax‑risk class/sub‑class during the suspension period. This shifts responsibility to companies to self‑assess and monitor their risk indicators.

• Excise goods & energy products – clarifications for new operator categories

Additional transitional rules apply to authorized importers, registered exporters, and energy‑product distributors, ensuring operational continuity and more effective implementation of previous anti‑fraud measures regarding excise and VAT.

What companies should do now

1) Share transfers (SRL)

• Verify the company’s fiscal status early by obtaining the fiscal attestation certificate before initiating the transfer.
• Prepare and submit the ANAF notification file within 15 days of the transfer (share‑transfer agreement + updated Articles of Association).
• If tax liabilities exist, plan and provide guarantees in line with Article 211 of the Fiscal Procedure Code; ONRC will require proof of ANAF’s approval at registration.

2) RO e‑VAT

• Update internal VAT procedures accordingly: even though the discrepancy notification has been removed, maintain a monthly reconciliation between VAT journals, e‑Invoice/SAF‑T data and the VAT return to avoid undetected inconsistencies.

3) Tax‑risk class

• Introduce an internal tax‑risk scorecard (late VAT filings, outstanding debts, mismatches in e‑reporting, number of amended returns, etc.).
• Schedule quarterly internal reviews; absence of ANAF communication does not eliminate the underlying tax‑risk monitoring performed by the authority.

4) Excise / energy‑product operators

• Review the company’s status and documentation (authorizations, guarantees, document flow) to ensure alignment with the newly clarified requirements and smooth interaction with partners and authorities.

How Argus Audit supports you

• OUG 13/2026 Compliance Checklist (share transfers, VAT/e‑reporting, tax‑risk indicators) – ready for immediate implementation.
• Rapid Tax‑Risk Mini‑Audit – 10‑day assessment of VAT flows, e‑Invoice/SAF‑T reconciliations, outstanding balances and reporting consistency.
• Operational Share‑Transfer Kit – ANAF notification model, ONRC documentation list, and guidance for guarantee preparation.