We present a summary of the main legislative changes impacting the tax field, published in  January 2026. 

Ordinance no. 1/2026 amending and supplementing Law no. 207/2015 on the Fiscal Procedure  Code (Official Gazette no. 75 of 30.01.2026). 

Ordinance no. 1/2026 transposes into national legislation Council Directive (EU) 2025/872 of 14  April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation  (DAC9): 

Informative Declaration on the Supplementary Tax (Pillar II) 

• • A standard model of informative declaration is introduced to fulfill the reporting  obligations for supplementary tax under art. of Law no. 431/2023. 
• • Specific rules are introduced regarding the communication between the tax authorities  of EU member states of the data reported through the automatic exchange of  information. 
• • The use by Multinational Enterprise Groups and National Large-Scale Groups of any other  form than the standard model of informative declaration constitutes a contravention and  is sanctioned with a fine ranging between RON 10,000 – 30,000. 
• • The standard model for the Informative Declaration regarding the supplementary tax  shall be approved by order of the President of the National Agency for Fiscal  Administration (NAFA) within 60 days from the entry into force of Ordinance 1/2026. 

Automatic exchange of financial information 

• • More stringent requirements are established regarding KYC and due-diligence  procedures, introducing additional checks as well as extended reporting obligations for  reporting financial institutions. 

Ordinance no. 6/2026 amends Law no. 207/2015 on the Fiscal Procedure Code, along with  certain fiscal-budgetary measures (Official Gazette no. 77 of 30.01.2026) 

Law no. 207/2015 on the Fiscal Procedure Code  

Declaration of secondary headquarters 

• • Simplification of fiscal registration when a taxpayer has multiple secondary  headquarters that pay salaries and income assimilated to salaries within the territorial  jurisdiction on the same administrative unit / subdivision as its fiscal domicile. 
• • For entities already established at the date of entry into force of Law no. 245/2025, the  application of sanctions for the untimely submission of the fiscal registration declaration  is postponed until June 30, 2026.

Tax on non-resident affiliated companies 

• • Article 251 of the Fiscal Code regarding the special regime for taxpayers recording  expenses with affiliated entities that are not established / constituted and not have their  effective management place in Romania is repealed. 

• This rule was introduced by Law 239/2025 and was effective starting January 1, 2026. 

RO e-factura for individuals identified by CNP 

• • The rules regarding the enrollment and use of the RO e-Factura system for  suppliers/service providers identified fiscally by personal numeric code (CNP) are  amended, extending until June 1, 2026 (previously January 15, 2026, under GEO 89/2025)  the deadline from which the transmission of invoices related to supplies of  goods/services must be mandatorily made through the RO e-Factura system. 

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For additional details regarding the above, you can contact any member of the Taxhouse team or you can send us an e-mail at office@taxhouse.ro.