VAT refunds, the new deadline for updating CAEN codes, and anti-fraud checks

The end of September brought three legislative and tax updates with a direct impact on business operations. We have summarized them below, along with the key implications and recommended practical steps.

1. VAT refunds: stricter risk criteria
Effective immediately, VAT refund requests are being evaluated based on an expanded set of risk criteria. Order No. 1123/2026 issued by the President of ANAF (the National Agency for Fiscal Administration), published in the Official Gazette on September 28, 2026, applies to VAT returns covering August and the third quarter.

• ANAF has introduced 14 new scenarios that can trigger a “high-risk” classification for a refund request. These include financial difficulties faced by the company or its suppliers, failure to file tax returns, or the company having been established less than six months ago.
• An approved refund may be revoked if risk factors are identified at a later stage.

What do we recommend?

If you intend to claim a VAT refund via the tax return due on October 25, we recommend contacting us well in advance. We can review the status of your company and your key suppliers, and assist you in preparing the supporting documentation.

2. CAEN codes: the update deadline has been extended to March 25, 2027
You have an additional six months to update your company’s scope of activity with the Trade Register in accordance with the new CAEN Rev. 3 classification. The initial deadline of September 25, 2026, has been extended to March 25, 2027, via Government Decision no. 788, published on October 1, 2026.

Updating CAEN codes is not merely an administrative formality. It can impact your tax status, the authorizations required for your business operations, and your eligibility for certain types of funding.

What do we recommend?

Do not delay the update until the deadline approaches, as the volume of requests at the Trade Register may increase. If you have other changes to make—such as adjustments to share capital or the administrator’s mandate—these can be handled as part of the same procedure.

3. Anti-fraud checks in the used vehicle trade
The tax anti-fraud authority has launched “Operation ATOM,” an inspection campaign targeting the used vehicle trade. The first phase involves checks on 35 companies holding inventories estimated at over €38 million.

Inspectors are tracing the lifecycle of each vehicle—from acquisition and origin to final sale and payment collection. They are also comparing advertised prices against those recorded in commercial documents and verifying the application of the VAT margin scheme, as well as the documentation related to brokerage contracts.

Even if you do not operate in the vehicle trade, the selection method used in this operation is noteworthy: company-reported data is analyzed and cross-referenced with available market information.

Our recommendation?

If you operate in the automotive trade, we recommend verifying the existence and consistency of documentation for every vehicle: acquisition and origin records, sales documents, payment records, and—where applicable—supporting documentation for the application of the VAT margin scheme.