New fiscal amnesty proposed for 2026: who could be exempt from state penalties

A legislative proposal has been submitted to Parliament that could introduce a new tax amnesty, similar to the one implemented in 2024. The measure would target individuals, companies, and public institutions with outstanding debts to the state recorded up to 31 August 2026.

According to the draft bill, which can be consulted on the official Senate website, those with arrears could benefit from the full cancellation (100%) of interest, penalties, and late payment surcharges. The main condition is that the principal debt must be paid in full. Additionally, the individual or company must be up to date with current tax obligations, must have filed all required tax returns, and must submit the cancellation request within the deadline established by law.

The relief would apply to all claims administered by central, local, and customs tax authorities. For debts owed to local budgets, the application of the measure would be optional, to be decided by each local authority individually.

All categories of taxpayers could benefit from this amnesty: individuals, companies, those practising liberal professions, unincorporated associations, public institutions, and territorial-administrative units.

What the 2024 amnesty example shows

The bill's initiators are drawing on the model of the tax amnesty implemented in 2024. According to the explanatory memorandum, the Government reported uncollected budget debts of 175 billion RON at the time, of which a portfolio of 71.8 billion RON was deemed eligible for cancellation — 60.5 billion RON representing the principal amount and 11.3 billion RON in interest and penalties. The measure at the time targeted 330,735 legal entity taxpayers (companies) and 848,705 individual taxpayers, and the Government's estimate was that up to 15% of eligible claims would be collected.

What special circumstances are being considered

The draft law also sets out rules for particular cases, such as amended tax returns, assessments issued ex officio by ANAF, ongoing tax audits, insolvency situations, and existing payment facilities. Provisions are also made for notifying taxpayers, deferring the calculation of interest and penalties, and suspending enforcement proceedings — but only for amounts that could be cancelled; enforcement proceedings for the principal amount (the core debt) are not suspended.

The law also sets out the procedure for challenging the cancellation decision.

It is important to note that the following would not be cancelled: the principal debt itself, unlawfully received state aid or de minimis aid, interest accrued thereon, amounts from European funds that cannot be cancelled under EU legislation, criminal sanctions, and any other obligations for which cancellation is prohibited by law.