Must a small company or a sole trader file SAF-T (D406)?
The dividing line is not large versus small, but double-entry versus single-entry bookkeeping. A small company files D406; a single-entry sole trader has nothing to report in it.
Short answer
- Yes, a small company files D406: small taxpayers came into SAF-T scope on 1 January 2025.
- No, a sole trader on single-entry bookkeeping does not file D406.
- The criterion is keeping double-entry books and preparing financial statements, not the size of the business.
- For quarterly filing, the 2026 deadlines are 30 April, 31 July, 2 November 2026 and 1 February 2027.
- Failure to file is fined 1,000–5,000 lei; an incorrect or incomplete filing 500–1,500 lei.
What the law says
- D406 is the informative return through which the standard audit file for tax (SAF-T) is submitted.
- The obligation was phased in: large taxpayers first, then medium ones, and small taxpayers from 1 January 2025.
- The penalties are set out in art. 337^1 of the Fiscal Procedure Code.
- The Assets section is reported annually, and the Inventory section only on express ANAF request, with at least 30 days allowed.
- When a filing deadline falls on a non-working day, it moves to the next working day.
Who files, and when
D406 obligation by legal form
| Who | Files D406? | Reason |
|---|---|---|
| SRL, even small or micro | Yes | Keeps double-entry books and prepares financial statements |
| Sole trader, single-entry | No | Keeps no double-entry books and files no balance sheet |
| Sole trader opting for double-entry | Yes | The criterion is how the books are kept, not the legal form |
| Dormant SRL | Yes, at zero | The obligation does not depend on there being transactions |
Practical examples
- An SRL with two employees and 300,000 lei of turnover files D406 quarterly, on the deadlines above.
- A consulting sole trader with 250,000 lei of income does not file D406, whatever the amount.
- An SRL that issued no invoices in a quarter still files D406, with its sections at zero.
- The Inventory section is not sent proactively: only if ANAF expressly requests it.
Common mistakes
- Assuming a small company or a micro-enterprise is exempt — small taxpayers have been in scope since 2025.
- Looking for the obligation by turnover, when the criterion is how the books are kept.
- Skipping the zero filing for a dormant company, which attracts a fine although there were no transactions.
- Filing a file with validation errors and treating the obligation as met — an incorrect filing has its own penalty.
How 4conta helps
4conta builds the SAF-T file from the same ledger entries it uses for the trial balance and the annual accounts, so there is no second data source to drift from the first. Validation runs before filing, so a structural error does not become a penalised incorrect filing.
The quarterly deadlines enter the filing calendar together with the next-working-day rule, and the Assets section is flagged as a separate annual obligation.