Unique control register for an SRL in 2026: 30 days from registration and a fine of RON 500–2,000

On Monday 26 October 2026, a new SRL has a booklet the accountant does not write and that you do not file in the private virtual space. The mandatory-accounting guide says who keeps double-entry books, that documents are kept for 10 years, and that an SRL files its annual financial statements with ANAF by 31 May. The annual-inventory guide is about the inventory register, code 14-1-2, not about the booklet in which an inspector writes a badge number. Neither says in how many days you buy the unique control register, or what fine attaches to not having it.

The five searches of this URL: (1) the unique control register is mandatory for an SRL in 2026 and optional for the other categories, including a PFA, (2) the deadline of 30 days from registration and where it is issued, (3) where it is kept — the registered office and any secondary office that has permits — and why moving the office does not require a new booklet, (4) who writes in it, and why a control can still go ahead without the booklet, (5) the fines of RON 500–1,000 and RON 1,000–2,000, plus half the minimum within 15 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 26 October 2026 against the text of Law no. 252/2003 published on legislatie.just.ro, against Law no. 348/2004, art. 5(5), against art. 16(1) and art. 28 of Government Ordinance no. 2/2001 in the form after GEO no. 7/2026, against art. LVIII of Law no. 296/2023, and against the sale notices still posted by the Sălaj county tax administration and by the Constanța unit. The statute’s page still prints the fines in old lei. I did not find on that page an art. 8 rewritten at other amounts.

Art. 1(1) of Law no. 252/2003 requires taxpayers that are legal persons registered with the National Trade Register Office and authorised according to the law to keep the unique control register. An SRL is a legal person. The duty does not wait for the first invoice and does not wait for the first employee. Paragraph (2) lets the other categories of taxpayer keep the register only if they choose to. A PFA is not the legal person in paragraph (1). The difference of form is in the PFA or SRL guide: choosing the form does not, for an SRL, move the text of paragraph (1).

«Authorised according to the law» is not a second company and it is not the town-hall licence for a shop. At the trade register, authorisation to function is the registration of the standard declaration on one’s own responsibility, for the activities declared at the registered office, at secondary offices, or, where relevant, elsewhere (Law no. 265/2022, art. 121(1) and art. 122(1), in the text published by ONRC). Art. 122(2) takes only the company’s own office activities out of that declaration. It does not say that an office-only SRL is exempt from the unique control register. Art. 6(3) puts the purchase on the newly established taxpayer, 30 days from the date of registration.

The point of the booklet is art. 2(1): a record of every control carried out by the specialised bodies, not only by ANAF. The statutory list covers the financial and tax field, health, plant health, urban planning, construction quality, consumer protection, labour protection, labour inspection, fire protection, and other fields the law provides. The same booklet is what the tax inspector, the labour inspector, and the firefighter ask for if they come to you. You do not open one booklet per institution. The record is made with the signature of the legal representative and the signature of the control body (paragraph (2)).

Art. 6(3) requires newly established taxpayers to buy the register within 30 days of the date of registration. The text says «days», not «working days». The day of registration is not counted. For an SRL registered on Monday 26 October 2026, day 1 is Tuesday 27 October, and day 30 is Wednesday 25 November 2026. That day is a working day, so the deadline does not move. Sunday 1 November 2026 falls inside the interval, not on the last day. Paragraph (2), the 30 days from the entry into force of the 2003 law, is the transitional deadline, and it is closed. You do not count today’s company on it.

Art. 6(1) says the register is issued, against payment, by the general directorates of public finance in the area of the registered office, on the basis of the registration certificate, for traders. Today the counter is the ANAF tax administration of that office: the notice still posted on 26 October 2026 by the Sălaj county administration carries the header of the Ministry of Finance, ANAF, and the Cluj-Napoca regional directorate. The checklist after incorporation opens the private virtual space for e-Factura and for returns. That space does not issue this booklet. Art. 10 says it is printed by Compania Națională «Imprimeria Națională» S.A. A register from a stationer, however similar, is not the purchase from the tax authority that art. 7(a) requires.

The statute sets no price and publishes no national list of papers. The two notices still posted on static.anaf.ro, the Sălaj county administration and the Constanța unit (18 I.Gh. Duca Street), both show RON 30.25 for the unique control register and RON 78.65 for the fiscal-evidence register, which is a different document. Check your own unit’s notice before you leave with that sum. The Sălaj notice also says registers are not sold on the last working day of the month. Friday 30 October 2026 is the last working day of October, because 31 October is a Saturday: in Sălaj, a company registered on Wednesday 30 September 2026 has day 30 on that Friday and may find the counter closed for sales. That is the local notice, not art. 6. The papers differ: the statute asks for the registration certificate; the notices also ask for a copy of the identity card and, if someone else collects the booklet, a power of attorney. For a working point they ask for an excerpt from the trade register.

Art. 5(1): the register is numbered, sealed, and kept by the legal representative of the unit being checked, or by that person’s substitute. It does not live in the accountant’s personal file. The contract with the CECCAR member may say who brings the supporting documents; it does not move custody of the sealed booklet. Paragraph (2): it is kept at the registered office and at each secondary office for which permits, authorisations, or functioning agreements were issued. What the registered office is, and what proof of it goes into the incorporation file, is in the registered-office guide. One booklet does not cover two addresses that both fall under paragraph (2): the text says «at the registered office and at each secondary office».

Not every address where you work for an afternoon is the secondary office in paragraph (2). The condition is that permits, authorisations, or functioning agreements were issued for that office. The trade-register functioning declaration, when it covers a secondary office, is the authorisation in art. 121 of Law no. 265/2022. An address that exists only as a plan, with no such act, does not open paragraph (2). When you buy the booklet for a working point, the Sălaj and Constanța notices ask for the trade-register excerpt. The issuer remains the tax unit in the area of the registered office, art. 6(1), not the administration of the county where the point sits. Do not travel to the other county merely because the shop is there.

A change of registered office is not a new incorporation. ANAF’s answer on a move applies art. 6(3) only to newly established taxpayers and says the special law does not require a new register when the office changes. The question-and-answer page does not carry a 2026 revision date; the article, re-read on 26 October 2026, still ties no purchase to a move. The numbered booklet moves with the office. The trade-register filing that changes the address is a different file and is in the ONRC amendments guide. Law no. 252/2003 does not describe a duplicate procedure if you lose the booklet. Failure to present it, when you are asked, is the offence in art. 7(b), not a third fine invented for «loss».

You do not fill in the rows to «show activity». Art. 3(2) requires the control body to record, before the control starts: the name of the persons authorised to carry out the control, the unit they belong to, the badge number, the number and date of the delegation or travel order, the objectives, the period of the control, the period under review, and the legal basis. Paragraph (3) requires them to read, beforehand, earlier control acts in their own field, so they know the findings, the measures, and how far those measures have been carried out. You sign as legal representative, next to the inspector’s signature (art. 2(2)). An empty register after two years with no control is the normal state, not a gap to be filled the night before.

Art. 3(4) says the control may take place only after those data have been entered. Paragraph (5) is the exception people look for when they want to stop the inspector: if the register is not presented, the verification is carried out, and the reasons for the failure to present it are written in the control act. You do not block a control by leaving the booklet at home or by saying you «have not bought it yet». Your separate offence is art. 7(b). After the control ends, the number and date of the control act are entered in the register (art. 4). Until there is an act, there is no number to write.

If the inspector does not write the elements in art. 3(2) and art. 4, art. 9 calls the omission a disciplinary breach and sends it to the civil-service statute or, as the case may be, to labour law. The article still cites Law no. 188/1999. It does not give you a sum you can collect, and it does not cancel the control. The journal, the inventory register, and the fiscal cash register remain other records. The electronic journal of the cash register and the Z report have their own retention period, in the guide on fiscal cash registers. Law no. 252/2003 does not copy the 10 years of the accounting archive and does not copy the five years of the cash-register journal. Do not apply those periods to this booklet by analogy.

Art. 7 has two offences. Letter (a): failure to buy the register from the general directorates of public finance in the area of the registered office, within the deadline in art. 6(3). Letter (b): failure to present the register when the specialised control bodies ask for it, art. 3(1). Art. 8(1), on the statute’s page on 26 October 2026, fines letter (a) from 5,000,000 lei to 10,000,000 lei and letter (b) from 10,000,000 lei to 20,000,000 lei. Those are old lei, from 2003. Law no. 348/2004, art. 1(1) and art. 5(5), replaces amounts in acts issued before 1 July 2005 by dividing by 10,000. Today’s bands are RON 500–1,000 and RON 1,000–2,000. ANPC’s control sheet of May 2024, on the questions about art. 7, prints the same two bands. I did not find, on the portal, an act that raised art. 8 to RON 1,000–1,500 and RON 1,500–2,500.

It is not a fine per day of delay. A purchase on day 31 is letter (a), once, inside the band of RON 500–1,000, not RON 500 multiplied by the number of days. Failure to present the booklet, even if you have since bought it and do not have it with you, is letter (b), the higher band. Art. 8(2) gives both the finding and the sanction to the specialised control bodies. Paragraph (3) completes the article with Government Ordinance no. 2/2001, approved with amendments by Law no. 180/2002. The report names the person sanctioned. Law no. 252/2003 does not say «the director pays the fine from a personal pocket» and does not say «only the company pays».

Art. 28(1) of Government Ordinance no. 2/2001, in the form after Law no. 203/2018, lets you pay, within at most 15 days of the handing-over or communication of the report, half of the minimum fine set by the act, not half of the sum the inspector wrote. For letter (a) the minimum is RON 500, so RON 250. For letter (b) the minimum is RON 1,000, so RON 500. A fine of RON 800 does not become RON 400. Art. 16(1) requires the report to mention this possibility. The 15 days are not working days. For a report handed over on Wednesday 25 November 2026, day 15 is Thursday 10 December 2026, a working day. Tuesday 1 December 2026, the National Day, falls inside the interval. Art. LVIII of Law no. 296/2023 removed the 15-day facility for the Accounting Law, for Law no. 70/2015, for GEO no. 28/1999, and for the other acts on that list. Law no. 252/2003 is not on the list. That is why the fiscal cash-register guide says a cash register does not get the 15 days, and this register does. Paragraph (1^1) of art. 28, added by GEO no. 7/2026 (Official Gazette no. 146 of 25 February 2026), is half of the amount actually imposed, and only for fines on building permits and urban planning. Do not use it for this booklet. Payment due to the state budget is made online, at credit institutions that have an agreement, or at the Treasury; a copy of the receipt goes to the agent, by post, or by email (art. 28(2)).

Walk through the steps in the first month after the certificate. The deadlines below are those in force on Monday 26 October 2026. Thirty days means calendar days. Fifteen days for half the minimum also means days, not working days.

Tavoris prepares the file for registering an SRL with ONRC, from the identity document and the registered-office contract. It does not buy the unique control register, does not queue at the tax administration, does not keep the sealed booklet, and does not sign it when an inspector arrives.

After the certificate, the payment account runs on a different clock: 60 working days, in the bank-account guide. The 30 days of the unique control register are calendar days and run from registration, in parallel, not after the bank opens the account. This article covers only Law no. 252/2003: who must keep the booklet, where it is issued, where it is kept, and what fine attaches to not having it.

Informational guide as of 26 October 2026. Sources: Law no. 252/2003, arts. 1–10, in the text on legislatie.just.ro on this date, with the fines still in old lei; Law no. 348/2004, art. 1(1) and art. 5(5), for the division by 10,000; Law no. 265/2022, arts. 121 and 122, for authorisation to function at the trade register; Government Ordinance no. 2/2001, art. 8 via the reference in Law no. 252/2003, art. 16(1) and art. 28, including paragraph (1^1) introduced by GEO no. 7/2026; Law no. 296/2023, art. LVIII, which does not name Law no. 252/2003; the price notices of the Sălaj county tax administration and of the Constanța unit, posted on static.anaf.ro on 26 October 2026, with no national tariff in the statute; the ANPC sheet of May 2024 for the bands of RON 500–1,000 and RON 1,000–2,000. Check legislatie.just.ro, anaf.ro, and your own unit’s notice. This is not legal or tax advice.