Updated list of medium taxpayers and implications for SAF-T reporting in 2023

The authorities have recently published the updated list of medium-sized taxpayers on the ANAF website, applicable as of 1 January 2023. The list covers over 15,000 entities and, besides the administrative implications, is particularly important in terms of SAF-T reporting requirements (SAF-T/D406 statement according to OPANAF no. 1783 of 04.11.2021 on the type of information the taxpayer/payer must declare through the standard fiscal control file, reporting template, the submission procedure and conditions, as well as the submission deadlines and the date/dates as of which the categories of taxpayers/payers are required to submit the standard fiscal control file).

More precisely, as of 1 January 2023 all taxpayers included on the list* will have to fill in and submit a D406 informative statement (SAF-T statement), either monthly or quarterly, depending on the applicable tax period for VAT. These periodic statements shall also be supplemented by the annual report on assets as well as the report on stocks which shall be communicated only at the request of the authorities.

* It should also be mentioned here that OPANAF no. 2518 of 15.12.2022 includes several clarifications regarding the deadlines from which the SAF-T reporting obligations shall become applicable for certain categories of taxpayers, including companies that became medium-sized taxpayers as of January 1, 2023. For example, medium-sized taxpayers on 31 December 2021 which no longer fall into this category on 1 January 2023 are required to submit the D406 informative statement as of 1 January 2025, but may, however, opt to submit it as of 1 January 2023 (without being able to give up this option later). Moreover, small taxpayers which fall into the category of medium-sized taxpayers as of January 1, 2023 are required to submit D406 statement as of 1 January 2023.

For some taxpayers, the news comes very late, considering that in approximately 2 weeks’ time their IT systems should already be adapted to the reporting requirements – even if a grace period of 6 months is applied to the submission of the D406 statement for medium-sized taxpayers, the workload of the financial and accounting department will increase significantly as the entries are not made from the beginning in compliance with the template provided by the authorities. The difficulties lie in the multitude of information the D406 statement must include on each transaction, business partners, stocks, assets, etc., and in particular in adapting software so that the generated D406 statement is complete, correct and submitted to the authorities without errors.

The fact that this statement has already been submitted since 2022 by large taxpayers, has helped them and the consultants involved in the implementation process gain an experience, but we cannot say that there is enough practice.

There still exists several challenges that need to be overcome, such as:

• software frequently used by taxpayers which have not yet been adapted or have been only partially adapted to the new reporting requirements. In this case, either a solution is expected from the software provider, or the taxpayer needs to identify a viable alternative;

• the use of several accounting and management software solutions by the same taxpayer for different purposes but which only when used together provide all the information required to fill out a D406 statement (e.g., a software for keeping quantity/stock/production records and another one for recording transactions and generating tax returns). Such a situation requires the acquisition or development of a software solution that would properly integrate the reports generated by the existing programs;

• the need to allocate significant resources in order to carry out the implementation process. The process itself is complex, time-consuming and requires close collaboration between internal teams in the financial – accounting departments, external consultants and software solution providers.

Although there are still various obstacles to overcome, with many companies having to perform additional work to be able to obtain a complete and correct statement, we can only hope that the experience gained by all parties involved, especially during 2022, will contribute to a less difficult implementation of the SAFT among medium-sized taxpayers

What must be done next?

Companies will first have to check the updated list of medium-sized taxpayers in order to determine whether they bound by D406 statement as of 1 January 2023. They will then have to analyse their internal software, the reports they generate and their available resources, so that they can define the needs for alignment with D406 statement. The remaining time is extremely short, therefore, we need to act quickly.

Sorana Cernea



Alexandru Pop

Tax Manager


TPA Romania

Cluj-Napoca, Str. Ploiești 17-19A

Tel.: +40 264 446 611


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