Two procedures requiring separate assessment
The simplified procedure concerns liabilities administered by the central tax authority, within the limits and for the debtors specified in the Tax Procedure Code. Not every public debt or taxpayer is eligible.
The regime applicable from 2026 generally caps simplified arrangements at RON 100,000 for individuals and RON 400,000 for legal entities, covers debts no older than 12 months and allows a maximum 12-month repayment period. Legal entities must also satisfy the requirement to have been established at least 12 months before applying. The law excludes certain liabilities and circumstances.
The Code provides an exception for debtors exceeding the cap who have certain, liquidated receivables from public authorities or institutions: an arrangement may be granted up to the amounts certified by those bodies. Disputed sums are excluded.
Standard instalment arrangements and payment capacity
A standard arrangement may extend to five years under statutory conditions. Assessment concerns temporary financial difficulty, ability to meet the schedule and the security or surety required in the circumstances. The maximum period is not an automatic entitlement to five years.
Financial documents should realistically explain how instalments and current liabilities will be paid. Forecasts ignoring essential operating expenses or debts to other creditors may lead to the relief being lost after approval.
What to check before applying
Tax records must be reconciled with the taxpayer’s records: principal, ancillary amounts, returns, unallocated payments and disputed sums. Local debts require review of the local authority’s regime and procedure; ANAF rules do not automatically transfer.
Enforcement and any insolvency proceedings, other arrangements and liabilities excluded by law are relevant. The procedure should be chosen using current taxpayer information, not solely the total arrears.
Obtaining and maintaining an arrangement
Filing is not approval and should not be treated as a general stay of enforcement. The effect on enforcement depends on the mechanism sought and decisions issued by the tax authority.
After approval, instalments, current obligations and other validity conditions must be met. Interest and ancillary liabilities have their own regime; an arrangement does not itself cancel debt or provide cost-free financing.
Murar și Asociații assesses the legal framework, documentation and tax measures affecting the company, coordinating with financial specialists. Useful documents include the tax certificate, liability schedule, enforcement documents and payment forecast.
Useful questions
Do pandemic-era tax deferrals still apply?
Temporary 2020 relief cannot be used as a general basis for a 2026 application. The mechanism currently in force and the taxpayer’s circumstances must be checked.
Is a simplified instalment arrangement granted for five years?
No. Its maximum duration is 12 months; up to five years is available under the standard regime if statutory conditions are met.
Legal sources
- Tax Procedure Code — Law No. 207 of 20 July 2015, ANAF version updated by Emergency Ordinance No. 38/2026 — Articles 184–209 and 209¹–209¹⁴.
- ANAF — changes to instalment arrangements effective from 1 January 2026 — Press release of 13 January 2026.
This analysis provides general information by reference to the sources and date stated. Advice on a specific situation depends on the documents, applicable law and any transitional rules.