SRL cash register in 2026: AMEF from day one, NUI/C801, RON 10,000–20,000 fines and QR until 1 November

Tavoris’s blog already covers the duty to accept cards, e-Factura B2B/B2C within 5 working days, the payment account and ANAF inactivity and the pre-filled P300 return. Searches for “mandatory SRL cash register 2026”, “AMEF exceptions”, “NUI C801”, “RON 10,000–20,000 fines” and “QR on the fiscal receipt 1 November 2026” are a different topic: the electronic fiscal marking device (AMEF) under GEO no. 28/1999, republished. A POS terminal does not replace an AMEF; e-Factura XML does not replace the fiscal receipt.

Five dominant topics: (1) who must use an AMEF from day one, at every location, (2) the closed list in art. 2 and card-only vending machines (Law no. 317/2024), (3) the NUI via C801 in SPV, fiscalisation and connection within 2 working days, (4) RON 10,000–20,000 fines plus activity suspension, and RON 8,000–10,000 for failing to connect, (5) the QR code on the receipt and the sanction freeze until 1 November 2026 (GEO no. 68/2025). Data updated as of 10 September 2026. Until 1 November 2026 (a Sunday) there are 52 calendar days left; the first working day after QR sanctions resume is Monday 2 November 2026.

Art. 1(1) of GEO no. 28/1999, republished, requires economic operators who collect, in whole or in part, in cash, by credit/debit card or with cash substitutes (vouchers, tickets) the consideration for goods sold at retail or services rendered directly to the public to use electronic fiscal marking devices. Legal form is irrelevant: an SRL, a PFA and a sole trader in the same collection situation share the same duty. There is no turnover threshold and no grace period after the ONRC certificate.

Art. 6 states that the duty arises on the date commercial activity starts at each location. If you open a café on Monday 14 September 2026, the AMEF must be fiscalised and used that day — not “once customers pick up” and not after you pass the RON 395,000 VAT-registration ceiling, which is a different calendar. A B2B consulting SRL that only collects by bank transfer, with no over-the-counter sales to individuals, falls outside art. 1(1) — but a single cash or card collection on the premises from a natural person can change the qualification; “occasional” is not defined in the ordinance.

The fiscal receipt remains the document the AMEF issues (art. 1(2)). Law no. 317/2024 (Official Gazette no. 1308/23 December 2024, in force from 26 December 2024) added art. 1(2^1): for card collections you are not required to print and hand over the receipt; you may print it at the customer’s request, and the bank statement serves as proof of purchase (GO no. 21/1992). That does not exempt you from the AMEF: the transaction must still be recorded on the device. For cash, the printed receipt remains mandatory. If you refuse to issue and hand over a cash receipt, the customer is entitled to the goods or service without payment (art. 1(10^1)), and the device operator risks a RON 1,000–2,000 fine (art. 11(9)). The practical premise is an active SPV after the certificate: without SPV you cannot obtain an NUI.

You are not exempt because you are on the 1% micro regime, a sole associate, or a “small firm”. Exceptions are only those in art. 2 of GEO no. 28/1999, a closed list. For an SRL the frequent ones are: liberal professions that do not involve a company — so a law or accounting SRL cannot hide here; installation, repair and maintenance at the customer’s home; construction, repair and maintenance of dwellings; mail-order trade, except home deliveries by shops; utilities; tour packages sold by travel agencies; electric-vehicle charging collected exclusively by card or e-wallet (GEO no. 125/2024, Official Gazette no. 1073/25 October 2024). The remaining letters (newspapers, ticketed transport, insurance, cash-and-carry, etc.) stay in the consolidated text on legislatie.just.ro — check them before you claim an exemption.

For the activities in art. 2(f), (h), (i)–(l), if you still collect cash without an AMEF, art. 2^1 requires receipts. That is a substitute duty, not a loophole. An IT-repair SRL that fixes laptops in its own workshop (the customer comes to you) is not “at the customer’s home” — an AMEF is required. A construction SRL on the client’s dwelling site may fall under letter (l), with a receipt; check with your accountant before treating the exception as the default rule.

Law no. 317/2024 added art. 3(2^3): for unattended vending equipment that operates exclusively on card payments, an AMEF is not mandatory. If the machine also accepts banknotes or coins, the AMEF remains mandatory; the RON 8,000–10,000 fine plus suspension for vending without an AMEF (art. 10(cc) and art. 11(1)(f)) has applied since 1 October 2024 (GEO no. 115/2023). Do not confuse this device exception with the POS exception: the card-payments guide covers GEO no. 193/2002 (accepting modern means of payment), not GEO no. 28/1999. You can have a POS without an AMEF only if you are outside art. 1(1); you can have an AMEF without a POS only if every receipt and payment is 100% through bank accounts — a rare combination in a shop.

Before the first sale you buy an AMEF with an electronic journal (art. 3(2)) from an authorised distributor or accredited unit — the list is on mfinante.gov.ro. The distributor must install a new device or replace the fiscal memory / electronic journal within 72 hours of your request (art. 5(5)). Fiscalisation (activating the fiscal memory, the header with CUI and the installation address, the first Z-report) is done by an authorised service technician, not by you and not by Tavoris.

The unique identification number (NUI) is requested exclusively in SPV, on form C801, since 1 March 2022. You attach a ZIP archive with the invoice and proof of payment, the sealing minutes, the warranty certificate, and the legal representative’s ID (copies marked “conforming with the original”). ANAF’s NUI-certificate guide provides for issuance within 2 days of the request; in practice automatic generation can be same-day if the serial number is already in ANAF’s records. Without an NUI the technician will not fiscalise. After installation, the “installation declaration” is drawn up in four copies (user + technician); ANAF’s guide requires one copy to reach the competent tax office the next day. The distributor or service unit files F4102 (OPANAF no. 4,156/2017) within 2 working days of drawing up or receiving the installation declaration.

Connecting to ANAF’s national surveillance IT system (OPANAF no. 435/2021, Official Gazette no. 319/30 March 2021) is your duty, art. 3^1(4). For AMEFs purchased after 1 December 2021, the deadline is 2 working days from the installation date — Saturdays, Sundays and public holidays do not count. The technician switches the device from profile 0 (offline) to profile 1 (online) and sends a verification Z-report. If the location has no electronic-communications network, you file F4110 (own-responsibility declaration, annex 2 to OPANAF 435/2021); you do not skip the connection. After connection, ANAF may send monthly SPV messages about file malfunctions (art. 2(2) of the order). AMEF data also feed the P300 under RO e-TVA: a shop that issues no receipts will show gaps against e-Factura and SAF-T.

Operating without an AMEF (art. 10(e)) is sanctioned, after Law no. 296/2023 (Official Gazette no. 977/27 October 2023, art. 11 in force from 11 November 2023), with a fine of RON 10,000 to 20,000, plus suspension of activity at the sales unit until you equip the unit and produce proof of paying the fine or half of it, plus confiscation of sums without supporting documents (art. 11(1)(d)). A complaint against the official report does not stay enforcement (art. 12(4)). A warning as the main sanction is not available for this offence (art. 12(5)). The half-minimum within 15 days under GO no. 2/2001 is not available for GEO no. 28/1999 (art. LVIII of Law no. 296/2023); only the 48-hour facility in art. 12(3) remains for certain letters — read the official report.

Failing to connect to the ANAF server (art. 10(ff) with art. 3^1(4)) costs RON 8,000–10,000 (art. 11(1)(l)). Not issuing a receipt, issuing one below the sale price, or failing to use the special register when the device is broken (art. 10(c)) is fined in steps, plus confiscation of the unjustified sum: RON 2,000 (sum ≤ RON 300 and ≤ 3% of the day’s sales), RON 5,000 (≤ RON 300 but > 3%), RON 6,000 (RON 300–1,000 and ≤ 3%), RON 12,000 (RON 300–1,000 and > 3%), RON 15,000 (> RON 1,000 and ≤ 3%), RON 30,000 (> RON 1,000 and > 3%) — art. 11(1)(e). A repeat within 12 months doubles the fine; a second repeat within 12 months triples it and suspends activity for 15 days (art. 11(5)–(6)).

Hospitality (CAEN 5610 restaurants, 5630 bars): the tip is shown on the receipt, on a bill with 0–15% boxes or an absolute amount, is distributed in full to employees and is taxed as income from other sources, without CASS/CAS (art. 2^3, Law no. 376/2022). Breach: RON 2,000–4,000 (art. 10(jj) and art. 11(1)(a)). Home delivery does not require showing the tip unless you opt in. Codes 5610/5630 must match the object of activity — see the CAEN Rev. 3 update by 25 September 2026 if the firm was incorporated before 2025. The electronic journal and Z-reports are kept for 5 years from 1 July of the year after the financial year (art. 4(5) and (8)); failing to archive: RON 4,000–6,000 (art. 10(o) and art. 11(1)(b)).

GEO no. 69/2024 (Official Gazette no. 582/21 June 2024) added art. 4(2^1): the date and time of issue, the receipt identification number and the AMEF’s fiscal serial number are printed on the receipt and as a QR code. Art. 4(2) also requires the beneficiary’s tax ID, at their request, plus the receipt identification number. Issuing a receipt without these data is an offence (art. 10(f)), fined RON 2,000–4,000 (art. 11(1)(h)).

Application of art. 10(f) and art. 11(1)(h) to the offence of issuing a receipt without the beneficiary’s tax ID, without the receipt identification number and without the art. 4(2^1) data as a QR code is suspended until 1 November 2026, by art. IV of GEO no. 68/2025 (Official Gazette no. 1132/8 December 2025). The previous freeze, under GEO no. 125/2024, had run until 1 September 2025. The repeated reason: ICI Bucharest must test models and issue the technical-approval supplement, and the Ministry of Finance must update the HG no. 479/2003 norms. As of 10 September 2026, 1 November 2026 is a Sunday; 52 calendar days remain. Do not treat the freeze as a repeal of the underlying duty: art. 4(2^1) stays in force; only the specific QR/tax-ID/receipt-number offence is paused.

Worked calendar for a shop opening Monday 14 September 2026: C801 + NUI in SPV on 14–15 September (2 days from the request); technician fiscalisation; installation declaration on Tuesday 15 September (the next day); distributor F4102 by Thursday 17 September (2 working days: Wednesday 16 + Thursday 17); profile-1 connection also within 2 working days of installation. First Z-report on opening day. If you are VAT-registered, the D300 for September is due 25 October 2026, which falls on a Sunday — check ANAF’s calendar for a move to Monday 26 October. Receipts still carry the applicable VAT rate — 21% standard from 1 August 2025. B2C e-Factura does not disappear: if you issue an invoice to a natural person, the XML remains due in 5 working days, independently of the receipt.

Work through the steps before the first collection from the public. The figures are those in force on 10 September 2026.

Tavoris prepares the ONRC incorporation dossier from your identity document and registered-office contract. It does not sell AMEFs, file C801, fiscalise, submit F4102 or connect a device to ANAF’s system.

After the certificate, SPV, the NUI and the AMEF remain yours, with the authorised technician and your accountant. The post-incorporation guide covers SPV; the POS guide covers accepting cards — this article covers only the fiscal device.

Informational guide as of 10 September 2026. GEO no. 28/1999, HG no. 479/2003, Law no. 296/2023, Law no. 317/2024, Law no. 376/2022, GEO no. 69/2024, GEO no. 125/2024, GEO no. 68/2025, OPANAF no. 435/2021 and OPANAF no. 4,156/2017 may be updated. Check anaf.ro, legislatie.just.ro and the authorised-distributor list on mfinante.gov.ro. This is not tax, accounting or legal advice.