New tax on crude oil and rules at the pump: What does emergency ordinance 24/2026 bring?

Through the emergency ordinance regarding the temporary reduction of the excise duty level applicable to diesel and the establishment of a solidarity contribution on revenues from the sale of crude oil and energy products obtained from the processing of crude oil extracted from the territory of Romania, as well as for the amendment and completion of Romanian Government emergency ordinance no. 19/2026 and for the amendment of Romanian Government emergency ordinance no. 12/2026, published in Official Gazette no. 272 of April 3, 2026, a new tax for crude oil producers and strict rules for the sale of fuels at the pump are introduced, against the backdrop of a temporary reduction in the excise duty on diesel.

What does it stipulate?

The normative act introduces a new solidarity contribution, applicable to exceptional revenues from the oil sector. This tax is due only in months when the average Brent crude oil price exceeds 70 USD/barrel. For producers selling crude oil extracted from Romania, the contribution is 60% applied to revenues exceeding this threshold. For integrated producers, who extract and refine local crude oil, a progressive rate (between 1.5% and 9.9%) is applied to revenues from the sale of energy products (gasoline, diesel, etc.), depending on the Brent quotation level. The contribution is considered a deductible expense when calculating profit tax.

For fuel retailers, a strict rule is imposed regarding price changes at the pump. During the crisis situation, distribution station operators may increase gasoline and diesel prices at most once a day, until 12:00 PM. In contrast, price reductions can be made anytime and as many times as necessary. Non-compliance with this obligation incurs substantial contraventional fines, ranging between 100,000 lei and 500,000 lei.

In parallel, the excise duty level for standard diesel is temporarily reduced. During the crisis situation, the excise duty decreases from 2,804.29 lei/1,000 liters to 2,504.29 lei/1,000 liters. The measure aims to mitigate the impact of rising pump prices on economic operators and the population.

Companies subject to the solidarity contribution are obliged to organize distinct accounting and operational records to track quantities of crude oil from national production, total processed quantities, and related revenues. Furthermore, transactions involving crude oil or energy products between affiliated persons must be evaluated at market value. Non-compliance with record-keeping obligations is sanctioned with fines ranging from 200,000 lei to 1,000,000 lei.

To whom does it apply?

The measures apply to a specific set of economic operators in the energy and retail sectors:

• Crude oil producers: Companies holding petroleum agreements that extract crude oil from the territory of Romania (with the exception of territorial sea perimeters) and commercialize it.
• Integrated producers and refineries: Companies that extract crude oil from Romania and, directly or through affiliates, process it, obtaining revenues from the sale of energy products (gasoline, diesel, kerosene, LPG, fuel oil, etc.).
• Retail fuel traders: All companies operating distribution stations (gas stations) and selling gasoline and diesel to final consumers.
• Transporters and other diesel consumers: These are indirect beneficiaries of the excise duty reduction, without having direct obligations.

What should you do?

• Implement a system of distinct accounting and operational records for crude oil extracted from Romania, processed quantities, and resulting energy products, if you fall into the category of solidarity contribution payers.
• Calculate and declare the solidarity contribution monthly, if the average Brent crude oil price exceeds 70 USD/barrel, with a payment deadline by the 25th of the following month.
• Review the transfer pricing policy for transactions involving crude oil and energy products conducted with affiliated persons, to ensure compliance with the market value principle.
• Update internal procedures for changing pump prices to limit increases to once a day, exclusively before 12:00 PM, if you operate fuel distribution stations.
• Instruct personnel in distribution stations regarding the new rules for displaying and changing prices to avoid sanctions.

Source: Official Gazette, Part I, no. 272 of April 3, 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 changes.