In brief

  • Form 081 gains a new section, the fifth, through which anyone who signed up voluntarily for the optional RO e-Factura Register can ask to be taken off it. The exit takes effect from the 1st day of the month following the submission of the application, whatever day of the month it was submitted on.
  • From the list of those who may join the system voluntarily, associations, foundations, political parties and religious denominations without a VAT number disappear. They are struck off the optional register automatically, through the IT system, without filing anything.
  • What remains are five categories that may opt for e-Factura: persons exempt from VAT for supplies to diplomatic missions, European institutions, international bodies and NATO forces, foreign cultural institutes, farmers under the special scheme, those who invoice using a personal identification number, and foreign companies without a place of business in Romania.
Act: Order of the President of the National Agency for Fiscal Administration no. 1.021 of 20 August 2026
Published: Official Gazette of Romania (Monitorul Oficial) no. 743 of 3 September 2026
In force from: 3 September 2026, the date of publication

Anyone who joined the national electronic invoicing system of their own accord may ask, from 3 September 2026, to be taken off the register. Order of the President of ANAF no. 1.021/2026 rewrites form 081 and adds to it a section that was missing until now: the application to be taken off the optional RO e-Factura Register. It is the twin of an order published nine days earlier, by which associations and foundations without a VAT number were moved ex officio into the mandatory register. The two orders bear the same date of signature, 20 August 2026, and the same signature.

The optional RO e-Factura Register is the public list of those who are not obliged to use the system but have chosen to use it. For a business partner, appearing in the register means that invoices from that company arrive through the ANAF system, not by e-mail. Until this order, form 081 had a single way out, and a narrow one at that: you could withdraw the registration application, but only before the registration took effect. Once actually in the register, there was no form through which to ask to leave.

The new point 141 of the procedure closes the gap. Suppliers and service providers already registered may ask to be taken off by filling in form 081 with section V ticked, and the removal operates from the 1st day of the month following the submission. This is exactly the rule laid down by Article 108(2) of Government Emergency Ordinance no. 120/2021, the legal basis cited on the form as well, next to the tick box.

The order also changes the name of the form. From „Application for registration in the optional RO e-Factura Register/withdrawal of the application for registration in the optional RO e-Factura Register” it becomes, more briefly, „Application for registration in/removal from the optional RO e-Factura Register”. The new name applies throughout the procedure and in the title of the 2024 order that it amends.

The second substantive change is the narrowing of the list. Point 1 of the procedure, which sets out who may opt in, is rewritten in full and now covers five categories. Associations set up under Government Ordinance no. 26/2000, other non-profit associations, political parties and religious denominations not registered for VAT purposes no longer figure among them. Article II of the order settles the position of those already enrolled: they are struck off the optional register with the help of the IT system and moved into the mandatory RO e-Factura Register, organised by ANAF Order no. 3.789/2024.

What it changes in practice

From 3 September 2026, a supplier entered in the optional register has, for the first time, a way out provided by the procedure. He fills in form 081 with the assistance software made available by the National Centre for Financial Information, ticks section V and submits it electronically. He is not required to give reasons for the application, and no condition of minimum time in the register appears.

The date of exit does not depend on the day on which the form was submitted, only on the month. An application submitted on 3 September 2026 and one submitted on 30 September 2026 produce the same effect, on 1 October 2026. The first waits 28 days, the second a single day. Anyone submitting on 1 October 2026 stays in the register for another month, until 1 November 2026. The rule mirrors the one for entry: registration too is made with the date of the 1st day of the month following the filing of the application, as the form itself states at section III.

For associations, foundations, parties and denominations without a VAT number there is nothing to do. The move is made ex officio, through the IT system. They do not fill in form 081 and do not receive an application to approve, but they leave the regime in which taking part was a choice and enter the one in which it no longer is.

Economic operators without a place of business in Romania keep a separate regime. They identify themselves on the form through a record number allocated by the tax authority and communicated by e-mail, a number that does not stand in for a tax identification number in Romania and that may be used only for e-Factura. If the commercial relations they carry on end up giving them tax rights and obligations in Romania, they still have to file the tax registration declaration. ANAF returned to the same paperwork in September 2026, with two orders that strip the watermark and the UV ink from the tax certificate and add position 117 to tax return 100.

What has changed compared with the previous situation

The change in the name of the form is not a matter of style. The old name spoke of registration and of withdrawing the application. The new name speaks of registration and of removal from the register. These are two different operations, and the form keeps both of them, in separate sections.

Withdrawal, section IV, is ticked by someone who has filed the registration application and changes his mind before the entry takes effect, that is by the 1st day of the following month. A person who withdraws has never reached the register, and on the form he has to enter the number and date of the initial application, so that the administration knows what exactly is being withdrawn. Removal, section V, is ticked by someone who is already registered and wants to leave. The first cancels an application, the second ends a membership.

Checking the facsimile published in the Official Gazette of Romania confirms that section IV has not been removed: the form has five sections, and withdrawal remains the fourth. The order therefore does not replace one mechanism with another, it adds one. What is lost is the precision of the title, because the new name no longer mentions withdrawal, even though it continues to exist on the form.

The second change, the narrowing of the list, has heavier consequences. An association without a VAT number that had signed up voluntarily in 2024 or 2025 was making a choice from which it could, in theory, withdraw. After 3 September 2026 it no longer has that choice, because it has been moved into a register from which leaving is conditional on not being obliged to use the system. Point 7 letter c) of the procedure, the one describing what is entered in the register about each applicant, has been aligned with the new list and sets out exactly the same five categories.

Advantages and disadvantages

What it improves

  • It closes a two-year-old gap. From July 2024 until September 2026, anyone who signed up voluntarily for the register had no form through which to get out of it.
  • The exit is not conditional on anything: not on a minimum time in the register, not on a statement of reasons, not on the agreement of the tax authority.
  • The rule on dates is simple and identical for entry and for exit, the 1st day of the following month, so it is easy to remember and hard to get wrong.
  • The form stays a single one for all three operations, registration, withdrawal and removal, instead of yet another declaration code to learn.
  • The list of categories in the procedure and the list on the first page of the form say the same thing, so the applicant ticks what he reads.

What remains a problem

  • Section V of the form does not say from what date the removal takes effect, even though section III, right above it, states expressly for registration that it is made with the date of the 1st day of the following month. Anyone who reads only the form does not learn the deadline.
  • Nor do the instructions for completion repeat the deadline at section V. The 1st day of the following month appears a single time, in the procedure, at point 141.
  • The act does not say what happens to invoices sent between the day of the application and the date of exit, even though the interval can run to almost a month.
  • The new name of the form no longer mentions withdrawal, which nevertheless stays on the form as a separate section.
  • Associations and foundations do not receive an individual notification. The move is made through the IT system, and the only way of finding out which register you appear in is to look at the public registers on the ANAF website.

Practical advice

  1. Look first at the public registers on the ANAF website and check which of them you appear in. Article 108(1) of Government Emergency Ordinance no. 120/2021 declares them public precisely so that anyone can consult them.
  2. If you want to leave, submit form 081 with section V ticked by the last working day of the month. One day of delay keeps you in the register for another whole month.
  3. Do not confuse section IV with section V. If you signed up this month and changed your mind before the entry took effect, tick IV and enter the number and date of the initial application. If you are already in the register, tick V.
  4. Fill in the form with the assistance software of the National Centre for Financial Information and submit it electronically. The form is not filed on paper at a counter.
  5. If you are an association, foundation, party or religious denomination without a VAT number, do not file any form for the move. Do check in the mandatory register from what date you appear there, because the way you issue your invoices hangs on it.
  6. If you invoice through an agent or a tax representative, have ready the number and the date on which the instrument of authorisation was recorded with the tax authority. The form asks for them at section II.

Frequently asked questions

What is the optional RO e-Factura Register?
It is the public list of those who are not obliged to use the national electronic invoicing system but have chosen to use it. It is kept by ANAF and can be consulted by anyone, including by business partners who want to know how they will receive the invoices.
Who can still join the system voluntarily after 3 September 2026?
Five categories. Persons benefiting from the exemptions in Article 294(1)(j) to (n) of the Tax Code, that is supplies to diplomatic missions and consular offices, to the institutions of the European Union, to international bodies and to NATO armed forces. The cultural institutes and centres of other states operating in Romania on the basis of intergovernmental agreements. Farmers who are natural persons under the special scheme. Suppliers who identify themselves for tax purposes through a personal identification number. And economic operators without a place of business in Romania, in dealings with companies or with contracting authorities.
How do I ask to be taken off the register?
Fill in form 081 with the assistance software made available by the National Centre for Financial Information, tick section V, „Application for removal from the optional RO e-Factura Register”, and submit the form by electronic means.
From when does the removal take effect?
From the 1st day of the month following the one in which you submitted the form. The day of the month does not matter. An application from 4 September 2026 and one from 29 September 2026 both take effect on 1 October 2026.
What is the difference between withdrawal and removal?
Withdrawal, section IV of the form, is used before the entry takes effect, that is before the 1st day of the month following the filing of the application. You are withdrawing an application that has not managed to put you in the register. Removal, section V, is used after you have actually reached the register. You are leaving a register you are already in.
I am an association without a VAT number. What do I have to do?
Nothing. You are struck off the optional register and entered in the mandatory one through the IT system, without any application on your part. It is still worth checking in the public register from what date you figure in the mandatory register.
What happens to invoices issued between the day of the application and the date of exit?
The order does not say. Until the 1st day of the following month you stay entered in the register, and the register is public, so your partners continue to see that you use the system. The prudent reading is to keep sending invoices through RO e-Factura until the date on which the removal takes effect.
Do I have to give reasons for the application for removal?
No. Point 141 of the procedure requires no justification, no minimum time in the register and no prior agreement of the tax authority. Ticking section V is enough.
I am a company from another country, without a place of business in Romania. Does this concern me?
Yes, if you opted for e-Factura in dealings with companies in Romania or with contracting authorities. The procedure for you is the one in Chapter IV of the procedure, and on the form you fill in section I.B, with the record number allocated by the tax authority. That number is not a Romanian tax number and is used only for e-Factura.
From when does the order apply?
From 3 September 2026, the date of publication in the Official Gazette of Romania. Article V says only that the order is to be published, without providing a later date, and Article 12(3) of Law no. 24/2000 establishes that orders enter into force on the date of publication if they do not provide otherwise.

Errors and inconsistencies in the published text

  • Article II, the date from which associations and foundations figure in the mandatory RO e-Factura Register. Article II of this order provides that, on the date it enters into force, that is on 3 September 2026, associations, foundations, political parties and religious denominations without a VAT number entered in the optional register are struck off it and „vor fi înscrise”, will be entered, in the mandatory RO e-Factura Register. That entry had, however, already taken place. ANAF Order no. 1.020/2026, signed on the same day, 20 August 2026, by the same person, and published in Official Gazette of Romania no. 706 of 25 August 2026, provides in its Article II that on the date it enters into force the same entities „se înscriu, cu ajutorul sistemului informatic, în Registrul RO e-Factura obligatoriu”, are entered, with the help of the IT system, in the mandatory RO e-Factura Register. The result is two different dates for the same event, 25 August 2026 and 3 September 2026, and an association that reads only one of the two orders cannot know since when it has been in the mandatory register. The consequence is not theoretical: in the nine days between 25 August and 2 September 2026, the same entities figure simultaneously in both public registers, entered in the mandatory one by order 1.020 but not yet struck off the optional one, because the striking off operates only through the present order.

Editorial analysis

The two orders are a single reform cut into two pieces. Both bear the date of 20 August 2026 and the signature of the same person, both move associations without a VAT number from one register into the other, both change the name of a form in the same way, 081 in one, 082 in the other. The only difference between them is the day on which they reached the Official Gazette of Romania: 25 August 2026 for one, 3 September 2026 for the other. Nine days of lag on a text written in one go, which produce an overlap of registers that neither of the two acts provides for or resolves.

The deadline within which the administration was supposed to make this amendment had been set by Parliament. Article IV(2) of Law no. 88/2026, published in Official Gazette of Romania no. 459 of 29 May 2026 and in force from 1 June 2026, gave ANAF 30 days to rewrite the procedures of the three RO e-Factura registers, that is until 1 July 2026. The order was signed on 20 August 2026 and published on 3 September 2026, 64 days after the deadline expired. On the taxpayer, by contrast, the order imposes a rigid calendar in which one day of delay costs a whole month in the register. A form submitted on 30 September 2026 and one submitted on 1 October 2026 are one day apart, but a month apart in their effects.

On the substance, the order does the right thing. A voluntary register you cannot leave is not voluntary, and for two years, from July 2024, that is exactly what the situation was: form 081 had a single escape hatch, withdrawal of the application before the entry took effect, that is a window of at most one month. Section V closes the gap. What is not closed is the information reaching the person filling in the form. On the form, at section III, it is written in black and white that registration is made with the date of the 1st day of the following month. At section V, immediately below, nothing is written about the date, and the instructions for completion add nothing. The deadline appears a single time in the whole set, at point 141 of the procedure, in a document that the person ticking the box does not have in front of him.

What should be changed

  • The deadline, written on the form at section V. A single sentence, „Removal from the optional RO e-Factura Register is made with the date of the 1st day of the month following the filing of this application”, mirroring the one that already exists at section III. It would spare the applicant the search for point 141 in a separate annex.
  • Publication of paired orders on the same day. When two acts signed on the same day move the same entities from one register into another, the lag in publication creates a period in which they appear in both registers. A coordinated entry into force provision would have eliminated the nine days of overlap.
  • Stating the real date in Article II. The text ought to record that the entry in the mandatory register took place on 25 August 2026 through ANAF Order no. 1.020/2026, not order it a second time. As it is written, it leaves two possible dates for the start of the same obligation.
  • A rule for invoices in the waiting interval. Up to 30 days can pass between the day of the application and the date of exit. The act does not say what happens to invoices sent in that stretch, and the silence pushes every accountant to decide alone.
  • The date of entry and the date of exit, displayed in the public register. The registers are public precisely so that business partners know which way the invoice travels. A register that shows only current membership does not answer the question that matters in an audit, namely from what date the supplier was entered.
  • The title of the form, completed with withdrawal. The new name speaks of registration and of removal, but the form keeps withdrawal of the application at section IV, which is a third operation, with a different regime and a different deadline.

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. 743 of 3 September 2026 16 pages PDF, 173 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.