Sovereign Ordinance No. 12.056 of 23 July 2026 strengthens the obligations of tax-refund operators. In particular, it requires proof of export of goods for which a VAT refund is claimed and use of a platform directly connected to the customs online service.
Maintaining authorisation also requires attention when the business or its ownership changes: transfer of the business and acquisition of control of the company holding the authorisation cause it to lapse. The acquiring company is presumed to exercise control where it holds, directly or indirectly, at least 33.33% of voting rights or shares and no other partner or shareholder holds, directly or indirectly, a larger proportion.
For an acquisition, examination of the authorisation must therefore accompany that of ownership and voting rights. Continuing the activity through the same company does not guarantee that the authorisation remains valid. Operationally, export evidence and the functioning of the interconnection address separate requirements: a successful technical transmission does not necessarily demonstrate that goods have left. Each refund claimed must still be reconciled with evidence substantiating that export.
Under article 3, these changes take effect from 1 March 2026. Failure to comply may lead to a fine capped at 300,000 euros, after thirty days have been allowed for observations. This ceiling must be presented neither as an automatic penalty nor as an opportunity to regularise without scrutiny.