The statutory audit threshold in 2026: who must be audited

Annual financial statements must be audited when a company exceeds, at the balance sheet date, the limits for at least two of the following three criteria in two consecutive financial years: total assets of RON 16,000,000, net turnover of RON 32,000,000 and an average of 50 employees (point 563(2) of the Accounting Regulations approved by OMFP no. 1802/2014).

The thresholds are unchanged for the 2026 financial year. For a company close to them, the practical question is not only "do we need an audit?" but "from which year, and how early should we start preparing?".

Two years, not one

Exceeding the limits in a single year does not trigger the requirement. If the limits are exceeded again in the following year, the financial statements for that second year must be audited. Conversely, the requirement ends only after two consecutive years below the limits. Any two of the three criteria will do: a company with few employees but with assets and turnover above the limits is caught.

Size criteria are not audit thresholds

Through Order no. 4,164/2024, which implements Commission Delegated Directive (EU) 2023/2775, the Ministry of Finance raised the criteria that classify entities as micro, small, medium-sized or large, starting with the 2024 financial statements (one of the limits, for example, is now RON 25,000,000 of total assets and RON 50,000,000 of net turnover). These criteria mainly determine the format of the financial statements. Medium-sized and large entities are audited in any case (point 563(1)), but for the others the requirement follows from the lower thresholds above. The order did not amend point 563, and the RON 16,000,000, RON 32,000,000 and 50-employee thresholds are restated unchanged in Order no. 2,036/2025 on annual reporting at 31 December 2025.

What follows

The statutory auditor is appointed by the general meeting of shareholders. With the statutory audit comes the requirement to organise internal audit (Article 65(7) of Law no. 162/2017). The first year is the most demanding, because the auditor also examines the opening balances, that is, the unaudited figures at the end of the previous year.

Step by step: a timetable for the first audit

1. September–October: estimate your figures at 31 December (total assets, net turnover, average headcount) and compare them with the previous year.
2. October–November: request proposals, choose the auditor and prepare the shareholders' resolution to appoint them.
3. December: agree with the auditor their attendance at the year-end inventory count and the documents needed for the opening balances.
4. January–February: the accounting close, reconciliations and the file supporting your estimates.
5. February–April: final fieldwork and the audit report, before the financial statements are approved.
6. Alongside: plan internal audit for the same financial year.

An example

An illustrative example with round numbers. At 31 December 2025 a distribution company has total assets of RON 18,000,000, net turnover of RON 35,000,000 and an average of 45 employees. Two criteria are exceeded, but it is the first year, so the 2025 financial statements do not require a statutory audit.

The 2026 budget shows assets of RON 20,000,000 and turnover of RON 38,000,000. If those figures hold, the limits are exceeded for a second consecutive year and the 2026 financial statements must be audited. The auditor should be appointed in the autumn of 2026, so they can attend the inventory count at 31 December and review the opening balances in good time. From 2026, the company also has to organise internal audit.

Common mistakes

• Confusing the size criteria, raised in 2024, with the audit thresholds, which have not changed.
• Looking at one year only: exceeding the limits once is just an early warning.
• Estimating from the September trial balance, without year-end provisions and adjustments that can move total assets above or below the limit.
• Appointing the auditor after 31 December: the inventory count can no longer be observed, and the alternative procedures take longer and need more evidence.
• Forgetting internal audit, which comes with the statutory audit.
• Assuming the requirement ends after a single year below the limits.

When a conversation helps

Start by checking your figures in the audit threshold calculator. If the result is borderline, if you are unsure what counts as net turnover or how average headcount is calculated, or if you want to know what a first audit means for your finance team, our free 60-minute assessment is a good place to start. You receive a written summary with recommended next steps.

Sources

• OMFP no. 1802/2014 – Accounting Regulations, point 563(2) (in Romanian)
• Order no. 4,164/2024 – updated size criteria (in Romanian)
• Order no. 2,036/2025 – reporting at 31 December 2025 (Annex 1, point 2.6(4)), Official Gazette no. 41 of 20 January 2026
• Law no. 162/2017 – Article 65(7), internal audit requirement (in Romanian)