ANAF expands risk analysis for VAT refunds / Companies must reconcile their tax data

Riana Gegiu

22 October 2026, 12:02

Economy

Foto: Facebook/ Agenția Națională de Administrare Fiscală

Always see our news on Google

ANAF has expanded, through Order No. 1,123/2026, the risk analysis applied to VAT refund claims, and companies must more carefully verify the consistency of the data reported before submitting their applications. The new rules examine not only the tax position of the company and its suppliers, but also discrepancies between declarations, the authority’s electronic systems, and changes in the amounts requested.

The analysis may include information from the D300 VAT return, RO e-Factura and RO e-Case de marcat, as well as significant increases in refund claims or substantial adjustments. Discrepancies do not automatically indicate a tax error, but they must be identified, explained and documented.

In this context, tax reconciliation should become a preventive process, rather than merely a check carried out at the end of the reporting period. Companies are encouraged to compare their accounting records and VAT ledgers with data from ANAF systems, verify relevant suppliers, and document the transactions that generated the balance requested.

The new checks may also affect cash-flow estimates, particularly for companies that depend on recovering significant amounts. Data control requires cooperation between the finance, tax, procurement and IT departments.

وع,

Context: ANAF’s announcement regarding risk criteria for VAT refunds was accompanied by warnings about bottlenecks and audits of deductions

Before expanding the risk analysis for VAT refund applications, the Chamber of Tax Consultants drew attention to the new criteria established by Order No. 1123 of September 21, 2026, and warned that tax inspections could occur even at companies that comply with their obligations. CCF cited as possible examples factors that companies cannot control, such as the existence of a minority shareholder in an unpublished ANAF database or subsequent tax problems involving suppliers. The organization also complained about the lack of clear thresholds and justification for the 24 risk indicators, calling for individual analysis and the possibility of challenging decisions.

Alongside this type of verification, ANAF announced targeted audits of companies that purchased luxury goods or carried out leisure-related improvements, in order to determine whether these are used in their economic activity or for personal purposes. In cases where the goods do not serve the business activity, the expenses would not be deductible, and the VAT could not be recovered, with the additional risk of tax liabilities arising from benefits granted through personal use.