- Instruction No. 24/2020 requires banks and non-bank financial institutions to report, on every business day, electronically, every cashless payment of electronic invoices they make on behalf of their clients.
- This obligation falls on financial institutions, not on the businesses that use those services, but it has a direct practical consequence: the tax administration automatically receives data on every cashless payment related to your invoices.
- This is part of a broader data-matching mechanism that the tax administration uses to compare business filings with actual bank transactions.
- The more a business accepts payments via POS or transfer, the more important it becomes to reconcile the statements with that data.
Instruction No. 24, dated June 16, 2020, “On the Registration of Electronic Invoice Payments,” implements Article 37 of Law No. 87/2019 “On Invoicing and the Monitoring System of Turnover,” and requires banks, non-bank financial institutions, and other entities providing cashless payment services to record and report to the tax administration every business day every payment made on behalf of and for the account of their clients.
From our daily work, we see that businesses read this type of notice and consider it irrelevant to them, since it's addressed to banks, not to them. In fact, the practical consequence directly affects them, because every POS payment or bank transfer the business receives is automatically reported to the tax administration by the financial institution, regardless of the business itself.
What does the directive actually specify?
The obligation of financial institutions, not of businesses.
Reporting is carried out by the financial institution itself, electronically, by the end of each business day, with specific information for each invoice paid and the amount paid. The business has no additional action to take under this specific instruction, but it should be aware that it exists.
Why is it part of a broader cross-cutting mechanism?
This data is combined with other sources of information (electronic invoices, VAT returns, bank transactions) to create a complete picture of the business's actual activity. We have covered it in detail in What the tax administration sees in your business data.
Every time there is a tax or financial change that affects your business, we notify you directly by email with a practical explanation.
Send me free notificationsWhy does it matter today?
Cashless payments are on the rise for every business.
With the December 31, 2026 deadline for mandatory POS, many more businesses will accept card and transfer payments, which means the volume of data that financial institutions report to the tax authorities will increase significantly. We have explained the deadline and the criteria in POS mandatory for businesses.
How we handle this with our clients
We advise clients that the declared turnover should match the actual payments received via POS or bank transfer, precisely because the tax administration obtains this information automatically from financial institutions, not just from the business's self-reporting.
Frequently asked questions
Does the business need to do anything about this directive?
Not directly; the reporting obligation falls on banks and nonbank financial institutions. But the consequence is that the tax administration sees your payments, which directly affects you.
What happens if my statements don't match the reported payments?
A discrepancy may raise red flags for review. We recommend periodic verification of the match between the reported revenue and the actual payments received.
