Through our continuous monitoring of e-invoicing legislation, EESPA has analysed the Romanian e-invoicing system. Our conclusion is that Romania is on the verge of rolling out a system that by design contradicts the automation objective that is central to the pursuit of many other tax administrations in digitizing VAT and invoicing processes. By harvesting data from the actual source system performing invoicing transactions, in real time, these tax administration platforms remove much of the human factor in data processing, which simultaneously boosts efficiency and reduces fraud and errors. 

Our evaluation of the Romanian system and access options to the SPV account demonstrates that Romania will miss out on these fundamental fiscal and economic benefits. Key design principles such as the option for taxpayers to outsource invoicing processes to professional third parties in an easy and secure manner, appear not to have been sufficiently considered in this context. 

Since automation of business processes is an important part of the digitization efforts currently ongoing in the EU (including the EU Commission’s VAT in the Digital Age project) EESPA would like to ask for an opportunity to discuss these issues with representatives of ANAF and perhaps assist with insights gained from more than a decade of close collaboration with tax administrations and other public and private sector stakeholders. 

Given the timing of the introduction of the mandates for B2G and B2B supplies of fiscal high-risk products in Romania, we would be grateful for an opportunity to have a dialogue on the above topics. In our opinion, it would be preferable if Romania modified these aspects of is e-invoicing system prior to the mandate taking full effect – even if this means postponing entry into force in order to start off with an approach that is aligned with the European and global trend towards continuous transaction controls.