Mandatory SRL accounting in 2026: double-entry, CECCAR, and financial statements by 31 May

On Monday 12 October 2026, a new SRL does not wait for the first invoice before it has accounts. Accounting Law no. 82/1991, art. 1(1), puts the duty on the company from the moment it exists. Art. 5(1) requires double-entry and annual financial statements. The after-incorporation guide says what you open at ANAF and at the bank. The PFA or SRL comparison notes that a PFA may stay on single-entry. Neither says who may keep the books, what fine an unrecorded receipt draws, or by when you file the balance sheet.

The five searches this URL covers, which the existing articles do not take as their subject: (1) accounting is mandatory for an SRL in 2026, in double-entry, including with no receipts, (2) who keeps it — the director, an employee with a higher degree in economics, or a contract with a CECCAR member, (3) the fine for unrecorded transactions, RON 2,000–20,000, (4) how long you keep documents, 10 years, and payroll sheets, 50 years, (5) an SRL’s annual financial statements, the 31 May deadline, and electronic filing. This is not the micro or profit-tax guide, and it is not the invoice guide.

Art. 1(1) of Law no. 82/1991 requires companies to organise and keep financial accounting. An SRL incorporated on Monday 12 October 2026 falls into that category on the day of registration, not in the month it issues the first invoice. Art. 5(1) adds the system rule: the persons in art. 1(1)–(4) keep double-entry accounts and prepare annual financial statements. Single-entry is for the categories the finance minister sets, not for an SRL. Under art. 1(5), a natural person taxed on actual income may keep single-entry records or, by option, double-entry. That is the difference from a PFA, set out in the PFA or SRL guide.

Art. 6(1) says every economic and financial transaction is recorded when it happens, in a document that becomes a supporting document. A month with no activity does not erase the duty to be organised. A month with no invoices still needs the books open, so you can show that there were no transactions, not that you skipped them. The accounting regulations that apply to companies are those approved by Order of the Minister of Public Finance no. 1,802/2014. This article does not repeat the chart of accounts. It only says the journal and the supporting document are not optional because the firm is “small” or because you are on the 1% micro tax.

The financial year usually matches the calendar year, and it lasts 12 months (art. 27(1) and (2)). An SRL that did not exist before 12 October 2026 has nothing to report for January to September. The first annual reporting covers the period from incorporation to 31 December 2026, if you stay on the calendar year. You may opt for a year that is not the calendar year, art. 27(3) and (5), in which case the deadline is no longer 31 May but 150 calendar days from the end of that year (art. 36(1^2)). The option is notified. Nobody assumes it for you.

Art. 10(1) puts responsibility for organising and leading the accounting on the director, or on the person who manages the entity. “Organises” does not mean the director fills in the journal. Paragraph (2) says the books are kept, as a rule, in departments led by the economic director, the chief accountant, or another authorised person. Those persons must have a higher degree in economics and be employed under the law, with duties to lead the accounting. Paragraph (4^1), which lets a natural person keep their own records, refers to art. 1(5), not to an SRL.

The path almost every new SRL uses is paragraph (3): a services contract with natural or legal persons authorised by law, members of the Body of Expert and Licensed Accountants of Romania (CECCAR). An expert accountant and a licensed accountant both qualify, if they are on the members’ roll. A friend who is “good at spreadsheets”, who is not a CECCAR member and is not employed with a higher degree in economics in the role in paragraph (2), does not close the duty. You check the status on the public CECCAR roll before you sign, not after the first inspection.

Liability is shared, not cancelled. Paragraph (4): if the books are kept under a contract, liability for leading the accounting lies with the provider, under the law and the contract. The director remains under paragraph (1): he chooses the provider, hands over the documents on time, and signs the statements as director. The director’s mandate, described in the remuneration guide, sets how you are paid for management. It does not stand in for an accounting contract, and it does not make you chief accountant. A free mandate, or one paid at the minimum wage to meet the micro-enterprise condition, is not the employment in art. 10(2).

Art. 41 point 1 treats as a contravention the holding of assets or liabilities, and the carrying out of economic and financial transactions, without recording them in the accounts. Art. 42(1)(a), in the form given by Emergency Ordinance no. 115/2023 (Official Gazette no. 1139 of 15 December 2023), sanctions point 1 with a fine from RON 2,000 to RON 20,000. It is not RON 2,000 per document, and it is not the 0.02% daily interest in the Fiscal Procedure Code. It is a contravention fine, inside that band, borne by the persons at fault (art. 42(6)). A receipt into the account, or a payment from the cash desk, that never reaches the books falls under point 1 even if you “meant to enter it next month”.

Art. 41 point 2(c) is a separate act: failing to draw up and use supporting documents, failing to record them in the period they belong to, failing to keep and archive them, and failing to reconstitute those that were lost. Together with letter (b) (the registers), art. 42(1)(c) sets the same band, RON 2,000–20,000. The invoice guide uses letter (c) for a missing invoice as a supporting document. Here the subject is organising the books, not the 15th-of-the-month deadline. A skipped stocktake is letter (d), with a fine from RON 3,000 to RON 20,000 (art. 42(1)(d)). Do not add the bands as if each invoice automatically produced the top of the range.

Late filing of the annual financial statements is art. 41 point 2(e), with steps in working days, not calendar days (art. 42(1)(e)): from RON 300 to RON 1,000 if the delay is between 1 and 15 working days; from RON 1,000 to RON 3,000 between 16 and 30 working days; from RON 1,500 to RON 4,500 beyond 30 working days. Drawing up and signing, in the same letter, have a separate band, RON 2,000–3,000. Example on 12 October 2026: 20 working days of delay fall in the second step, so the fine sits between RON 1,000 and RON 3,000. It is not 20 times an amount per day. On 12 October 2026 I did not find an act later than Emergency Ordinance no. 115/2023 that moves these ceilings. If the Official Gazette publishes one, the new text prevails.

Art. 25(1) keeps the mandatory accounting registers and the supporting documents for 10 years, from the end of the financial year in which they were drawn up. Payroll sheets are kept for 50 years. A document issued in December 2026, in a year that ends on 31 December 2026, starts its 10 years at the close of that year, not on the invoice date. Paragraph (2) lets the minister set, with reasons, registers and documents that are kept for 5 years. Do not treat 5 years as the general rule for invoices and the journal.

Loss, theft, or destruction is reconstituted under the regulations, within at most 30 days of discovery (art. 26). In cases of force majeure, the term is 90 days from the finding that it has ended. Both terms are in days, and the text does not call them working days. An archive kept only at the accountant’s office, with no copy at the company, leaves you exposed if the contract ends: art. 25 puts the archive on the persons in art. 1, that is on the SRL, not in the provider’s personal file. The contract with the CECCAR member should say how you receive the registers and documents when it ends.

The 50-year payroll sheets are why Form 112 is not only a monthly file. The payroll sheet behind the contributions is archived for half a century. If you have no employees and no mandate that produces a payroll sheet, do not invent a payroll file to “show activity”. An empty staff list is kept as what it is. Reconstitution under art. 26 does not replace filing the financial statements on time.

Art. 36(1)(a), in the form of Emergency Ordinance no. 138/2024 (Official Gazette no. 1222 of 5 December 2024), requires companies governed by Law no. 31/1990 to file one copy of the annual financial statements with the competent tax office by 31 May inclusive of the following year. Other legal persons, letter (b), have 30 April. An SRL is letter (a), not letter (b). If the date falls on a non-working day, the last day is the next working day (paragraph (1^1)). 31 May 2026 was a Sunday, so the deadline for the 2025 statements was Monday 1 June 2026. On 12 October 2026 that deadline is closed. The next 31 May that concerns a full calendar year, 2026, is Monday 31 May 2027, and it does not move.

For an SRL incorporated on Monday 12 October 2026, on a calendar year, the first set covers 12 October–31 December 2026 and is filed by Monday 31 May 2027. From financial year 2025, Emergency Ordinance no. 138/2024 requires filing only in electronic form, under the specifications on the ANAF portal. You no longer file a paper copy “to be safe”. The statements are signed by the director and by the person who leads the accounting. The figures in the balance sheet are not the tax. The 1% rate and Form 100 are in the micro guide. The 16% rate and Form 101 are in the profit-tax guide. The balance sheet replaces neither.

If you chose a year that is not the calendar year, art. 36(1^2) moves the filing to 150 calendar days from the end of that year, counted from the day after the date the statements refer to. Letter (b) of art. 36, which you are not, has 120 days in the same situation (paragraph (1^3)). Do not mix 150 days with the 15 working days in the late-filing fine. Repeated failure to file, and statements with wrong data, have their own points in art. 41 (point 7, wrong data, a fine of RON 30,000–40,000 under art. 42(1)(n)). Before you file, match the trial balance to the bank statements. The mandatory bank account and the risk of fiscal inactivity are in the bank-account guide, not in this 31 May deadline.

Walk through the steps in the first month after the certificate. The figures are those in force on Monday 12 October 2026. The 31 May 2026 deadline, moved to 1 June because it fell on a Sunday, is already closed.

Tavoris prepares the SRL incorporation dossier for the trade register, from the identity document and the registered-office contract. It does not hire the chief accountant, it does not sign the contract with the CECCAR member, it does not record the transactions, it does not sign the financial statements, and it does not file them with ANAF.

After the certificate, the tax vector and the bank account are in the after-incorporation guide and in the bank-account guide. This article covers only the double-entry duty, who may lead the books, the fines in art. 42, and the 31 May deadline.

Informational guide as of 12 October 2026. Sources: Accounting Law no. 82/1991, arts. 1, 5, 6, 10, 25, 26, 27, 36, 41 and 42; Emergency Ordinance no. 115/2023 for the fine bands; Emergency Ordinance no. 138/2024 for the 31 May deadline, the move off a non-working day, and electronic filing from financial year 2025; Order of the Minister of Public Finance no. 1,802/2014 for the accounting regulations of companies. On this date I did not identify a later act that changes art. 10 or the ceilings in art. 42. Check legislatie.just.ro, ANAF, and the CECCAR roll. This is not accounting or legal advice.