Because of its complexity and impact, the SAF-T reporting gave rise to intense discussions in the Romanian economic environment. Since there is a natural association between SAF-T and ERP systems, especially for large and medium-sized taxpayers, we receive many questions on this topic. We have thus noticed that there is a lot of confusion and that many companies are not prepared for this new type of reporting.
We have put together a selection of frequently asked questions about SAF-T reporting, to which you will find answers below. We’ll approach them one at a time.
- Is it true that the D496 statement contains all the accounting records of a company?
That is almost true, meaning that the Informative Statement D406 (SAF-T reporting) includes a very large volume of records. There are over 800 types of accounting and tax data, which implies that virtually all accounting records in the reporting period (month or quarter) will be transferred to the authorities. This is probably the most complex report ever requested by the tax authorities.
- How do I know if SAF-T reporting is mandatory for my company?
Communication has been quite straightforward in this sense. Still, there are some uncertainties about the submission deadlines. Therefore, according to ANAF, the obligation to submit the Informative Statement D406 belongs to all Romanian legal entities and to those units without Romanian legal personality of the foreign legal entities that have the obligation to keep their accounting in the double-entry system.
The deadline by which companies are required to report in the SAT-F format is rather unclear, and there have also been some changes in the taxpayers’ classification. For large taxpayers, the SAF-T reporting is already mandatory starting January 1, 2022, with the mention that for companies that were not listed as large taxpayers in 2021, the deadline is July 1, 2022. For mid-sized taxpayers, the deadline is January 1, 2023, while for small taxpayers it’s January 1, 2025.
- What data must the SAF-T statement contain and where is it taken from?
As said before, there are about 800 types of data, some of them mandatory and some optional, grouped into several categories: Master Files (Accounting Accounts / Accounting Journal, Customers, Suppliers, fees, measurement units, cost centers, stock movements), Accounting Records – Accounting Journal (transactions, analytical accounts), Source Documents (sales invoices; purchase invoices; Payments; Movements of goods; Transactions with assets). Also, the Fixed Assets Register must be reported annually, and the inventory and the movements of stock at the request of the authorities.
- Can I get the D406 statement in SAF-T format without an ERP system?
Given the scale of the records, we do not believe that a company with more than 10 employees and a turnover of over 2 million Euros (approximate European classification for SMEs) can obtain the D406 statement only with the help of a simple accounting application. An integrated management system is obviously needed for its capacity to record, process, and generate the data associated with the SAF-T report.
- How do I identify in the ERP system the data that is required to complete the D406 statement?
SAP Business One, for example, allows getting the statement in the SAF-T format, and data is automatically collected and validated based on computational algorithms. Without such a functionality, mandatory and optional data fields must be manually identified, and validity and structure of the data must be verified for compliance with ANAF requirements. Partial or incorrect transmission of data is penalized by ANAF, and the statement must be resubmitted.
- My ERP system does not have all the data fields corresponding to the D406 statement. What do I have to do?
Not all ERP systems are ready for SAF-T reporting. If you are in such a situation, you have two options: A: Use some of the existing fields not used for other purposes for SAF-T associated records, or add new fields through software development. B: Change the ERP system and move to a more performing one.
- In which currency is the SAF-T statement declared??
RON (Romanian Leu) is the currency of the statement but for transactions in other currencies, such as EUR, USD or GBP, the currency of the document, the value in the foreign currency as well as the exchange rate must also be declared.
- How do I upload the 406 statement?
The submission procedure is similar to other ANAF reports. The document and the associated XML file are uploaded on the ANAF website based on a digital signature. The website offers a receipt and the possibility to validate the recorded data. The existence of errors leads to warnings/penalties and the re-submission of the statement.
- The 406 Statement attaches particular importance to stocks. What happens with stocks that are not owned by the company but are received for processing or custody?
The SAF-T scheme includes several fields related to stocks and their circulation. Taxpayers will report any movement of stocks, both in terms of quantity and value, alongside with other information such as: identification codes, warehouse IT, unit prices, etc. The statement also includes a subsection for reporting stocks made available to the company, without the company actually owning them: stocks in custody, stocks in consignment, goods received for processing, returnable packaging, etc. The section will be associated with account 8028 (Goods received under administration, concession, or lease) and will mention the legal owner of the stocks.
- Companies are already submitting a series of VAT statements. Will they remain active after the implementation of SAF-T?
Most likely these forms /statements will overlap for a while, but ANAF plans to give up other VAT-related statements in the future. However, removing other redundant statements will only be possible after the authorities have tested and validated the reliability of the SAF-T format. This time horizon is unknown at the moment.
Surely you have other questions about the D406 statement and the SAF-T format. Whether technical or business-related, a consultant from System Innovation will help you find the information you want.