05/10/2026
Quick summary: By Government Decision No. 788 of 1 October 2026, the transition period for the CAEN Rev. 3 classification has been extended until 25 March 2027. Until that date, CAEN Rev. 2 and CAEN Rev. 3 codes may be used in parallel. The obligation to update the registered business activities with the Trade Register remains unchanged — only the deadline has moved. We explain what the new decision provides, what it changes for your company and why postponing until March 2027 is a risky strategy.
Government Decision No. 788 of 1 October 2026 amends Government Decision No. 284/2025, the legal act that approved the CAEN Rev. 3 classification and set the transition period from the previous classification. Initially, this period was 18 months from 25 March 2025 and expired on 25 September 2026.
The new decision extends the deadline by a further six months, until 25 March 2027. Until that date, CAEN Rev. 2 and CAEN Rev. 3 codes may be used in parallel in dealings with public authorities.
The decision applies to all professionals registered with the Trade Register — companies (SRL, SA), authorised natural persons (PFA), sole proprietorships and family businesses — registered before 1 January 2025 that have not yet updated their business activities.
The reason is primarily statistical. According to Trade Register (ONRC) data cited by the Ministry of Economy, by 25 September 2026 only 37,24% of professionals required to update had actually converted their business activities to CAEN Rev. 3. In other words, almost two thirds of companies were not ready when the original deadline expired.
The Ministry also explicitly acknowledged the cause: for some companies the update is simple, but in sectors such as trade, construction, transport and IT, some codes have been split into several categories, classification questions remain and, in certain cases, operating permits must also be updated. These are exactly the situations we encounter most often in our practice.
Only one thing changes: the date until which both classifications are accepted in parallel. If you have not yet updated, you have until 25 March 2027 before the old Rev. 2 codes are treated as outdated.
The consequences we described in our article on the risks of not updating CAEN codes — blocked filings with the Trade Register, a certificate of registration details considered non-compliant by banks and funders, inconsistencies with the tax authority (ANAF) — remain valid. They are simply postponed from 25 September 2026 to 25 March 2027.
The obligation to update remains. The extension does not make the CAEN Rev. 3 conversion optional. All professionals registered before 1 January 2025 must complete it.
The procedure remains the same. For companies, the update requires a code correspondence analysis, a shareholders' resolution or sole shareholder decision, updated articles of association and a registration application with the Trade Register — the steps we detailed in our guide to updating CAEN codes.
There is no fine for simply missing the deadline. The fine of RON 5,000–35,000 under Law No. 296/2023 penalises carrying out an activity without the required legal authorisation, regardless of the CAEN classification, and is unrelated to the conversion deadline.
Permits must still be aligned with the new codes. Where a code has been split, an operating permit issued for the former activity may need to be updated.
The extension is good news, but the first deadline shows what will happen at the second. Here are four reasons why we advise our clients not to treat the extra six months as an invitation to postpone.
If almost two thirds of companies did not convert in 18 months, a very large volume of applications is likely to be filed again in the final weeks before 25 March 2027. Processing times lengthen, and an application rejected for a formal defect may not be refiled in time.
Where one Rev. 2 code corresponds to several Rev. 3 codes, choosing the main activity code and removing codes that do not reflect the actual business are legal decisions with practical effects: every code retained is a declaration that the company meets the legal conditions for that activity.
Any other change you will file with the Trade Register anyway — a change of registered office, a transfer of shares, a change of director — is the right moment to include the CAEN conversion in the same application and with the same documentation. This is particularly relevant for limited liability companies with net turnover above RON 400,000, which must in any case carry out a share capital increase to at least RON 5,000 under Law No. 239/2025: both operations can be handled through a single resolution and a single updated articles of association.
Banks, contracting authorities and business partners conducting due diligence do not necessarily wait for the deadline to request an updated certificate of registration details. Business activities still recorded under the old classification may raise additional questions in a financing application or public tender, even during the transition period.
Step 1 — check your status. Review your latest certificate of registration details: if your business activities appear under CAEN Rev. 3 codes, your company is already up to date. Companies incorporated after 1 January 2025 received Rev. 3 codes directly.
Step 2 — analyse the correspondence. Identify which Rev. 3 codes your current activities convert into and decide which codes to keep, which to remove and which is your main activity code.
Step 3 — plan the filing. If you have other corporate changes planned in the coming months, include them in the same application. If not, file the update as soon as possible, ahead of the rush in early 2027.
I have already updated my CAEN codes. Do I need to do anything else?
No. The extension does not affect companies that have already converted their business activities to CAEN Rev. 3.
Until when can I use CAEN Rev. 2 codes?
Under Government Decision No. 788/2026, CAEN Rev. 2 and Rev. 3 codes may be used in parallel until 25 March 2027.
Will my company be fined if it does not update its CAEN codes by 25 March 2027?
The legislation governing the transition period does not provide for a fine for simply missing the deadline. The real risk is administrative: blocked Trade Register filings and problems with banks, funders and the tax authority (ANAF).
My company is suspended. Must I update by March 2027?
As long as the company remains suspended and you file nothing with the Trade Register, the update becomes relevant when activity resumes, as the resumption application will also need to include the CAEN conversion.
Can I update my CAEN codes together with a share capital increase?
Yes, and it is recommended. Both operations require a shareholders' resolution and updated articles of association, so they can be filed in the same Trade Register application.
What if the Trade Register rejects my update application?
The registrar's decision can be challenged, but in most cases the faster route is to remedy the reason for rejection and refile a complete application. That is exactly why filing early leaves room for corrections.
Our firm works exclusively with legal entities, serving clients throughout Romania, in updating registered business activities to CAEN Rev. 3 — including complex cases where codes have been split, permits must be aligned or the conversion is combined with other corporate changes. We handle the entire process: correspondence analysis, drafting the resolution and updated articles of association, and filing with the Trade Register.
This article is for information purposes only and does not constitute legal advice. For an analysis of your company's specific situation, please contact our firm.
Author: F.R.I.
