Why a dedicated SAF-T guide for SRL
Lexter’s blog covers SRL incorporation, post-certificate steps (SPV, e-Factura), 1% micro regime, VAT, dividends, card payments, and suspension. SAF-T is mentioned briefly, but searches for “SAF-T mandatory 2026”, “Form 406 deadlines”, “D406 quarterly”, “SAF-T fines”, and “SAF-T company with no activity” become critical in 2026 — when grace periods expired and all legal entities must report.
Five dominant topics: (1) who files Form 406 and since when, (2) monthly vs quarterly periodicity, (3) the 2026 deadline calendar (including Q2 by 31 July), (4) Assets and Stocks sections, (5) zero filing, fines, and ONRC suspension exception. Data updated as of 21 July 2026.
1. Who files Form 406: all SRLs regardless of size or tax regime
From fiscal year 2026, Standard Audit File for Tax (SAF-T) reporting via informative Form D406 is mandatory for all legal entities — including small SRLs, micro-enterprises (1%), non-VAT payers, and newly incorporated companies — regardless of turnover or tax regime (ANAF Order 1783/2021, Annex 5).
Rollout was gradual: large taxpayers (2022), medium (2023), small (2025). From 2026, no accommodation periods or tolerance mechanisms remain for any taxpayer — non-filing triggers sanctions from the first reported period.
Filing is exclusively electronic via ANAF SPV with qualified e-signature — the same channel used for e-Factura and Form 700. See our post-incorporation guide for SPV activation after the ONRC certificate.
2. Monthly vs quarterly: periodicity follows VAT regime
D406 periodicity aligns with the VAT tax period, not accountant preference:
- Monthly — if VAT payer with monthly returns (turnover equivalent above EUR 100,000/year).
- Quarterly — if quarterly, half-yearly, or annual VAT payer.
- Quarterly — if non-VAT payer (most new SRLs in early months).
3. D406 deadlines in 2026: last day of the following month
Legal deadline: last calendar day of the month immediately following the reported period. If that date falls on a weekend or public holiday, the deadline moves to the next working day (general ANAF rule).
As of 21 July 2026, the imminent quarterly deadline is 31 July 2026 — Form 406 for Q2 (April–June 2026). Most new non-VAT SRLs and quarterly VAT payers should have already filed Q1 by 30 April 2026.
Indicative quarterly calendar 2026: Q1 (Jan–Mar) → 30 April; Q2 (Apr–Jun) → 31 July; Q3 (Jul–Sep) → 31 October (2 November if weekend); Q4 (Oct–Dec) → 31 January 2027 (1 February 2027 if weekend).
Monthly filing (July 2026 example): June → 31 July; July → 31 August; August → 30 September. Check your company’s personalized calendar in SPV.
4. Special sections: Assets (annual) and Stocks (on ANAF request)
Standard Form D406 contains structured accounting data (journal, master file, balances). Two sections have separate rules:
Assets — annual reporting at financial statements deadline (Form 101). For 2025 financial year, indicative deadline was 25 June 2026 (or next working day). No grace period applies.
Stocks — reported only upon express ANAF request, within at least 30 calendar days. Do not proactively report stocks in the regular D406.
The file must be valid: XML per OPANAF 1783/2021 schema, with error-free receipt in SPV. Accounting software or dedicated SAF-T apps generate the export.
5. Zero filing, ONRC suspension, and RON 1,000–5,000 fines
Active company with no transactions in a period: filing obligation remains. Submit an “empty file” — header + mandatory structures, no transaction lines. Opening balances (deposited share capital, incorporation expenses) may appear in the report. Non-filing triggers fines even if you issued no invoices.
Exception: company with ONRC-suspended activity and active ANAF derogatory regime — no D406 during suspension (Tax Procedure Code art. 101 para. (41), per Annex 5 update projects). See suspension/removal guide for the difference between active company with no revenue and officially suspended company.
Sanctions (Tax Procedure Code, art. 219 et seq.): non-filing — RON 1,000–5,000 per reported period; incorrect or incomplete data — RON 1,000–5,000 plus correction obligation. In 2026, grace periods expired — ANAF applies sanctions from the first non-compliant period.
Checklist: SAF-T for SRL (July 2026)
Follow these steps after the ONRC certificate:
- Confirm periodicity: monthly (monthly VAT) or quarterly (non-payer / quarterly VAT).
- Check next deadline in SPV — as of 21 July 2026: Q2 by 31 July for quarterly filers.
- Export SAF-T from accounting software (or empty file if zero activity).
- File D406 in SPV with qualified signature; keep error-free receipt.
- Plan Assets section at Form 101 deadline (25 June annually, prior year).
- If company is long-term inactive: evaluate ONRC suspension vs monthly/quarterly zero filing.
- Maintain consistency with e-Factura and tax returns (D100 micro, D300 VAT) — data cross-checks at audit.
Lexter and SAF-T
Lexter helps with SRL incorporation — articles of association, ONRC dossier, SPV setup data. It does not generate SAF-T files, file Form 406, or configure accounting software.
After the certificate, D406 reporting is your and your accountant’s obligation via ANAF SPV — whether you chose 1% micro or 16% profit tax.
Disclaimer
Informational guide as of 21 July 2026. ANAF Order 1783/2021, Annex 5, Tax Procedure Code, and SPV procedures may change. Verify anaf.ro. Not tax or accounting advice.
Frequently asked questions
- Is SAF-T mandatory for all SRLs in 2026?
- Yes. From fiscal year 2026, all legal entities — including small SRLs, micro, and non-VAT payers — file Form D406. Grace periods have expired.
- What is the D406 deadline for Q2 2026?
- 31 July 2026 (last calendar day of the month following April–June quarter). If it falls on a weekend, the deadline moves to the next working day.
- Do I file D406 monthly or quarterly?
- Follow your VAT tax period: monthly if monthly VAT payer; quarterly if quarterly/half-yearly/annual VAT payer or non-VAT payer.
- Must I file SAF-T if the company has no activity?
- Yes, if the company is active at ONRC — file an empty file (header + empty structures). Exception: ONRC suspension with active ANAF derogatory regime during suspension.
- What fine applies for not filing D406?
- RON 1,000–5,000 per reported period (month or quarter) for non-filing, per Tax Procedure Code. No grace period in 2026.
- How is this different from the post-incorporation guide?
- Post-incorporation covers SPV, e-Factura, and bank account. This guide details the separate SAF-T/D406 obligation — periodicity, deadlines, zero filing, and fines.
- Does Lexter file Form 406 for me?
- No. Lexter prepares SRL incorporation documents. SAF-T is generated from accounting and filed in SPV, usually by your accountant.