Starting January 1, 2026, several changes introduced in 2022 through Government Ordinance no. 188/2022 to the Fiscal Procedure Code have finally become applicable. These updates impact how tax inspections are organized and conducted by ANAF (the National Agency for Fiscal Administration) and mark a significant shift aimed at improving transparency, predictability, and fairness in the relationship between the state and taxpayers.
Below, we explain clearly what these changes mean, define the key terms, and show how individuals and businesses can prepare for tax inspections in the coming years.
 
What is a tax inspection?
A tax inspection is a verification carried out by ANAF on taxpayers to determine the correctness of their tax declarations, the existence of tax liabilities, and compliance with legislation. There are three types of inspections:
  • General – all tax obligations are reviewed;
  • Partial – only some obligations, periods, or types of taxes are checked;
  • Documentary – based solely on available documents, without an on-site visit.
     
What are the new rules valid from January 1, 2026?
1. Control programs are set at the national level
Until now, tax inspections were scheduled at the regional or local level. Starting in 2026, all inspections will be coordinated centrally by ANAF’s main office, based on a single national control program.
This program relies solely on risk analysis, meaning an evaluation of each taxpayer’s fiscal behavior based on financial indicators, type of activity, declaration history, etc.
📌 What does this mean for taxpayers?
Tax audits will no longer depend on local decisions but will follow a national, unified system. This increases predictability and reduces the risk of inconsistent interpretations across different regions.
 
2. Taxpayers will mainly be selected based on risk level
From 2026, ANAF is required to select at least 90% of taxpayers for inspection based on identified fiscal risk. Only up to 10% may be selected randomly.
If the 10% threshold for random selection is exceeded, it will be considered a disciplinary offense for tax inspectors, and ANAF management must apply sanctions.
📌 Why is this important?
Selection becomes more objective. If your business or personal finances don’t raise risk indicators (e.g., major discrepancies between income and expenses), the likelihood of being selected for an audit is significantly lower.
 
3. National competence for tax inspectors
The law now explicitly states that tax inspectors have jurisdiction across the entire territory of Romania, regardless of where the taxpayer is registered.
This rule also applies to documentary verifications, not just in-person inspections.
📌 What does this mean in practice?
You may be audited by an ANAF department from another city or county, making it essential to organize your documents and ensure smooth digital communication with authorities.
 
4. You can request information on your fiscal risk classification
A key update allows each taxpayer to request their risk classification (e.g., low, medium, or high risk), as determined by ANAF’s periodic risk analyses.
This information must be communicated through any method that provides proof of receipt (e.g., email with confirmation, registered mail), unless public interest justifies limiting access to this information.
📌 How is this useful?
If you’re a business owner or individual taxpayer, you can request this classification before being selected for a tax audit. This gives you the chance to understand what might expose you to risk and correct any issues before they attract penalties.
 
Practical example:
A company in e-commerce with rapidly growing revenues and large payments to foreign suppliers may be considered high-risk, especially if it files tax returns late or shows major differences between collected and deducted VAT. Based on the risk analysis, the company may be included in the national control plan and selected for an audit in 2026.
If the administrator requests risk classification in advance and identifies red flags, they can contact a tax consultant or accountant to correct any issues.
 
What do these changes mean for you?
✅ Whether you're a business owner, accountant, or freelancer, you need to know that ANAF is becoming more organized, digital, and focused on real risks. This benefits compliant taxpayers but also increases scrutiny for those with poor tax management.
 
How can you prepare?
  • Make sure all tax returns are submitted correctly and on time.
  • Periodically review your company’s fiscal position with a specialist.
  • Request your fiscal risk classification from ANAF.
  • Keep all supporting documents accessible and well-organized.
  • Be proactive - if there are risks or uncertainties, seek expert advice.
     
 
Our recommendation
To make the best decisions for yourself and your business, it is essential to work with specialists who fully understand tax law and the changes coming in 2026.
📞 Contact the Financess team for personalized assistance:
Phone: (+40) 749 097 969
Email: contact@financess.ro