Mandatory Daily Reporting to ANAF: What Order 393 Brings
Through Order 393 regarding the amendment of the Order of the President of the National Agency for Fiscal Administration no. 3,746/2020, published in Official Gazette no. 259 of April 1, 2026, mandatory technical amendments are introduced regarding the method of reporting information about bank and payment accounts to the central electronic Register.
What Does It Stipulate?
The main amendment consists of imposing a new technical structure, in XML format, for daily data reporting to ANAF. The Agency has updated the file format to streamline data collection and introduce new automatic validation rules. The use of the old reporting format will no longer be permitted after the expiration of a 10-working-day period from the effective date of this order, at which point ANAF systems will reject any file that does not comply with the new structure.
The purpose of reporting remains unchanged. The targeted institutions must daily communicate to the central electronic Register a detailed list of account opening and closing operations. The transmitted information includes complete identification data for account holders (natural persons or legal entities), persons with signatory rights, beneficial owners, and persons claiming to act on behalf of the client. The data set includes the IBAN code, the account opening date, and the account closing date.
Similarly, the daily reporting obligation also applies to safe deposit box rental agreements. Institutions must transmit the identification data of persons who have rented such boxes, as well as information regarding the termination date of the rental agreements. All this information must be integrated into the new XML format.
To Whom Does It Apply?
The reporting obligations according to the new technical procedure target all credit institutions (banks), payment institutions (known as PI), and electronic money institutions (known as EMI) operating in Romania.
What Are the Sanctions?
Although the order focuses on procedural aspects, non-compliance with the transition period and non-use of the new XML format are equivalent to non-fulfillment of the legal daily reporting obligation. The immediate consequence is the technical rejection of reports, which may lead to the sanctions provided by the Fiscal Procedure Code for non-declaration.
What You Need to Do
- Download the new XML structure and related technical documentation from the official ANAF website, once they become available, to understand the new formatting and validation requirements.
- Update internal reporting applications to generate files according to the new XML format, ensuring correct mapping of all mandatory data fields.
- Ensure testing and implementation of the new reporting procedure in production before the expiration of the 10-working-day period from April 1, 2026.
Published in Official Gazette, Part I, no. 259 of April 1, 2026.
Note: This material is strictly for informational purposes and does not constitute legal, tax, or business advice. As the interpretation and application of legal provisions may vary significantly depending on the specific circumstances of each entity, we recommend seeking specialized legal assistance before adopting any operational decisions based on these amendments.