Form 112 and the first SRL employee in 2026: REGES the day before, 25% CAS, RON 4,325 and the 25 September deadline

Tavoris’s blog already covers the first 30 days after the certificate (SPV, e-Factura, REGES in one section), how you pay the director (mandate vs employment contract vs dividends) and the employee test for micro 1%. Searches for “Form 112 SRL 2026”, “first SRL employee”, “CAS CASS CAM 2026”, “minimum wage RON 4,325 and RON 200” and “REGES Online day-before deadline” are a different topic: monthly payroll reporting and the Labour Inspectorate register. A paid mandate is not sent to REGES; an employment contract is. Form 112 is not Form 100 (micro-tax, withheld dividends) and not Form 300 (VAT).

Five dominant topics: (1) when the first employee appears and what you must already have (SPV, a payment account, the micro 90-day clock), (2) REGES Online — no later than the day before work starts, including a Sunday, (3) the 2026 rates: CAS 25%, CASS 10%, CAM 2.25%, income tax 10%, (4) the RON 4,325 minimum wage from 1 July 2026 and the RON 200 facility, (5) Form 112 — Friday 25 September 2026 for August, monthly vs quarterly, fines. Data updated as of 14 September 2026. Until Friday 25 September 2026 there are 11 calendar days left; 25 September is also the CAEN Rev. 3 ONRC deadline and the Form 300 due date — three calendars, not one.

The first employee, for the Labour Inspectorate, is the person with an individual employment contract (CIM) concluded in writing before work starts (art. 16 of Law no. 53/2003 — the Labour Code). The duty to file them in REGES Online and on Form 112 arises in the month you pay salary or assimilated income. A sole-associate SRL with no CIM and no paid mandate does not file Form 112 and does not open REGES — but then it also fails the micro-enterprise employee test.

For micro 1%, GEO no. 8/2026 gives 90 calendar days inclusive from the ONRC registration date (companies incorporated from 25 February 2026) to have a full-time CIM or a director’s mandate paid at least at the national minimum wage. Do not confuse those 90 calendar days with the 60 working days for the payment account: without an account you cannot pay net wages. Example: certificate on Monday 17 August 2026 → day 90 is Saturday 14 November 2026. If you want micro status, the contract must be running before that date, not “when clients show up”.

A director on a paid mandate is “assimilated to an employee” for contributions and Form 112, not for REGES and not for the Labour Code. A PFA invoicing the SRL is not an employee. A civil collaboration without a CIM, if the work is performed under subordination, is a recharacterisation and undeclared-work risk. Before you sign, decide with your accountant: CIM (REGES + Form 112 + the RON 200 facility, if you are at the minimum) or mandate (Form 112 only, no RON 200) — the detailed comparison is in the director remuneration guide.

REGES-ONLINE replaced REVISAL. The legal basis is Government Decision no. 295/2025 (Official Gazette no. 319/31 March 2025). For a new CIM, art. 5(1)(a) requires the data in art. 4(2)(a)–(k) — identity, COR occupation, contract type and duration, workplace, working time, gross salary — to be transmitted no later than the day before activity starts. The official FAQ on reges.inspectiamuncii.ro states: whether or not that previous day is a working day. If the first working day is Monday 21 September 2026, transmission must be finished on Sunday 20 September 2026, not on Monday morning.

Amendments do not share that deadline. Gross basic salary, allowances, bonuses and other additions (art. 4(2)(j)) are transmitted within 20 working days of the change (art. 5(4)); the 1 July 2026 rise from RON 4,050 to RON 4,325 fell on that calendar. Role, contract type, duration, workplace and working-time pattern (letters (e)–(i)) are transmitted no later than the day before the change takes effect (art. 5(3)). Suspension on a medical certificate: 3 working days from the date the employer registers the certificate. Termination: no later than the termination date. Completing the register with wrong or incomplete data: a RON 3,000–6,000 fine (art. 9(4) of GD no. 295/2025). Failure to transmit the contract on time where work was performed and salary declared: RON 3,000–5,000 per person; other late amendment filings: RON 5,000–8,000.

The GD no. 295/2025 fines do not replace the Labour Code. Taking someone on without a CIM: RON 40,000 per person, aggregated cap RON 1,000,000 (art. 260(1)(e), as amended by Law no. 239/2025, applicable from 18 December 2025). A CIM concluded but not sent to the register by the day before: RON 20,000 per person, cap RON 200,000 (letter (e¹)). The Labour Inspectorate records the offence; ANAF does not “fix” REGES through Form 112. The platform is reges.inspectiamuncii.ro; you need an employer account after the CUI, not the ONRC dossier. The post-incorporation guide mentions REGES in the checklist; this article is the day-count, not the week-count.

For salary and assimilated income (including a paid mandate), the rates in Law no. 227/2015 as at 14 September 2026 remain: CAS 25% (art. 138) and CASS 10% (art. 156), withheld from the employee’s gross; 10% income tax (art. 64) on the taxable base, not on gross; CAM 2.25% (art. 220^3–220^4), borne by the company. There is no old-style “employer CAS” of 8% or 10.5%. Form 112 declares all of them, plus the nominal list of insured persons, to ANAF, CNPP, CNAS and ANOFM in one XML file.

Worked example: a CIM at the minimum wage, July–December 2026, full time, main job, no dependents, with the RON 200 facility (next section). CAS/CASS/CAM base = 4,325 − 200 = RON 4,125. CAS 25% = RON 1,031.25. CASS 10% = RON 412.50. Basic personal deduction (art. 77) = 20% × 4,325 = RON 865. Taxable base = 4,325 − 200 − 1,031.25 − 412.50 − 865 = RON 1,816.25. Income tax 10% ≈ RON 182. Net ≈ RON 2,700 (4,325 − 1,031.25 − 412.50 − 182). CAM 2.25% × 4,125 ≈ RON 93. Employer cost ≈ RON 4,418. Payroll software rounds to bani; do not copy these figures onto a payment order without that month’s timesheet.

On a mandate paid at RON 4,325 you do not deduct the RON 200. CAS ≈ RON 1,081, CASS ≈ RON 433, CAM ≈ RON 97, and net pay comes out below a CIM at the same gross. CASS on dividends is a different mechanism: 10% on the 6/12/24 minimum-wage bands anchored to RON 4,050 (1 January 2026), declared by the associate on Form 212 by 25 May 2027, not on Form 112 — see the dividends guide. For a part-time CIM, the minimum CAS base is usually the full monthly minimum wage, with exceptions (another contract that already covers the base); do not treat “two hours a day at RON 1,000 gross” as a contribution saving without checking art. 146.

Government Decision no. 146/2026 (Official Gazette no. 196/13 March 2026) sets, from 1 July 2026, the national gross basic minimum wage at RON 4,325 a month for a normal programme, on average 166.667 hours/month, i.e. RON 25.949/hour, excluding bonuses. GD no. 1,506/2024 (RON 4,050) is repealed from the same date. Below that gross, on a full-time CIM, the contract is unlawful; the Labour Inspectorate can fine you and order back pay. An employee with more than 24 months’ seniority with the same employer cannot stay exactly at the minimum — the practical step is RON 4,326, so you do not breach the seniority rule in the Labour Code.

The RON 200/month facility (GEO no. 89/2025, art. III) is not an automatic relief for a “small firm”. It applies only to CIM income, full time, at the main job, in July–December 2026, if all of the following hold: (a) the contractual gross basic salary, excluding bonuses, is exactly the legal minimum for that month (RON 4,325); (b) gross salary income from the same employer, excluding meal tickets, holiday vouchers and the food allowance, does not exceed RON 4,600 inclusive. A RON 300 bonus breaks the ceiling. In January–June 2026 the amount was RON 300 and the gross-income ceiling RON 4,300, at the RON 4,050 minimum. A mandate does not get the facility.

The RON 200 is left out of the monthly CAS, CASS, income-tax and CAM bases. That is why the employer cost at the RON 4,325 minimum (~RON 4,418) is lower than 4,325 × 1.0225. If you raise basic pay by one leu above RON 4,325, you lose the RON 200 and fall back onto the full base — net pay sometimes rises by less than you expect. The Form 112 that applies to July 2026 income (joint order no. 605/95/928/2314/2026, Official Gazette no. 463 bis/2 June 2026) has dedicated rows for the RON 200 (insured-person annex, fields 8.2 / 9.x). ANAF’s helper software (version A) was updated on 24 August 2026; do not file the first-half version for July–August.

Form 112 is filed electronically, with a qualified signature, in SPV — the premise is activating SPV after the certificate. General deadline: the 25th inclusive of the month following the month for which the income is due (art. 147(1) of the Fiscal Code). Payment of CAS, CASS, income tax and CAM shares that deadline. For August 2026 wages, the deadline is Friday 25 September 2026 — a working day, so it does not move. As of 14 September 2026 there are 11 calendar days left. For September, 25 October 2026 is a Sunday: the next working day is Monday 26 October 2026. The 21 December exception (art. 155(2) of Law no. 207/2015) brings forward returns otherwise due on 25 December; in 2026, 21 December is a Monday.

Quarterly filing (art. 147(4)–(5), read with art. 80(2)) is not one sheet per quarter: you complete a Form 112 for each month and send them together by the 25th of the month after the quarter. Who may use it: micro-enterprises with an average of up to 3 employees in the previous year; profit-tax payers with turnover up to EUR 100,000 and up to 3 employees; a new SRL that declared the same estimate at fiscal registration. You may opt for monthly filing by an option declaration by 31 January. If during the quarter someone takes medical leave or ceases to be insured, that month’s Form 112 is due by the 25th of the month after the event. Q3 2026, with no special event: 25 October → Monday 26 October 2026. Many new employers stay monthly precisely so they do not miss a medical-leave month.

Late Form 112 is a contravention (art. 336(1)(b) of the Fiscal Procedure Code): for an SRL that is not a medium or large taxpayer, the fine is RON 500–1,000 (paragraph (2)(d)); medium and large: RON 1,000–5,000. Half of the minimum may be paid within 48 hours of the report being served (art. 338(3)) — RON 250 or RON 500. On top of the fine: interest at 0.02%/day (art. 174(5)) and a late-payment penalty of 0.01%/day. If the amounts surface only at inspection, the undeclared-tax penalty is 0.08%/day (art. 181), capped at the principal, reducible by 75% if you pay by the due date in the assessment. Corrections are made with a Form 112 amendment, not an email to ANAF. Without Form 112, medical leave, contribution history and the insured-person record stay empty — the employee sees that at CNPP and CNAS.

Work through the steps before the first working day. The figures are those in force on 14 September 2026.

Tavoris prepares the SRL incorporation dossier for ONRC, from the identity document and the registered-office contract. It does not draft employment contracts, transmit REGES Online data, run payroll or file Form 112.

After the certificate, SPV, REGES and Form 112 remain yours, with your accountant and, if needed, a payroll provider. The post-incorporation guide covers activating SPV; the micro guide covers why you need an employee or a mandate — this article covers only how they are reported.

Informational guide as of 14 September 2026. Law no. 53/2003, Law no. 227/2015, Law no. 207/2015, GD no. 295/2025, GD no. 146/2026, GEO no. 89/2025, GEO no. 8/2026, Law no. 239/2025 and joint order no. 605/95/928/2314/2026 may be updated. Check anaf.ro (tax calendar, Form 112 software), legislatie.just.ro and reges.inspectiamuncii.ro. Payroll rounding and the month’s timesheet are for your accountant. This is not tax, employment-law or HR advice.