In brief

  • ANAF has rewritten the form called Invitation to a hearing, the document by which you are called to state your case before the tax authority issues a tax assessment decision following a check carried out from the desk, with no inspectors at your premises.
  • The hearing may also be held online, and the new form says it takes place only through the videoconference platform of the Ministry of Finance and ANAF. The old version left the technical details to be agreed with the inspector.
  • The only deadline that told the taxpayer to move in good time has vanished from the form, the notice of at least 24 hours. The real deadline, of 2 working days, sits in another order, to which the new form does not refer.
Act: ANAF Order no. 1.019/2026
Published: Official Gazette of Romania (Monitorul Oficial) no. 732 of 1 September 2026
In force from: 1 September 2026

The quietest tax check is the one you never see: ANAF looks at your tax file and at what other people have declared about you, and the first news you get is a letter listing the differences found. It is called documentary verification and it is governed by Articles 148 and 149 of the Tax Procedure Code, the same code that is about to be republished with its articles renumbered. ANAF Order no. 1.019/2026, published in Official Gazette of Romania no. 732 of 1 September 2026, changes one of the four forms used in this procedure: the invitation by which you are called to a hearing before the tax authority decides how much you owe. On the same line of procedures rewritten in 2026, MF Order no. 1.128/2026 changes the rules of the advance tax ruling.

Documentary verification is a tax check carried out at a distance. Nobody comes to the company premises, no documents are taken away, no inspection report is drawn up. The tax authority carries out what the law calls a consistency analysis: it compares what you have declared with what it already holds in your tax file and with information received from third parties, from banks to the invoices your business partners have sent into the electronic system. If a difference emerges, you are notified and asked for documents. You have 30 days from service of the notification in which to produce them, with the possibility of asking for an extension on duly justified grounds. If you do not produce them, or if the documents confirm the difference or are incorrect or incomplete, ANAF issues a tax assessment decision.

Before the decision, however, there is a compulsory step, and that step is what the form changed now is about. Article 149(4) of the Tax Procedure Code states that a tax assessment decision issued without hearing the taxpayer is null and void, with a single exception: the taxpayer has given written notice that he waives the hearing. The Invitation to a hearing is the document by which the tax authority triggers this step. From 1 September 2026 its content is new.

ANAF works the same way when the VAT return is missing: a recent order automatically cuts half the input VAT of companies that do not file the 300 return.

What it changes in practice

The same option was written into the mediation procedure as well, and there the deadline is spelled out: the video call has to be requested within two working days of receiving the notice.

The first effect is that the online hearing now has a single route. The form says the discussion may take place either at the premises of the tax authority or through electronic means of remote communication providing an audio-video connection, and that if you choose the remote route it is carried out through the videoconference platform of the Ministry of Finance and ANAF. The platform was approved by ANAF Order no. 705/2026, published in Official Gazette of Romania no. 494 of 15 June 2026 and in force from 17 June 2026, and the list of procedures that may be conducted on it expressly includes, at point 2.5, the hearing in documentary verification.

The second effect is that the online hearing becomes a procedure with a written trace. Under Article 5 of Order no. 705/2026, meetings on the platform are recorded, transcribed with the electronic system of the tax authority, and the minutes of the meeting are served in the Private Virtual Space. Identification is done with the qualified certificates of the Private Virtual Space account, with a username and password plus a code received on the telephone, or through the ROeID platform. This is the exact opposite of the earlier situation, in which the technical details of a video conversation were agreed with the inspector and nothing survived the meeting except what he recorded.

The third effect is the most important one for whoever receives the invitation, and it is an effect of omission. The 2023 form required the taxpayer to inform the tax authority at least 24 hours before the time set, if he wanted the hearing online. The new form has deleted the sentence and put nothing in its place. The deadline that actually applies is written in Article 3(2) of Order no. 705/2026: the option is exercised through the Private Virtual Space, within 2 working days, under penalty of forfeiture of the right to opt. Anyone who misses those 2 working days is left with the face-to-face meeting, and the new form mentions neither the deadline nor the sanction. Instead, it refers the reader to the ANAF portal, the Online Services section, for „informații suplimentare”, further information.

The fourth effect is a condition of access about which the form says nothing. Article 3(1) of Order no. 705/2026 reserves the platform to taxpayers registered in the Private Virtual Space. The invitation offers the choice between the premises and the online route to everyone who receives it, including an individual who has no account there and who, in fact, cannot use the online route.

The fifth effect is that the rest of the rules are untouched. The period of 5 working days from the date of the hearing, within which you may file your statement of position in writing, stays in the form, as does the possibility of extending it by no more than 5 further working days on justified grounds, with the agreement of the head of the tax control body. The two hearing dates, with day and time, the notification by which you may waive the hearing and the channels through which you send in your statement of position also remain: the Private Virtual Space, email, post with recorded delivery and acknowledgement of receipt, or the registry of the tax authority. The same simplification reached the certificates in September 2026: ANAF dropped the banknote-style printing of the tax certificate and opened it to electronic delivery.

What has changed compared with the previous situation

The form replaced now is not the one from 2020. Annex no. 2 to Order no. 3.666/2020 has already been rewritten once, by ANAF Order no. 927/2023, published in Official Gazette of Romania no. 587 of 28 June 2023, an order with exactly the same title as the present one. The comparison that matters is therefore with the 2023 version, and very little of it changes, but the change falls precisely at the sensitive point.

The paragraph on the remote hearing. The 2023 version said: „În situația în care veți opta pentru audiere prin intermediul sistemelor electronice de comunicare la distanță, veți informa organul fiscal cu cel puțin 24 de ore înainte de ora stabilită pentru audiere, în vederea stabilirii detaliilor tehnice ale întâlnirii, de comun acord cu reprezentantul desemnat din cadrul organului fiscal.”, that is, if you opt for a hearing through electronic means of remote communication, you will inform the tax authority at least 24 hours before the time set, so that the technical details of the meeting can be agreed with the designated representative of the tax authority. The 2026 version says: „În situația în care optați pentru derularea procedurii de audiere prin intermediul sistemelor electronice de comunicare la distanță, aceasta se realizează prin platforma de videoconferință”, if you opt to conduct the hearing procedure through electronic means of remote communication, it is carried out through the videoconference platform, and the sentence goes on to name the platform of the Ministry of Finance and ANAF. Three things disappeared in the same sentence: the 24-hour deadline, the obligation to inform the tax authority, and the agreement on the technical details.

A new paragraph, of reference. After it, the following was added: further information on the rules and the specific conditions for holding meetings on the platform is available on the ANAF portal, www.anaf.ro, in the Online Services section. It is the only place in the form where the taxpayer is sent to look for the rules, and the destination is a web page, not a legal act.

The structure charged with carrying the order out. In the list in Article II, the 2023 „Direcția generală coordonare control fiscal”, the General Directorate for Tax Control Coordination, is replaced with „Direcția proceduri și programare control fiscal”, the Directorate for Tax Control Procedures and Planning. The rest of the list, namely the General Directorate for the Administration of Large Taxpayers, the regional general directorates of public finance and the structures subordinated to them, the General Directorate for Tax Anti-Fraud and the General Directorate for the Control of Individuals’ Income, stays the same.

What has not changed, although it looks new. The 5 working days for the written statement of position, the time given next to each of the two hearing dates, the notification waiving the hearing and the statement that a document signed with a qualified digital certificate is valid without a stamp have all been in the form since 2023. They came in then as a consequence of Government Emergency Ordinance no. 188/2022, which supplemented Article 149 of the Tax Procedure Code. The original 2020 version was built differently: it had a single date, on which the statement of position could be submitted in writing or made orally, with no time given and without the 5 working days afterwards.

Advantages and disadvantages

What it improves

  • The online hearing no longer depends on the goodwill and the equipment of the inspector: there is a single platform, provided by the tax authority.
  • The discussion is recorded and transcribed, and the minutes reach the taxpayer through the Private Virtual Space, so a trace exists that is independent of what the inspector wrote down.
  • Participants are identified electronically, by means recognised by ANAF, so the online hearing carries the same procedural weight as one held at the counter.
  • A taxpayer administered by a regional directorate in another county no longer loses a day on the road for an hour-long discussion about a draft decision.
  • The form keeps, in black and white, the 5 working days after the hearing, the period that matters most for the defence.

What remains a problem

  • The deadline within which the online route has to be requested no longer appears anywhere in the form, although it exists and is lost through forfeiture after 2 working days.
  • The form offers everyone the choice between the premises and the online route, although the platform works only for those registered in the Private Virtual Space.
  • The rules on the online hearing are pointed to on a web page, which can change at any time, instead of the order that lays them down.
  • The order has no transitional provisions for invitations issued on the old form before 1 September 2026, for hearings scheduled after that date.
  • The form says what happens if you fail to appear on either date, but it does not say what happens if you give notice waiving the hearing, and the consequence is the same.

Practical advice

  1. Do not mistake the invitation to a hearing for a mere information letter. It is the last procedural moment at which you can change the content of the tax assessment decision before it is issued and served.
  2. If you want the hearing online, say so at once, not on the day of the meeting. The option is exercised through the Private Virtual Space within 2 working days of the notice, and after that the right to opt is lost.
  3. Check your Private Virtual Space every day once you have received the notice from the tax authority. Both the invitation to opt and, later, the rules and the access to the videoconference arrive there.
  4. If you are not registered in the Private Virtual Space, count on travelling. The videoconference platform is reserved to taxpayers registered there, whatever choice the form offers you.
  5. Read carefully the draft tax assessment decision or the draft order of measures attached to the invitation. That is the subject of the hearing, and your statement of position has to address the findings in it, not the check in general.
  6. Note the date of the hearing and count 5 working days from it. That is the period in which you may file your statement of position in writing, and an extension of up to 5 further working days has to be requested with reasons and approved by the head of the tax control body.
  7. If you cannot attend the first date, do not assume the second one solves everything. Failure to appear on two consecutive dates means the hearing is deemed to have taken place, under Article 9(3)(b) of the Tax Procedure Code, and the decision can be issued without you.
  8. Remember that a tax assessment decision issued following documentary verification is a decision subject to subsequent verification, so it can be reopened at a future inspection. It can be challenged within 45 days of service, before the tax authority that issued it.

Frequently asked questions

What is documentary verification, in short?
A tax check carried out from the desk, with no visit to the taxpayer’s premises. The tax authority compares the data in your tax file with information received from third parties and checks whether they match. If differences appear, it asks you for documents, and if these are missing or confirm the difference, it issues a tax assessment decision.
How does it differ from a tax inspection?
A tax inspection involves the presence of inspectors, the checking of records on the spot and an inspection report. Documentary verification is carried out on existing documents and on information from third parties, and the resulting decision is subject to subsequent verification, so it can be reopened at a future inspection.
What should I do when I receive the invitation to a hearing?
Read the draft decision or draft order attached, decide whether you are going to the premises or asking for the online route, and appear on the date and at the time in the invitation. After the hearing you have 5 working days to file your statement of position in writing.
How do I ask for the hearing to be held online?
Through the Private Virtual Space, within 2 working days of the notice from the tax authority, under Article 3(2) of ANAF Order no. 705/2026. The new invitation form does not mention this deadline, but it applies, and missing it entails forfeiture of the right to opt.
What happens if I do not appear at the hearing?
If you appear on neither of the two dates and do not give notice waiving the hearing, the hearing is deemed to have taken place and the decision can be issued. The rule comes from Article 9(3)(b) of the Tax Procedure Code, and the form reproduces it.
Can I waive the hearing?
Yes, by notifying the tax authority before the scheduled date or dates. The effect, however, is the same: the tax assessment decision can be issued, because Article 149(4) of the Tax Procedure Code exempts from the sanction of nullity precisely the case in which the taxpayer has waived the hearing in writing.
How long after the hearing do I receive the decision?
Within no more than 25 working days from the date of the hearing, under Article 149(6) of the Tax Procedure Code. The deadline does not appear in the invitation form.
From when does the new form apply?
From 1 September 2026, the date of publication in the Official Gazette of Romania. The order does not provide for a later date of entry into force and contains no transitional provisions for invitations issued earlier.
Is this the same act as Order no. 1.019/2026 on fuel markups?
No. That one is an order of the minister of finance, on form 183. This one is an order of the president of ANAF, with the same number, published in the same period, but concerning documentary verification.

Editorial analysis

The order does something right and necessary: it aligns the form with the infrastructure ANAF has already built. From 17 June 2026, when Order no. 705/2026 entered into force, the hearing in documentary verification appeared on the list of procedures that may be conducted through the videoconference platform, yet the form sent to the taxpayer went on talking to him about technical details agreed with the inspector. Seventy-six days passed between the two moments, during which the official document described a procedural reality that no longer existed. The present order closes that gap, and that is the good part.

The problem is what it put in place of the old text. The 2023 form carried a simple signal: give at least 24 hours’ notice. It was not the exact legal deadline, nor did it need to be, but it told the reader that the option for the online route is not exercised on the day of the hearing. The new form deleted the sentence and replaced it with a reference to a section of a website. The real deadline, the one in Article 3(2) of Order no. 705/2026, is shorter and harsher than the one deleted: 2 working days, through the Private Virtual Space, under penalty of forfeiture. The taxpayer holding the invitation has no way of learning this from the invitation. Article 7(1) of the Tax Procedure Code requires the tax authority to inform the taxpayer of the rights and obligations that fall to him during the procedure, and the invitation form is precisely the vehicle of that duty. A forfeiture deadline that does not appear in the document giving notice is the only thing genuinely wrong with this order, even if it contradicts nothing in its own text.

The arithmetic of the deadlines also says something that does not show up when you read the act from beginning to end. After the hearing, the taxpayer has 5 working days in which to file his statement of position in writing, and the extension of up to 5 further working days does not depend on him: it is granted on justified grounds, with the agreement of the head of the tax control body, that is of the very structure that is going to decide. From the same moment, ANAF has, under Article 149(6), up to 25 working days in which to issue the decision. The ratio is one to five. In calendar days, the taxpayer has around a week and the tax authority around five. This is not an injustice in itself, a file takes longer to write than a letter, but it is worth saying that the only deadline in the procedure that can be lost beyond recovery belongs to the taxpayer, and the only one that can be extended with someone’s agreement is his as well.

There is one more mismatch, this time between what the form offers and who can use it. The invitation offers the addressee the choice between the premises and videoconference, „în funcție de modalitatea aleasă de dumneavoastră”, according to the option you choose. The platform, however, is reserved by Article 3(1) of Order no. 705/2026 to taxpayers registered in the Private Virtual Space. The individual who receives the invitation on paper, precisely because he has no account there, is exactly the person to whom the form offers a choice he cannot make. As for cross-references, the form cites Article 9 and Article 149(5) of the Tax Procedure Code by number. Both are correct today, checked against the text in force. Except that Law no. 136/2026 has triggered the republication of the code with its articles renumbered, and on the day of republication a form printed and sent to taxpayers will be citing two articles that no longer exist under those numbers.

What should be changed

  • The 2 working days, written into the form. A single sentence, saying that the option for a hearing through the videoconference platform is exercised through the Private Virtual Space, within 2 working days of receipt of the notice, under penalty of forfeiture, would make the search on the portal unnecessary and would close the only real risk in the new version: the loss of a right without its holder being told.
  • A reference to the order that lays down the rules, not to a section of a website. The ANAF portal gets reorganised, and a section called Online Services today may be called something else a year from now. A reference to ANAF Order no. 705/2026 stays verifiable and gives the taxpayer a text he can hold up against the tax authority.
  • The condition of registration in the Private Virtual Space, stated where the choice is offered. The form should say that the online route is available to taxpayers registered in the Private Virtual Space. Otherwise the choice offered to those not registered is a formality, and the refusal that follows looks arbitrary.
  • The effect of waiving the hearing, stated expressly. The form explains what happens if you appear on neither of the two dates, but says nothing about what happens if you give notice waiving the hearing. A reader in good faith may believe that waiving protects him, when in fact Article 149(4) treats it the same way: the decision can be issued. One sentence would prevent a waiver made on a wrong calculation.
  • The 25 working days, entered in the form. A taxpayer who knows his own 5 working days should also see the window within which the decision may be issued against him. He would know when to check his communications and could more easily spot a decision issued before his own period for defence had expired.
  • Cross-references made by the title of the article, not only by number. Written as Article 149(5), „Rezultatul verificării documentare”, the result of the documentary verification, the text survives the republication of the code. It is a cheap precaution for a form that reaches taxpayers in tens of thousands of copies and that will be read after the renumbering as well.

Original text of the legal act

The text below is reproduced in Romanian, the official form of publication.

The full text, as published in the Official Gazette of Romania

Official Gazette of Romania no. 732 of 1 September 2026 16 pages PDF, 143 KB the act starts on page 9

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This article is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed attorney or tax advisor.