Annual SRL inventory in 2026: inventory register 14-1-2, 7 working days, and a fine of RON 3,000–20,000

On Monday 19 October 2026, an SRL that has not counted what it holds cannot close the year merely because the journal is open. The mandatory-accounting guide says the books are double-entry from day one, who may keep them, and that an SRL files its annual financial statements by 31 May. Inventory appears there in one sentence, as a fine band. It does not say who counts when you are alone, how a plus is set off against a minus, or in how many working days the minute reaches the director.

The five searches of this URL: (1) the annual inventory of an SRL's assets in 2026, including when there is no stock, (2) the inventory commission when you have no employees, (3) pluses and minuses, set-off, and replacement value, (4) the inventory register, code 14-1-2, (5) the fine of RON 3,000–20,000 and the two deadlines of 7 working days. This is not the calendar of a return due on the 25th, and it is not a guide to whether an expense is deductible. The figures below were checked on 19 October 2026 against the consolidated Accounting Law no. 82/1991 on legislatie.just.ro, the norms in Order of the Minister of Public Finance no. 2,861/2009, and Order no. 2,634/2015.

Art. 7(1) of Law no. 82/1991, in the form given by GEO no. 13/2021, requires the persons in art. 1 to inventory assets, liabilities, and equity at the start of activity, at least once during the financial year, on a merger, division, transformation, or liquidation, and in the other cases the law provides. A services SRL with no warehouse still has something to inventory: the bank balance, cash, receivables, payables, and share capital. «We have no stock» is not an exception to art. 7. The exceptions to the annual rule, paragraph (2), concern special goods held by public institutions, not a new SRL.

Point 4(1) of the norms approved by Order no. 2,861/2009 (Official Gazette no. 704 of 20 October 2009) says the annual inventory is made, as a rule, when the financial year closes. It does not say «mandatory on 31 December» for goods and fixed assets. Paragraph (2) allows an earlier count if the results go into that year's annual statements. A warehouse counted in November is updated in the inventory register with entries and exits through 31 December (point 4(4) and point 44(2)). On 19 October 2026, the order's page on legislatie.just.ro still shows the 2009 deadlines. I did not find a 2024–2026 order that moves them.

Two dates are fixed when the financial year is the calendar year. Cash in the register is inventoried on the last working day of the year, after every receipt and payment is recorded, comparing the cash book with the cash breakdown and with the accounts (point 29(3)). 31 December 2026 is a Thursday and not a legal holiday, so the cash count is Thursday 31 December 2026. Money at the bank is agreed to the statement of 31 December or of the last banking day (point 29(2)). Liquidation is a separate case from the annual count: the same art. 7 requires it. Voluntary suspension at the Trade Register is not liquidation. The difference between a pause and striking off is in the suspension and dissolution guide. This article does not repeat the ANAF derogation.

Point 6(1) of the same norms requires the inventory to be carried out by commissions appointed by a written decision of the director. The decision must state the membership (the names of the chair and of the members), how the count is done, the method, the storeroom, the start date, and the end date. Paragraph (2): where the entity has few employees, one person may carry out the inventory, and responsibility for correctness stays with the director. Paragraph (7) is the rule for a company with no staff: if there is no employee who can do the work, the directors do it. You do not hire someone in December merely to have three signatures on the list.

Paragraph (5) keeps off the commission the keepers of the storerooms being counted, the accountants who keep that storeroom's records, and the internal or statutory auditors. The accountant may attend, if the internal procedure says so, without being a member. Read together, paragraphs (5) and (7) do not force you to bring in a stranger when you are the only person in the company: the director counts. If the director also holds the goods, the director still signs the keeper's declaration in point 8 — other storage places, third-party goods, pluses or shortages already known, goods not yet received, cash from sales, and the date of the last entry or exit document. The declaration is dated. A message to the accountant does not replace it.

The inventory decision is not the resolution by which the sole associate approves the statements or distributes profit. The sole-associate guide explains when a contract with your own company, and the decision under art. 196^1, must be in writing. Here the paper is issued by the director, under art. 2 of Order no. 2,861/2009 and points 5–6 of the norms, even if you are also the sole associate. The CECCAR member who keeps the books under a contract does not sit as a member of the commission if that person keeps the storeroom's records. You may ask them to agree the lists to the accounts after the count. The accounting contract does not stand in for the inventory decision.

The result is the physical lists compared with the warehouse cards and with the accounts, after you correct the errors found in that comparison (point 35). A plus is valued under the applicable accounting rules (point 40(1) and point 46(3)): acquisition cost, using the market price on the date it is found or the cost of similar goods. An imputable shortage is charged to the person at fault at replacement value (point 40(2)). The norm defines that as the market purchase price of a good with similar features and wear, plus non-recoverable taxes, including VAT, plus transport, supply, and other costs for the good to enter the storeroom. In the accounts, the shortage is recorded at book value. The two figures are not the same number.

Example as of 19 October 2026, for a good whose VAT is not recoverable. Market price RON 100, standard rate 21% (Fiscal Code, art. 291(1), the form in Law no. 141/2025), so RON 21, plus RON 9 transport: replacement value is RON 130. Law no. 199/2026, in force from 18 October, added an 11% rate only for bee feed and did not move the 21%. If you are a VAT payer and the tax would be deductible on a real purchase, do not add the RON 21 automatically: the norm asks for non-recoverable taxes. Who is a VAT payer is in the VAT guide. A good with no document is not settled from memory. The supporting document is in the invoice guide.

Setting shortages off against pluses is an exception, not the habit (point 40(3)). You need, at the same time, a risk of confusion between sorts of the same good (appearance, colour, size, packaging) and differences from the same custody period and the same storeroom. There is no set-off if the shortage comes from theft or from damage caused by the keeper's fault (paragraph (4)). The list of sorts that can be confused is approved annually by the director, before you use it on the result (paragraph (5)). Set-off is for equal quantities. Allowances for loss and perishability apply only after the shortage is found, only up to that shortage, and they are maximum limits, not a percentage you book by default (point 41). The minus left after set-off and after the allowances is recovered from the persons at fault.

Point 44(1) of the inventory norms makes the inventory register (code 14-1-2) a mandatory accounting document. It records the inventory results, grouped by nature, on the balance-sheet headings. The lists, the minutes, and the analytical statements support it. Paragraph (3): the register is filled in when the balances of all balance-sheet accounts are final, including profit tax and impairment adjustments. A file saved in November, before tax and adjustments, is not the year's register. Partial inventories during the year follow the norms, but the inventory register is completed at the annual inventory (point 34(3)).

The models named in point 34(1) are those in annex no. 3 to Order no. 3,512/2008. That order was repealed. Art. 9 of Order no. 2,634/2015 (Official Gazette no. 910 of 9 December 2015) repeals it from 1 January 2016. The code stayed the same: in the norms of Order no. 2,634/2015, the inventory register is still code 14-1-2, next to the journal 14-1-1 and the general ledger 14-1-3, and the inventory list is code 14-3-12. On 19 October 2026, the order's PDF on anaf.ro and the annex published by the Ministry of Finance still show these codes. Use the forms in the order that is in force, not a printout left behind in the 2009 text.

The register does not replace the bank statement. Point 29(2) requires the statement balances to be agreed to the accounts. Without a payment account there is nothing to agree, and the missing account has its own fine and its own inactivity risk, explained in the bank-account guide. The balance sheet is drawn up from the inventory register and the trial balance at the close of the year (point 45(2)). The balance-sheet headings must match the accounts as agreed to the inventory. Filing that balance sheet with ANAF stays in the accounting guide, with the deadline of Monday 31 May 2027 for the 2026 financial year. The chain in this article stops at the register.

Art. 41 point 2(d) of Law no. 82/1991 treats as a contravention the failure to follow the Ministry of Finance rules on carrying out the inventory. Art. 42(1)(d), in the form of GEO no. 115/2023 (Official Gazette no. 1139 of 15 December 2023), fines that act from RON 3,000 to RON 20,000. The guilty persons bear the fine (paragraph (6)). It is not calculated per line on the list. It is found by staff with tax-inspection and financial-control duties (paragraph (4)). On the same portal, the note under art. 42 repeats art. LVIII of Law no. 296/2023: fines under the Accounting Law do not get the facility of paying half the minimum within 15 days. RON 3,000 does not become RON 1,500. The band of RON 2,000–20,000 for unrecorded operations is a different letter, (a), and is developed in the accounting guide. Do not add them into one ceiling.

Point 43: the proposals in the minute are presented to the director within 7 working days of the end of the operations. Point 45(1): the results are recorded in the operational records within at most 7 working days of approval. The order does not print a calendar. The count below drops Saturdays, Sundays, and the days that are not worked under art. 139(1) of the Labour Code (Law no. 53/2003), including 6 and 7 January, added by Law no. 52/2023. Bridge days for budgetary staff, art. 139(4), are not subtracted for a private SRL.

Example. The operations end on Thursday 17 December 2026. The 7 working days for presenting the minute are: Friday 18, Monday 21, Tuesday 22, Wednesday 23, Thursday 24, then Friday 25 December is the first day of Christmas, Saturday 26 and Sunday 27 are not counted, Monday 28 and Tuesday 29. The deadline falls on Tuesday 29 December 2026. If the director approves the same day, the 7 working days for recording in the operational records start on Wednesday 30 (day 1), Thursday 31 (day 2), skip Friday 1 January 2027 and the weekend, continue on Monday 4 and Tuesday 5 (days 3 and 4), skip Wednesday 6 and Thursday 7 January, then Friday 8 (day 5), Monday 11 (day 6), and Tuesday 12 January 2027 (day 7). Cash in the drawer on Thursday 31 December is also compared with the cash-register ceiling. That ceiling, and the 2 working days for paying in the surplus, are in the cash-ceiling guide, not in this 7-day deadline.

Walk through the steps before the 2026 financial year closes. The working-day deadlines below use the calendar checked on 19 October 2026: 31 December 2026 is a Thursday, 25 December is a Friday, and 6 and 7 January 2027 are a Wednesday and a Thursday.

Tavoris prepares the SRL incorporation dossier for the Trade Register, from the identity document and the registered-office contract. It does not issue the inventory decision, count the stock, fill in inventory register code 14-1-2, approve a set-off of pluses against minuses, or file the financial statements.

After the certificate, double-entry and the 31 May deadline are in the accounting guide. The account you agree to the 31 December balance is in the bank-account guide. This article covers only the inventory duty, the commission, the differences, the register, and the fine of RON 3,000–20,000.

Informational guide as of 19 October 2026. Sources: Accounting Law no. 82/1991, art. 7, art. 41 point 2(d), and art. 42(1)(d), (4), and (6), in the form of GEO no. 115/2023; the note on Law no. 296/2023, art. LVIII, under art. 42 on legislatie.just.ro; Order no. 2,861/2009, points 2, 4, 6, 8, 19, 29, 34, 35, 40, 41, 43, 44, 45, and 46; Order no. 2,634/2015, art. 9 and codes 14-1-2 and 14-3-12; Fiscal Code, art. 291(1), standard rate 21%, unchanged by Law no. 199/2026; Labour Code, art. 139, for the days that are not counted as working days. This is not accounting or legal advice. Check legislatie.just.ro, anaf.ro, and the Ministry of Finance before you close the year.