GPS data in RO e-Transport is the transport operator’s obligation, not the declarant’s. The company that moves the goods — the transport organizer in the words of OUG 41/2022 — answers for the vehicle and for transmitting positioning data along the declared route, through the telematics device fitted to the truck. The company that obtains the UIT code is usually a different one entirely: the importer, the buyer, the supplier or the exporter. Both obligations attach to the same shipment and are checked separately, and no declaration software can discharge the positioning one for you.
Two obligations, two companies, one truck
The most useful thing to understand about this system is that it asks two unrelated questions about every shipment, and sends the bills to different addresses.
| Question | Answered by | How |
|---|---|---|
| What is on this truck, and whose is it? | The declarant — importer, buyer, supplier, exporter or depositary | A declaration to ANAF, before departure, returning a UIT code |
| Where is this truck now? | The transport operator, as transport organizer | Positioning data from the vehicle’s device, along the route |
A Romanian importer buying from Italy declares the intra-community acquisition and receives the code. The Italian or Romanian haulier carrying the load is the transport organizer and owes the positioning data. Neither can perform the other’s duty, and neither is excused by the other’s compliance. Who declares what, in every direction of trade, is set out in who must declare in RO e-Transport and in the RO e-Transport overview.
What OUG 29/2025 changed
According to the specialist press and the road carrier associations, OUG 29/2025 postponed the penalties for failing to transmit positioning data. The obligation itself was not suspended — only the sanction for breaching it. The reported effect is that penalties apply in full from 1 January 2026, alongside the rest of the e-Transport sanction regime that came out of its own grace periods.
The important consequence of a postponement is one that catches operators out: a suspended penalty is not a suspended duty. Data that was not transmitted during a grace period was still owed, and a carrier that treated the postponement as an exemption has a gap in its records rather than a clean sheet.
What GPS data in RO e-Transport means in practice
For a haulier, this is a fleet question, not a paperwork question. It needs a positioning device in the vehicle, a telematics system capable of sending data to ANAF’s system in the required form, and an operational habit of having both switched on for the whole of a declared transport.
The parts that go wrong are ordinary and mechanical:
- A device that is fitted but not transmitting to ANAF. Fleet tracking for your own dispatchers and transmission to a tax authority are two different data flows. Having the first does not create the second.
- A subcontracted leg. When the trailer is handed to another carrier, the transport organizer for that leg has to be transmitting. Written into the subcontract, or it will not happen.
- A trip that starts before the transport is declared. The declaration is filed at most 3 calendar days before the declared start date, and in any case before the vehicle moves. A truck that leaves early creates a mismatch that no positioning data can repair.
What declaration software does not do
Plainly: it does not transmit GPS data, and it cannot.
A declaration application knows what you typed or imported — parties, goods, weights, values, addresses, dates. It has no connection to the box installed behind the dashboard of a truck it has never seen, and no way to know where that truck is. Positioning data comes out of the vehicle, through the carrier’s telematics provider, into ANAF’s system. That is a separate contract with a separate supplier.
This matters when comparing suppliers. Some vendors sell telematics and add declarations; some sell declarations and cannot supply telematics. Reading a feature list without knowing which of the two obligations each item addresses is how a company ends up paying twice for one and nothing for the other.
Which transports does the positioning obligation follow?
The same ones that have to be declared. The threshold test is in the implementing order.
Below those limits there is no declaration and nothing for the positioning data to attach to. Above them, both duties run together for the whole journey — which is why a carrier’s compliance question is never “do we have trackers” but “are they transmitting for every declared load, including the subcontracted ones”.
What it costs to get it wrong
The penalties for e-Transport breaches are reported, in the specialist press summarising OUG 41/2022 art. 13-14 as amended in 2024, at 20,000 to 100,000 lei for legal persons and 5,000 to 10,000 lei for drivers, with confiscation of the value of undeclared goods as a separate measure. A contravention report can be challenged under OG 2/2001 within 15 days at the district court for the place where the contravention occurred, and the complaint suspends enforcement of the fine. The practical steps are in RO e-Transport fines and appeals.
Where the standard advice fails
“We have GPS, so we are compliant.” Fleet tracking is not transmission to ANAF. Ask your telematics provider, in writing, whether they send e-Transport positioning data and for which vehicles.
“The shipper handles e-Transport, so it is not our problem.” The shipper handles the declaration. The positioning data is the carrier’s, and it is the carrier that is stopped.
“Sanctions are postponed, so we will start later.” The duty ran throughout the postponement. Starting late leaves a gap in exactly the period a later inspection would look at first.
“One system will cover everything.” Two obligations, two kinds of supplier. Buy them knowingly rather than assuming one box covers both.
Sources: OUG 41/2022 on legislatie.just.ro; technical information on mfinante.gov.ro; ANAF’s RO e-Transport guide (2025). The dates attributed to OUG 29/2025 come from specialist press and carrier association reporting, not from our own reading of the ordinance.
Frequently asked questions
Who has to transmit GPS data in RO e-Transport?
The transport operator — the company that actually moves the goods, called the transport organizer in OUG 41/2022. It answers for the vehicle and for the positioning data. The party that declares the transport and obtains the UIT code is usually somebody else: the importer, the buyer, the supplier or the exporter. Two different obligations, on two different companies, for the same movement.
Does declaration software transmit the GPS data for me?
No. Declaration software talks to ANAF about the content of a shipment; positioning data comes from the telematics device installed in the vehicle and is transmitted by the transport operator's own system. No application that builds and sends declarations can supply a position it has no way of knowing. If a vendor implies otherwise, ask which device in which vehicle they are reading.
What did OUG 29/2025 actually change?
According to the specialist press and the carrier associations, OUG 29/2025 postponed the penalties for failing to transmit GPS positioning data; the obligation itself was never suspended. The reported effect is that sanctions apply in full from 1 January 2026. Treat the dates as reported rather than as our own reading, and confirm the current position before relying on a grace period.
Is GPS required for domestic transports as well?
The positioning obligation follows the transport that has to be declared in RO e-Transport, which includes domestic movements of high fiscal risk goods above the thresholds. The practical test is the same one as for the UIT code: a vehicle of at least 2.5 tonnes maximum technically permissible mass, carrying goods above 500 kg gross or above 10,000 lei in value for at least one consignment.
Does a valid UIT code protect us if the GPS data was not sent?
No. The two obligations are separate and are checked separately. A transport can have a perfectly valid UIT code and still expose the transport operator to a penalty for missing positioning data, and a fully monitored vehicle carrying undeclared goods is still an undeclared transport. Neither one substitutes for the other.
What should a shipper ask a carrier before loading?
Three things: whether the vehicle carries a working positioning device, whether the carrier's system is transmitting to ANAF for declared transports, and who at the carrier is named as transport organizer for this trip. Put the answers in the transport order. The shipper does not carry the GPS obligation, but a stopped truck is the shipper's problem too.
Where do I check the current rules on GPS in e-Transport?
The Ministry of Finance publishes the technical information for RO e-Transport, and ANAF publishes its system guide. Both are updated more often than commentary is. Because the sanction dates have already been moved once, by OUG 29/2025, verify the position that applies on your transport date rather than relying on an article written a year earlier.
