e-Factura for medical practices in Romania: a practical guide

Since 2025, almost every invoice issued by a clinic in Romania goes through RO e-Factura, including invoices to individual patients. If you manage a practice in Romania and your background is in another country’s system, this changes how you issue, correct and archive invoices. Below are the core rules, the problems that come up often in practice, and a checklist.

This article is for general information. Romanian tax law changes often, so check the current wording with your accountant before you change your invoicing flow.

What RO e-Factura is

RO e-Factura is the national system through which invoices are sent electronically to the Ministry of Finance (ANAF), which validates them and makes them available to the buyer. The main legal basis is Government Emergency Ordinance (GEO, in Romanian OUG) 120/2021, later amended by, among others, Law 296/2023 and GEO 115/2023.

In short, the system was phased in as follows:

• B2B (to companies): since 1 January 2024, invoices between businesses established in Romania must go through RO e-Factura, including invoices issued by taxable persons that are not registered for VAT.
• B2C (to individuals): since 1 January 2025, under GEO 115/2023, invoices to individual patients are also in scope.

The transmission deadline

The general rule is that the invoice must be sent to the system within 5 working days from the date it is issued. The deadline has been changed several times since the system was introduced, so confirm the current wording with your accountant. Keep public holidays and closures in mind too: if invoices pile up from a Friday to after a long weekend, the deadline gets closer faster than you expect.

How it works technically

The invoice is not sent as a PDF but as an XML file in UBL 2.1 format, following the Romanian national specification RO_CIUS. Access is through the Virtual Private Space (SPV, the ANAF online portal), using a qualified digital certificate. If you use invoicing software, you authorize it through ANAF’s OAuth mechanism so it can send invoices on behalf of the clinic.

A typical flow looks like this:

1. The software generates the XML file and uploads it.
2. ANAF returns an upload index, an identification number for the submission.
3. The software checks the invoice status periodically using that index.
4. The invoice is either validated or rejected with a list of validation errors.
5. If it is rejected, you correct the data and send it again. A rejected invoice counts as not sent, so the deadline keeps running.

What to archive

The invoice with legal value is the validated XML file, electronically signed by the Ministry of Finance. The PDF generated from it is useful for the patient, but it does not replace it. Keep the signed XML in the clinic’s archive for the full legal retention period for accounting documents, which you confirm with your accountant.

Specifics for clinics

VAT-exempt medical services

Most medical services are exempt from VAT under art. 292 of the Romanian Fiscal Code. A VAT exemption does not exempt the invoice from e-Factura: exempt invoices must also go through the system, with the correct exemption code. Watch out for services that may not qualify, for example some aesthetic procedures without a therapeutic purpose. Agree the treatment of each service with your accountant.

Patients who do not give their CNP

For invoices to individuals, the usual identifier is the CNP, the Romanian personal numeric code. If the patient does not provide it, the invoice can be issued using 13 zeros (0000000000000) in place of the CNP. Do not make the service conditional on the CNP just for the invoice, and do not ask for more data than you need. Foreign patients often do not have a CNP at all, so the same rule is useful for them.

Fiscal receipt and invoice

Many practices take payment from patients through a cash register (casă de marcat) and issue a fiscal receipt (bon fiscal). The rules on fiscal receipts and on e-invoices interact: there are cases where the patient asks for an invoice on top of the receipt, cases where the receipt counts as a simplified invoice, and cases the law treats differently. Do not assume the receipt automatically exempts you from e-Factura or the other way round. Your accountant should confirm the exact flow for your clinic, based on how you take payment and which documents you issue.

Patient or company

The same consultation can be invoiced to the patient or to a company, for example an employer, an insurer or another clinic that refers patients. The buyer data differs (CNP or company tax code CUI, address, name), and an invoice issued to the wrong buyer has to be reversed and reissued. Settle at the front desk, before the invoice is issued, who is paying.

Common problems in practice

Situation	What can go wrong	What you can do
Several locations	Invoice series mixed between sites	Use one invoice series per location
Wrong invoice	Correction on paper or in the PDF	Issue a reversal (storno) invoice and a new invoice, both through e-Factura
Rejected invoice	The deadline passes without anyone noticing	Check submission status and errors daily
Holidays and leave	Invoices not sent after days off	Name a person who checks submissions during these periods too
Expired digital certificate	The software can no longer send	Note the expiry date and renew early

Reversals (storno)

You cannot edit an invoice that has already been validated. If the amount, the service or the buyer is wrong, you issue a reversal invoice (with negative values), which also goes through e-Factura, followed by a correct invoice. Keep the link between the original invoice, the reversal and the new invoice, so it is easy to follow during an audit.

Series per location

For groups with several sites, separate series per location make it easier to reconcile payments and track errors. Numbering must stay continuous within each series. Decide on series together with your accountant.

Checklist

• You have a valid qualified digital certificate and SPV access for the clinic.
• Your invoicing software is authorized through ANAF OAuth and produces UBL 2.1 XML following RO_CIUS.
• Each service has its VAT treatment confirmed by your accountant, including the exemption code.
• The front desk knows when to invoice the patient and when to invoice a company.
• You have a rule for patients without a CNP (13 zeros).
• The receipt and invoice flow is confirmed in writing by your accountant.
• Someone checks rejected invoices daily and resends them within the deadline.
• The signed XML files are archived, not just the PDFs.
• You have separate series per location, if you run more than one site.

Clinesto issues invoices from the signed visit, with separate series per location, generates the e-Factura XML (UBL CIUS-RO) for each one and uploads it to the SPV once you authorise it with the clinic’s certificate. It checks the status every 10 minutes, keeps the signed response, shows rejection errors and turns them into a task, and receives supplier invoices from the SPV. The SPV upload runs as a pilot until it is confirmed on the ANAF test environment. The tax rules that apply to your clinic are still something you settle with your accountant.