Declaration 394 (D394, Romania)

What Declaration 394 is

Declaration 394 (D394) is the Romanian recapitulative informational declaration of supplies and acquisitions performed on national territory between VAT-registered persons. It is filed monthly (by the 30th of the following month) through SPV and allows ANAF to run an automatic cross-check between what the supplier declares and what the buyer declares.

Who files D394

• All VAT-registered taxpayers in Romania (monthly or quarterly)

• Including micro-companies that are VAT-registered

• Not required from: non-VAT payers, individuals, public institutions outside VAT

What D394 contains

• Section C: B2B sales to partners with a tax ID

• Section D: B2B purchases from partners with a tax ID

• Section E: cash supplies/acquisitions (cash registers)

• Section F: adjustment, reverse and credit invoices

• For each partner: tax ID, taxable base, VAT amount, number of invoices

Relationship with e-Factura

Starting 2024, ANAF uses RO e-Factura data to pre-populate D394. Practically, if all B2B invoices are sent through RO e-Factura, ANAF builds D394 automatically - the operator only verifies and validates. For high volumes (>500 invoices/month), this cuts D394 prep time from 8-16 hours/month to 30 minutes.

Deadlines and penalties

• Filing deadline: day 30 of the month following the reporting period

• Failure to file: fine €2,500-€2,800 for legal entities

• Incorrect data / partner mismatches: trigger tax inspections and clarification requests

• Discrepancies over €200 between supplier and buyer → tax inspection almost guaranteed

How D394 is generated

1. The ERP / accounting system extracts every invoice issued and received in the period

2. Groups them per partner (tax ID) with total base + VAT

3. Generates the XML file per the ANAF schema

4. The operator signs it with a qualified digital certificate

5. Submits via SPV → SPV returns a receipt with the registration number

Common mistakes

1. "D394 = VAT journal" - false. The journal is internal; D394 is an external declaration to ANAF with a fixed XML structure.

2. "If I filed D300, I don't have to file D394" - false. D300 (VAT return) and D394 (recapitulative) are complementary, not alternatives.

3. "ANAF pre-population is perfect" - false. Pre-population only covers invoices sent through e-Factura; cash receipts (Section E) and pre-2024 invoices must still be entered manually.

4. "I can report rounded values" - false. ANAF cross-checks to the cent.