Moldova requires e-Factura for supplies to Transnistrian-region businesses

What changed in detail

Law No. 214 of 31 July 2024, which amends several acts on budget, fiscal and customs policy, was published in Monitorul Oficial nr. 355-357 on 15 August 2024 (art. 545). Art. II point 35 adds three paragraphs to Fiscal Code art. 117. The gazette numbers them (1⁴), (1⁵) and (1⁶), with superscripts.

• (1⁴): a VAT payer supplying goods or services to an economic agent located in Moldova that has no fiscal relations with Moldova’s budget system must give the buyer an electronic tax invoice (e-Factura). In practice these are entities in the Transnistrian region.
• (1⁵): the same duty applies to supplies of goods and services for projects under art. 104 letter c¹), the zero-rated supplies for projects financed by external assistance.
• In both cases, supplies of electricity, heat, natural gas, electronic communications services and utility services are excluded.
• (1⁶): the e-Government Agency or, where relevant, the Public Services Agency provides the information on which persons have no fiscal relations with the budget system.

Under Art. XVII(1), the law enters into force on 1 January 2025. Point 35 is not among the exceptions.

What it means

This is not a business-to-government mandate. It is a targeted e-invoicing duty for two flows: sales to left-bank (Transnistrian) businesses and supplies to externally financed projects. Both are areas where the State Tax Service wants a real-time record. A supplier needs to know which customers fall outside the fiscal system, and (1⁶) points to the state agencies as the source of that list.

As of November 2026 these paragraphs are in force. We found no later law amending them. Moldova has since gone further in bringing the region into its tax system. Law 67/2026 extends VAT to certain supplies from 1 January 2027 (md-convergence-fund-vat-commencement-2026), and Government Decision 469/2026 phases in VAT on Transnistrian imports (md-transnistria-vat-hg-469-2026).