RO e-Factura for PFAs, associations, foundations, and natural persons: Clarifications and new deadlines through Order 378/2026
Through the Order of the president of the National Agency for Fiscal Administration no. 378/2026 regarding the amendment and completion of the Order of the president of the National Agency for Fiscal Administration no. 3,789/2024 for the approval of the Procedure regarding the organization and registration in the mandatory RO e-Factura Register, as well as the model, content, and completion instructions of form (082) “Application for registration in the mandatory RO e-Factura Register”, published in the Official Gazette no. 250 of March 31, 2026, essential amendments are introduced regarding the obligations for registration and use of the RO e-Factura system, especially for natural persons carrying out economic activities.
What it stipulates
The Order brings clarifications and new deadlines for certain categories of taxpayers, especially for suppliers/service providers who are fiscally identified by personal numeric code (CNP). It is established that these entities do not have the obligation to use the national electronic invoicing system RO e-Factura until June 1, 2026. This provision offers an important respite for adapting to the system’s requirements. Furthermore, those who have already been registered in the mandatory RO e-Factura Register can now request removal from this register, a process that is carried out as of the date of submitting the request.
For natural persons identified by CNP who carry out economic activities and who are not yet registered in the system, clear compliance deadlines are established. Those who started economic activity before June 1, 2026, are obliged to request registration in the mandatory RO e-Factura Register no later than May 26, 2026, their registration becoming effective starting June 1, 2026. In the case of persons who start economic activities after June 1, 2026, the registration obligation remains valid before the start of the activity, and registration is carried out within 3 working days from the date of the request.
The normative act amends and completes the procedure for organizing and registering in the RO e-Factura Register, as well as the model of form (082). The new form now allows both registration and removal from the register. Also, the register will include detailed information regarding the history of registrations, namely the date of registration and the date of removal, ensuring improved traceability of taxpayers’ status in the e-Factura system.
To whom it applies
The provisions of this order apply to the following categories of entities:
- Associations and foundations established according to law, other non-profit/non-patrimonial associations, political parties, and cults, which are not registered for VAT purposes, for invoices issued starting July 1, 2025.
- Natural person farmers who apply the special regime for farmers, for invoices issued starting July 1, 2025.
- Suppliers/service providers who are fiscally identified by personal numeric code (CNP), such as authorized natural persons (PFA), individual enterprises (II), family enterprises (IF), or liberal professions, who have obligations to use the RO e-Factura system according to current legislation.
What you need to do
- Evaluate whether your entity falls into the category of suppliers/service providers identified by personal numeric code (CNP) and whether you have RO e-Factura obligations.
- Check if you are already registered in the mandatory RO e-Factura Register.
- Decide if you wish to request removal from the register, in case you are a natural person identified by CNP and have been registered.
- Ensure that, if you are a natural person identified by CNP and started economic activity before June 1, 2026, you submit form 082 for registration no later than May 26, 2026.
- Implement the procedure for using the new form (082) for registration or removal from the register.
- Instruct personnel responsible for fiscal compliance regarding these new deadlines and procedures.
- Monitor ANAF communications for any additional clarifications regarding the application of these provisions.
Published in Official Gazette, Part I, no. 250 of March 31, 2026.
Note: This material is strictly for informational purposes and does not constitute legal, fiscal, or business advice. As the interpretation and application of legal provisions can 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.