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Mandatory e-Invoice for NGOs

Through Order 1.020/2026, published in Official Gazette no. 706 of August 25, 2026, new rules are introduced regarding the registration of certain entities in the mandatory RO e-Invoice Register.

What does it stipulate?

The main amendment extends the obligation to register in the national electronic invoicing system to a new category of entities. Associations, foundations, political parties, and religious cults that are not registered for VAT purposes now have the obligation to register in the mandatory RO e-Invoice Register. This registration must be completed before commencing any economic activity. Practically, any economic transaction carried out by these entities will have to be managed through the e-Invoice system, similar to classic economic operators.

To facilitate the transition, the order provides for an automatic transfer mechanism. Entities from the categories mentioned above that were already registered in the optional RO e-Invoice Register will be automatically transferred by the authorities to the mandatory RO e-Invoice Register. This measure eliminates the need to submit a new application for entities that were already voluntarily using the system, but it consolidates their status as obligated users.

The registration procedure is carried out by submitting form (082) “Application for registration in/removal from the mandatory RO e-Invoice Register”. Actual registration in the register is completed within 3 working days from the date of form submission. In parallel, the normative act also clarifies the procedure for deregistration from the register. Suppliers, service providers, or farmers applying the special regime, who have been registered in the register but do not have the legal obligation to use the system, may request removal using the same form (082). Deregistration becomes effective starting from the 1st of the month following the submission of the application.

To whom does it apply?

The obligation to register in the mandatory RO e-Invoice Register applies to the following categories of entities, provided that they are not registered for VAT purposes according to the Fiscal Code:

  • Associations and foundations established according to Government Ordinance no. 26/2000.
  • Other non-profit or non-patrimonial associations.
  • Political parties.
  • Religious cults.

The provisions regarding the possibility of requesting removal from the register concern natural person suppliers/service providers and farmers who apply the special regime, who have been registered in the mandatory RO e-Invoice Register, but who do not have the legal obligation to use the system.

What should you do?

  • Evaluate your tax status and economic activities. If your entity falls into the categories above, is not a VAT payer, and carries out or intends to start economic activities, you must comply with the new rules.
  • Submit form (082) before commencing economic activity. Complete and electronically submit the application for registration in the mandatory RO e-Invoice Register to avoid any non-compliance.
  • Check your status in the register if you were optionally registered. If your entity was already in the optional Register, confirm on the ANAF website that the transfer to the mandatory Register has been correctly performed.
  • Request removal from the register if you do not have this obligation. If you are among the economic operators registered in the register without a legal obligation to do so, submit form (082) to request deregistration.

Source: Official Gazette, Part I, no. 706 of August 25, 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 can vary significantly depending on the specific circumstances of each entity, we recommend that you seek specialized legal assistance before adopting any operational decisions based on these changes.

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