RO e-TVA for SRLs in 2026: P300 vs D300, abolished notice, and the 30 September deadline

Tavoris’s blog covers VAT registration (RON 395,000 threshold, 21% rate, cash VAT, D300/D394), e-Factura, SAF-T (D406), and e-Transport. The pre-filled RO e-TVA return is mentioned only in passing, but searches for “e-TVA 2026”, “P300 vs D300”, “pre-filled VAT return”, “e-TVA compliance notice”, and “cash VAT 30 September 2026” dominate September 2026 — with 27 days left until the cash-VAT pre-fill suspension expires.

Five dominant topics: (1) what P300 is and which data ANAF uses, (2) why D300 remains the only legally binding return, (3) the disappearance of the compliance notice and fines (GEO 89/2025 and GEO 13/2026), (4) the 30 September 2026 cash-VAT deadline, (5) how to reconcile monthly without copying P300. Data updated as of 3 September 2026.

RO e-TVA is the system through which ANAF places a pre-filled VAT return — form P300 — in the Virtual Private Space (SPV) for persons registered for VAT (art. 316 of the Fiscal Code). The legal basis is GEO 70/2024 (Official Gazette no. 582/21 June 2024); the P300 model is approved by ANAF Order 3,775/2024. P300 is not a tax assessment title.

ANAF aggregates data from RO e-Factura, SAF-T (D406), RO e-Transport, electronic cash registers, and, where available, D394. Cross-border operations (intra-EU acquisitions/supplies, import/export, reverse charge) are not covered by mandatory domestic e-Factura: on those rows P300 relies on D390, customs declarations, and SAF-T and may stay incomplete — a frequent source of false “differences”.

Who receives it: SRLs, PFAs, IIs, and non-residents registered for VAT. A non-VAT payer (under the RON 395,000 threshold, without voluntary registration) does not receive P300 — but remains obligated to use e-Factura. A 1% micro-enterprise that is also a VAT payer receives P300 like any other taxable person.

D300 is the VAT return you prepare from your own records and file in SPV. General deadline: the 25th inclusive of the month after the tax period (monthly or quarterly, art. 322 Fiscal Code). The form in force from the first 2026 tax period is ANAF Order 174/2026 (Official Gazette no. 105/9 February 2026), with separate rows for 21% (standard), 11% (single reduced rate from 1 August 2025, Law 141/2025), and transitional 9% for certain dwellings. Exception: a return due on 25 December is filed by 21 December (art. 155(2) Tax Procedure Code); in 2026, 21 December is a Monday (a working day), so it does not shift.

P300 is sent electronically, for the same period, by the 5th inclusive of the month after the legal D300 deadline. Example as of 3 September 2026: for August operations, the monthly D300 is due Friday 25 September; the matching P300 appears in SPV by Monday 5 October. Do not wait for P300 before filing D300 — the calendar is the reverse: your return first, then the comparison.

P300 is not an administrative tax act and does not reverse the burden of proof. At an audit, supporting documents matter (art. 73 of Law 207/2015), not the pre-filled return. If P300 is wrong (duplicated e-Factura invoice, 21% instead of 11%), you fix the source — credit note/e-Factura, D406 correction — you do not “edit” P300; realignment shows in the next period’s pre-filled return.

The original GEO 70/2024 provided a RO e-TVA compliance notice when D300 and P300 had “significant differences”: cumulatively at least 20% and at least RON 5,000 on the compared rows. A reply was mandatory within 20 days, with fines of RON 1,000–10,000 by taxpayer category. 2024–2025 guides that still describe this flow are outdated.

From 1 January 2026, GEO 89/2025 removed the reply duty and the non-compliance fines. From 9 March 2026, GEO 13/2026 (Official Gazette no. 181/9 March 2026) repealed from GEO 70/2024 art. 5 (the notice and significant differences), art. 8 (automatic inspection selection on this mechanism), and art. 16. ANAF no longer issues RO e-TVA compliance notices. GEO 70/2024 remains in force for generating P300.

Abolishing the notice does not erase fiscal risk. Persistent differences remain a risk-analysis indicator (art. 121 Tax Procedure Code). The separate compliance notice that warns of a possible tax inspection — a different instrument under the Procedure Code — still exists. Monthly D300 ↔ P300 ↔ e-Factura ↔ D406 reconciliation remains good practice, not an SPV “reply” obligation.

For taxpayers using the cash VAT system (RON 5,000,000 turnover ceiling in 2026, GEO 8/2026 — details in the VAT guide), application of the pre-filled RO e-TVA return is suspended until 30 September 2026 inclusive. The reason: chargeability on collection/payment cannot be read from e-Factura alone; ANAF postponed pre-filling until the IT tools include that information.

As of 3 September 2026, 27 calendar days remain. There is, at this date, no published extension of the suspension and no automatic go-live from 1 October 2026. After 30 September, the regime (P300 for cash VAT as well, or a further postponement) depends on a later enactment — watch anaf.ro. Until then, if you are on cash VAT: file D300 as before; do not wait for a P300 that is not made available for this regime.

If you are not on cash VAT, P300 already runs. Do not confuse this date with 25 September 2026 (CAEN Rev. 3 at ONRC) or with 30 September 2026 for Form D318 (refund of VAT paid in 2025 in other EU states) and for the transitional 9% rate on certain dwellings (Law 161/2026, supply by 30 September 2026 inclusive). Those are different deadlines; only the e-TVA one concerns pre-filling for cash VAT.

After you file D300, open P300 in SPV (by the 5th of the following month). Compare output and input VAT rows. Typical differences: inbound invoices in e-Factura not booked; credit notes in one month and the original in another; 21% instead of 11% (or 9% on eligible dwellings); advances; exempt vs taxable supplies; incomplete cross-border rows in P300.

Do not “correct” D300 to match P300 if your records are right. Fix the wrong source (e-Factura, journals, D406) and, if D300 is wrong, file a correct return or regularise in the current period (art. 105 Tax Procedure Code). The accounting contract should say who performs D300 ↔ P300 reconciliation; fiscal liability stays with the SRL.

Mistakes to avoid in September 2026: treating 2025 articles about the 20-day fine as current law; delaying D300 while waiting for P300; ignoring P300 because “the notice disappeared”; assuming P300 already covers cash VAT.

Follow these steps according to your VAT regime:

Tavoris prepares the SRL incorporation dossier. It does not generate D300 or P300, reconcile VAT returns, or file declarations in SPV.

After the certificate, VAT registration, e-Factura, and returns remain yours (and your accountant’s). Tavoris guides on VAT, e-Factura, and SAF-T cover the related duties; this article covers only the pre-filled return.

Informational guide as of 3 September 2026. GEO 70/2024, GEO 89/2025, GEO 13/2026, ANAF Order 3,775/2024, ANAF Order 174/2026, and ANAF announcements on cash VAT after 30 September 2026 may change. Verify anaf.ro. Not tax or accounting advice.