# Romania’s tax code promises six months’ notice. It usually gives three days.

Romania’s Fiscal Code, 2016–2026 · 149 acts, each one measured

Article 4 of Romania’s Fiscal Code promises that a law changing it takes effect at least six months after it appears in the Monitorul Oficial, the official gazette, and a government ordinance at least 15 days after. Since 2016 the Code has been changed by 149 acts. Of the 78 laws, only four left six months before the first new rule; of the 71 ordinances, only six left 15 days. For half of all 149, the new rule applied within three days.

## The six months

- Day 0. For 44 acts, the first new rule applied on the very day the act appeared in the Monitorul Oficial. Nearly all are government emergency ordinances: decrees with immediate force of law, later approved or rejected by Parliament, which take effect on publication unless they set a later date.
- Day 3. By day 3, 113 of 149 had applied. A Romanian law takes effect three days after publication unless it sets a later date. The Code asks every law that changes it to set one: six months away.
- Day 8. On 24 December 2025 an emergency ordinance appeared with new rules from 1 January 2026: eight days, Christmas and New Year included. It is not the only one: nine acts appeared in the last two weeks of a year, for 1 January.
- Day 15. The minimum the Code accepts for ordinances. 125 of 149 acts had already applied before reaching it.
- Day 52. Autumn 2017: the ordinance that moved almost all social contributions from employers to employees and cut income tax from 16% to 10% appeared on 10 November, for 1 January. It was one of the largest rewrites of the Code, 193 changes.
- Three months. Halfway. Only seven acts had not yet applied.
- Six months. The promise. Only four acts of 149 got this far.

## The day the rule itself changed

On 20 September 2023 the government adopted an emergency ordinance with a single article. It rewrote paragraph (4) of Article 4, the exceptions to the six-month promise. It appeared in the Monitorul Oficial that same day and applied from that same day.

The new text lets new or higher taxes arrive sooner than six months “exclusively in extraordinary situations of excessive budget deficit procedure”. The European Union’s excessive deficit procedure against Romania was opened in April 2020 and was still running in 2025.

## Christmas rules

Nine times since 2016, the next year’s rules appeared in the Monitorul Oficial in the last two weeks of December and applied from 1 January. The most recent appeared on 24 December 2025. 1 January is the date the Code requires for new or higher taxes (Article 4(2)); the required notice is missing.

## One sentence, again and again

Almost half the acts do not even hide it. 73 of the 149 state in writing that they apply “by derogation from the provisions of Art. 4 of Law no. 227/2015” (Law 227/2015 is the Fiscal Code), that is, bypassing the very article that promises the notice. Of those, three still gave the required notice. Another 69 gave less than the Code requires for their kind of act, without saying so. Only 10 of 149 gave the notice required.

Below, the sentence as it appears in each of the 73 acts, in the order they appeared. It is quoted in the original Romanian.

## What changed for you

Pick your situation. The threads that concern you stay lit in the chart above, and your numbers appear here.

## The Code, article by article

Each line below is one article of the Code, in order; the darker it is, the more acts have changed it since 2016. 504 of 642 articles have been changed at least once. Most often: Article 25, the expenses a company may deduct from profit (21 acts), Article 291, the VAT rates (20 acts) and Article 456, exemptions from the tax on buildings (20 acts).

## Every act, one by one

For each act: when it appeared in the Monitorul Oficial, after how many days its first new rule applied, how many changes it made to the Code, and whether it wrote that it departs from Article 4.

- 22 October 2026: Law 204/2026, 3 days
- 15 October 2026: Law 202/2026, 78 days
- 15 October 2026: Law 199/2026, 3 days
- 5 August 2026: Law 170/2026, 3 days
- 8 May 2026: Emergency Ordinance 38/2026, same day
- 16 April 2026: Emergency Ordinance 26/2026, same day
- 9 March 2026: Emergency Ordinance 13/2026, 22 days
- 27 February 2026: Emergency Ordinance 9/2026, same day
- 25 February 2026: Emergency Ordinance 8/2026, same day
- 25 February 2026: Emergency Ordinance 7/2026, same day
- 30 January 2026: Ordinance 6/2026, same day
- 24 December 2025: Emergency Ordinance 89/2025, 8 days
- 17 December 2025: Emergency Ordinance 78/2025, 1 day
- 15 December 2025: Law 239/2025, 3 days
- 8 December 2025: Emergency Ordinance 68/2025, 7 days
- 29 August 2025: Ordinance 22/2025, 3 days
- 25 July 2025: Law 141/2025, 7 days
- 4 April 2025: Emergency Ordinance 21/2025, same day
- 13 March 2025: Emergency Ordinance 11/2025, same day
- 12 March 2025: Law 14/2025, 3 days
- 31 January 2025: Ordinance 3/2025, 3 days
- 31 December 2024: Emergency Ordinance 156/2024, 1 day
- 23 December 2024: Law 317/2024, 3 days
- 17 December 2024: Law 313/2024, 3 days
- 9 December 2024: Law 309/2024, 3 days
- 5 December 2024: Emergency Ordinance 138/2024, same day
- 22 November 2024: Emergency Ordinance 132/2024, 40 days
- 21 November 2024: Law 290/2024, 41 days
- 11 November 2024: Emergency Ordinance 128/2024, 51 days
- 24 October 2024: Emergency Ordinance 123/2024, same day
- 8 October 2024: Law 254/2024, 85 days
- 26 September 2024: Emergency Ordinance 115/2024, same day
- 5 September 2024: Law 244/2024, 26 days
- 29 July 2024: Emergency Ordinance 100/2024, same day
- 27 June 2024: Law 204/2024, 3 days
- 26 June 2024: Emergency Ordinance 78/2024, 5 days
- 21 June 2024: Emergency Ordinance 70/2024, 10 days
- 20 June 2024: Law 192/2024, 195 days
- 7 June 2024: Emergency Ordinance 59/2024, 13 days
- 30 April 2024: Emergency Ordinance 43/2024, same day
- 12 April 2024: Emergency Ordinance 34/2024, same day
- 3 April 2024: Law 74/2024, 3 days
- 29 March 2024: Emergency Ordinance 31/2024, same day
- 29 March 2024: Emergency Ordinance 30/2024, same day
- 25 March 2024: Emergency Ordinance 26/2024, same day
- 5 March 2024: Law 33/2024, 3 days
- 18 January 2024: Emergency Ordinance 2/2024, same day
- 15 December 2023: Emergency Ordinance 115/2023, same day
- 27 October 2023: Law 296/2023, 5 days
- 20 October 2023: Law 282/2023, 73 days
- 20 September 2023: Emergency Ordinance 74/2023, same day
- 11 July 2023: Law 216/2023, 3 days
- 12 April 2023: Law 88/2023, 60 days
- 30 March 2023: Law 69/2023, 3 days
- 13 January 2023: Law 39/2023, 3 days
- 12 January 2023: Law 34/2023, 3 days
- 20 December 2022: Law 370/2022, 3 days
- 9 December 2022: Emergency Ordinance 168/2022, same day
- 17 November 2022: Law 309/2022, 410 days
- 17 November 2022: Law 301/2022, 3 days
- 31 August 2022: Ordinance 37/2022, 15 days
- 27 July 2022: Law 266/2022, 3 days
- 25 July 2022: Law 247/2022, 3 days
- 22 July 2022: Law 252/2022, 3 days
- 15 July 2022: Ordinance 16/2022, 3 days
- 24 June 2022: Emergency Ordinance 87/2022, same day
- 17 June 2022: Emergency Ordinance 85/2022, same day
- 23 May 2022: Law 142/2022, 223 days
- 17 May 2022: Law 135/2022, 3 days
- 26 April 2022: Law 112/2022, 3 days
- 31 March 2022: Law 72/2022, 3 days
- 9 March 2022: Law 48/2022, 3 days
- 8 March 2022: Emergency Ordinance 20/2022, 3 days
- 31 January 2022: Ordinance 11/2022, 3 days
- 28 January 2022: Ordinance 4/2022, 4 days
- 30 December 2021: Law 322/2021, 3 days
- 18 December 2021: Emergency Ordinance 130/2021, same day
- 17 December 2021: Law 301/2021, 3 days
- 10 December 2021: Law 291/2021, 22 days
- 9 December 2021: Law 287/2021, 3 days
- 9 December 2021: Law 286/2021, 3 days
- 31 August 2021: Ordinance 8/2021, 3 days
- 28 June 2021: Emergency Ordinance 59/2021, 3 days
- 29 March 2021: Emergency Ordinance 19/2021, same day
- 26 February 2021: Emergency Ordinance 13/2021, same day
- 31 December 2020: Emergency Ordinance 226/2020, 1 day
- 21 December 2020: Law 296/2020, 3 days
- 20 November 2020: Law 262/2020, 3 days
- 20 November 2020: Law 258/2020, 3 days
- 13 November 2020: Law 248/2020, 49 days
- 6 November 2020: Law 241/2020, 56 days
- 6 November 2020: Law 239/2020, 3 days
- 4 November 2020: Law 230/2020, 58 days
- 26 October 2020: Emergency Ordinance 181/2020, same day
- 27 July 2020: Law 155/2020, 3 days
- 24 July 2020: Law 153/2020, 3 days
- 15 July 2020: Law 131/2020, 3 days
- 6 July 2020: Law 104/2020, 3 days
- 26 May 2020: Law 68/2020, 3 days
- 14 May 2020: Emergency Ordinance 70/2020, same day
- 14 May 2020: Emergency Ordinance 69/2020, same day
- 16 April 2020: Emergency Ordinance 48/2020, same day
- 1 April 2020: Law 32/2020, 3 days
- 31 January 2020: Ordinance 6/2020, 3 days
- 9 January 2020: Emergency Ordinance 1/2020, same day
- 31 December 2019: Emergency Ordinance 89/2019, same day
- 30 December 2019: Law 263/2019, 2 days
- 18 October 2019: Law 185/2019, 3 days
- 11 October 2019: Law 179/2019, 3 days
- 8 October 2019: Law 172/2019, 3 days
- 26 July 2019: Law 156/2019, 3 days
- 21 June 2019: Emergency Ordinance 43/2019, 30 days
- 30 May 2019: Emergency Ordinance 35/2019, same day
- 23 May 2019: Emergency Ordinance 31/2019, 9 days
- 19 April 2019: Emergency Ordinance 26/2019, 12 days
- 17 April 2019: Law 60/2019, 3 days
- 17 January 2019: Law 30/2019, 3 days
- 10 January 2019: Law 13/2019, 3 days
- 29 December 2018: Emergency Ordinance 114/2018, same day
- 28 December 2018: Law 354/2018, 4 days
- 3 December 2018: Law 285/2018, 3 days
- 9 October 2018: Emergency Ordinance 89/2018, same day
- 25 July 2018: Law 198/2018, 3 days
- 17 July 2018: Law 175/2018, 168 days
- 22 June 2018: Law 145/2018, 3 days
- 17 May 2018: Law 111/2018, 3 days
- 30 March 2018: Emergency Ordinance 25/2018, same day
- 23 March 2018: Law 72/2018, 3 days
- 23 March 2018: Emergency Ordinance 18/2018, same day
- 8 February 2018: Emergency Ordinance 3/2018, same day
- 10 November 2017: Emergency Ordinance 79/2017, 52 days
- 7 November 2017: Law 209/2017, 55 days
- 2 October 2017: Law 196/2017, 91 days
- 31 August 2017: Ordinance 25/2017, 3 days
- 25 July 2017: Ordinance 4/2017, 7 days
- 21 July 2017: Law 177/2017, 3 days
- 14 June 2017: Law 136/2017, 3 days
- 19 May 2017: Law 107/2017, 3 days
- 14 April 2017: Law 61/2017, 262 days
- 28 March 2017: Law 26/2017, 3 days
- 30 January 2017: Emergency Ordinance 9/2017, same day
- 12 January 2017: Law 2/2017, 3 days
- 6 January 2017: Emergency Ordinance 3/2017, same day
- 6 December 2016: Emergency Ordinance 84/2016, same day
- 5 September 2016: Emergency Ordinance 46/2016, same day
- 30 June 2016: Emergency Ordinance 32/2016, same day
- 30 May 2016: Law 112/2016, 3 days
- 14 April 2016: Law 57/2016, 120 days
- 25 March 2016: Emergency Ordinance 8/2016, same day

## The exceptions the Code grants itself

Article 4 itself sets two exceptions to the six months and to the 1 January rule. The first, from the start: changes that follow from Romania’s international commitments. The second, since September 2023: new or higher taxes, “exclusively in extraordinary situations of excessive budget deficit procedure”.

There is a legal limit too: Article 4 sits in an ordinary law, and a later law or ordinance can override it. The promise binds only as far as the next lawmaker honours it.

Some acts transpose EU directives and may fall under the first exception. Even so, only 10 of 149 gave the notice the Code requires for their kind of act.

## How it was measured

Romania’s official legislation portal (legislatie.just.ro) publishes the Fiscal Code in every consolidated form: 93 versions, from 1 January 2016 to 25 October 2026. After each changed paragraph the portal notes the date the new text applies from and the act that changed it, with the number and date of the Monitorul Oficial issue it appeared in. Notes from every version were gathered and deduplicated, so that changes later rewritten again still count: 2,810 changes from 149 acts.

An act’s notice is the number of days between its gazette date and the date its first new rule in the Code applies; “six months” means six calendar months from publication. This is strict with the acts: a law that changes one thing in three days and another in a year counts as three days, the first thing anyone has to adapt to. Laws are measured against six months, ordinances against 15 days. Counted change by change, the median notice is seven days.

Laws that approve an ordinance and change its text again are separate acts. The two acts published before 2016, when the Code did not yet apply, are left out. Derogation sentences were searched for in the full text of every act. The often-quoted figure of 554 amendments up to 2023 comes from a Tax Institute study reported by CursDeGuvernare in September 2023; this page counts something else: days.

The portal has no consolidated versions between December 2016 and January 2021, so a change made in those years and rewritten before 2021 left no note. The list was therefore checked another way: a full-text search of the laws and ordinances that mention Law 227/2015 (for 2016–2020 every one the portal returned; from 2021, those about taxes, years in which consolidated versions are at most four months apart) found seven acts more acts that amended the Code without appearing in the notes. Their dates were read from each act’s own text, and their changes counted from the act’s numbered points. For acts from those years whose portal note gave a later date than usual, the date of the first new rule was checked against the act’s text. Acts that only postpone a deadline in the Code or suspend one of its rules, without changing its text, are not counted.

Some acts say a rule applies to income from a given month, or to applications filed after a date; the portal’s note does not always capture this. The numbers describe what the official portal recorded and, for the acts without notes, what their own text says.

## Sources

- [Law 227/2015, the Fiscal Code: consolidated text and consolidation history, Portal Legislativ](https://legislatie.just.ro/Public/DetaliiDocument/171282)
- [Emergency Ordinance 74/2023 amending Article 4(4) of the Fiscal Code](https://legislatie.just.ro/Public/DetaliiDocument/274632)
- [Constitution of Romania, Art. 78 (entry into force of laws) and Art. 115 (ordinances)](https://www.cdep.ro/pls/dic/site.page?id=339)
- [Council Decision (EU) 2020/509 on the existence of an excessive deficit in Romania](https://eur-lex.europa.eu/eli/dec/2020/509/oj)
- [The Tax Institute study of Fiscal Code amendments 2016–2023, as reported by CursDeGuvernare (September 2023)](https://cursdeguvernare.ro/the-tax-institute-impactul-a-7-ani-de-haos-fiscal-top-10-cele-mai-bune-si-cele-mai-proaste-masuri.html)
- [The text of each amending act, Portal Legislativ (links in the table of acts)](https://legislatie.just.ro/)
