Main legislative changes of December 2025
I. Tax amendments and supplements introduced by Ordinance 89/2025
The Ordinance no. 89/2025 for the amending and supplementing of Law no. 227/2015 on the Fiscal Code, the regulation of certain budgetary fiscal measures, as well as for the amendment and completion of certain normative acts on the establishment of measures for the recovery and efficiency of public resources and for the modification and completion of certain normative acts was published in the Official Gazette, Part I no. 1203 of December 24, 2025.
Among the most important changes we mention the following:
1. Minimum turnover tax
Taxpayers who register a turnover of more than EUR 50,000,000 in the previous year and who in the calculation year determine a corporate income tax lower than the minimum turnover tax, are obliged to pay corporate income tax at the level of the minimum turnover tax. The tax rate for 2025 is 1% of the calculation base provided by the Fiscal Code.
For the 2026 fiscal year/amended fiscal year starting in 2026, the tax rate will be 0.5%.
The minimum turnover tax is to be eliminated starting with 2027/amended fiscal year starting in 2027.
Taxpayers who have decreased the value of fixed assets in progress/assets according to indicators I and A, have the obligation to keep the respective assets in the patrimony for the remaining period of the period equal to half of the period of economic use, established according to the applicable accounting regulations, but not more than 5 years. This obligation applies less to the following situations:
- they are transferred within the reorganization operations, carried out according to the law;
- are alienated in the liquidation/bankruptcy procedure, according to the law;
- are destroyed, lost, stolen or defective and replaced, provided that these situations are duly demonstrated or confirmed by the taxpayer;
- are removed from the patrimony as a result of the fulfillment of obligations provided by law.
The same rule applies to taxpayers who owed ICAS (Additional Tax for Legal Entities Operating in the Oil and Natural Gas Sectors).
The excess costs of indebtedness resulting from transactions/operations that financed the acquisition/production of assets in progress/assets are allocated in the following fiscal years, to the deductible ceiling represented by the RON equivalent of the amount of EUR 1,000,000.
2. Additional tax for legal entities operating in the oil and gas sectors
The period of application of the ICAS supplementary tax is extended until December 31, 2026/the last day of the amended fiscal year ending in 2027. The tax rate does not change, it will continue to be 0.5% of the calculation base, according to the provisions of the Fiscal Code.
3. Microenterprise income tax
Starting with January 1, 2026, the tax rate of 3% is eliminated. The tax rate of 1% is maintained, which becomes a single rate for all micro-enterprises, regardless of the activity carried out or the income achieved.
We remind you that this tax regime applies to Companies that have not exceeded the equivalent in lei 100,000 euros starting with January 1, 2026. The verification of the ceiling for 2026 is based on the income earned until December 31, 2025.
If the turnover recorded on December 31, 2025 exceeds the ceiling of 100,000 euros, the company will become a corporate income tax payer starting with January 1, 2026.
4. Income tax
Starting with January 1, 2026, the tax rate increases from 10% to 16% for:
- goods and/or services received by a participant in the legal entity, granted/provided by the legal entity for its personal benefit;
- the amount paid to a participant in a legal entity, for his personal benefit, for the goods or services purchased from him, above the market price for such goods or services.
5. Construction tax
The construction tax will apply only for 2026 and will be repealed again starting January 1, 2027. It was repealed in 2017 and reintroduced in 2025.
6. RO e-Invoicing
Starting with January 1, 2026, the deadline for submitting invoices in the national electronic invoice system RO e-Invoice, provided by Emergency Ordinance no. 120/2021, is 5 working days from the date of issuance of the invoice, but no later than 5 working days from the deadline for issuing the invoice. Previously, the deadline was 5 calendar days from the date of issue.
7. RO e-VAT
Amendments are made to the level of the Emergency Ordinance no. 70/2024 as follows:
- the application of RO e-VAT for VAT on collection is suspended until September 30, 2026
- and several obligations and notifications are repealed, such as the obligation of taxpayers to respond to RO e-VAT compliance notifications.
8. Tax benefits regarding the taxation of the minimum wage in 2026
The exemption from income tax and social contributions for the amount of 300 lei/month between January and June 2026 and 200 lei/month between July and December 2026 continues to apply, in compliance with the conditions provided by law. In order to benefit from this exemption, the minimum gross monthly salary established according to the individual employment contract must not be reduced, without including bonuses and other additions.
Starting with July 1, 2026, the value of the minimum wage will increase from 4,300 lei to 4,600 lei.
II. Changes to the VAT registration procedure
The Order no. 2.633/2025 for the amendment and completion of certain normative acts regarding the registration/cancellation of registration for value added tax purposes and regarding the declaration of value added tax, in the Official Gazette, Part I no. 1.166 of December 16, 2025.
Changes are made to the VAT registration procedure, the procedure for the ex officio cancellation of VAT registration, as well as VAT declaration and reporting through the VAT return – for taxable persons with economic activity in Romania or non-resident persons carrying out activities in Romania.
III. Stimulating cooperation between national tax authorities
The Emergency Ordinance no. 71/2025 for amending and supplementing Law no. 207/2015 on the Fiscal Procedure Code, in the Official Gazette, Part I no. 1146 of 10 December 2025.
Ordinance no. 71/2025 transposes into Romanian legislation the EU Directive DAC8 no. 2023/2226 on administrative cooperation in the field of taxation. The changes mainly relate to the automatic reporting and exchange of information on income from crypto-asset transactions and on advance tax rulings for the wealthiest (with high financial resources).
This ordinance provides for the obligation of crypto-asset service providers in Romania to submit information to ANAF, in order to correctly identify the revenues obtained through these transactions.
IV. Approval of the new model of Single Declaration 212 form
The new form of the Single Declaration (212) for the income earned in 2025, updated according to Order no. 2736/2025 for the approval of the model, content, method of submission and management of the form, has been published in the Official Gazette, Part I, no. 1207 of December 29, 2025.
The form is used by individuals to declare the income tax and social contributions due starting with 2025, as well as for declaring the health insurance contribution due by individuals who opt for the payment of the contribution, starting with 2026. Also, the obligation to declare the estimated income for 2026 was eliminated.
The deadline for submitting the Single Declaration is May 25, 2026 for income obtained in 2025.
V. Approval of the Nomenclature of Independent Activities
The Nomenclature of independent activities for which the net income can be determined based on the annual income norms, activities carried out by taxpayers who earn income from production, trade, service provision activities, was approved by Order no. 1.960/2025 published in the Official Gazette, Part I, no. 1215 of December 30, 2025.
VI. Approval of the quota of foreign workers for 2026
For 2026, a quota of 90,000 foreign workers newly admitted to the Romanian labor market is established, by Decision no. 1169/2025, published in the Official Gazette, Part I, no. 1221 of December 31, 2025.
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