Short answer: Romania's GEO 32/2026 moved foreign hiring onto the WorkinRomania platform and limits standard D/AM2 hires to shortage occupations. These hires go through an authorised placement agency, unless the employer is authorised itself. On 10 September 2026 a Bucharest court suspended the shortage list, and new employer registrations and D/AM2 applications are on hold.
Why are D/AM2 applications on hold?
On 10 September 2026 the Bucharest Court of Appeal admitted a request to suspend Order 1073/2026, which approved Romania's List of Shortage Occupations, until the court rules on the merits. The case, number 5633/2/2026, was filed on 2 September 2026 (court record via InfoDosar, last change 14 Sep 2026).
On 15 September 2026 the General Inspectorate for Immigration (IGI) said that, following the decision, the WorkinRomania flows for employer registration, employer authorisation and the single application for D/AM2 visas had been temporarily disabled at the Labour Ministry's request. IGI added that this "is not caused by a technical malfunction" (IGI, 15 Sep 2026).
On 20 October 2026 the Labour Ministry said employers still cannot complete certain registration and authorisation procedures or file D/AM2 applications, and that consultations with the employers' association that brought the case are continuing (Labour Ministry, 20 Oct 2026). On 26 October 2026 the WorkinRomania homepage still showed the court-ordered deactivation notice. No date for reopening has been announced.
What did GEO 32/2026 change?
Government Emergency Ordinance (GEO, in Romanian OUG) 32/2026 was adopted on 23 April 2026 and published in the Official Gazette no. 335 of 27 April 2026 (OUG 32/2026, legislatie.just.ro; full text read from the 3 Jun 2026 archived copy). The main changes:
- One digital procedure. Employers must be registered, or authorised, on WorkinRomania.gov.ro, with some exempt categories (Art 4).
- Shortage occupations only. Standard D/AM2 hiring is allowed only for occupations on the List of Shortage Occupations, which is updated every six months (Art 1).
- An annual quota, set by government decision, which can be supplemented (Art 1).
The platform went live on 6 Aug 2026 (the full OUG 32 procedures apply from 8 Aug 2026); since mid-September its employer and D/AM2 flows have been disabled (WorkinRomania, checked 26 Oct 2026; the 8 August start follows from OUG 32/2026, Art 48).
Who may hire D/AM2 workers?
GEO 32/2026 has two kinds of employer (OUG 32/2026).
Registered employers must have no tax arrears and, for companies, at least one year of activity in fields compatible with the shortage occupations, plus further conditions. The National Employment Agency (ANOFM) decides within 30 working days (Art 5). The number of foreign workers is capped at the previous year's average headcount, and individuals who employ may hire at most three (Art 6). Registered employers must contract an authorised placement agency for D/AM2 workers (Art 10).
Authorised employers may recruit without a placement agency. They need at least 24 months of uninterrupted activity in a compatible field, an average of at least 50 employees in the previous year, and no more than 20% of their foreign workers having lost their status (Art 12). They lodge a guarantee of €1,000 per foreign worker, and €2,000 is taken from it for each foreigner removed from Romania (Art 13 and 14).
What does the law say about placement agencies?
These are the rules in GEO 32/2026. They describe Romanian law, not any service offered by Testiy.
- Placing foreigners on the Romanian labour market requires ANOFM authorisation, only for shortage occupations and only against firm job offers (Art 23(1)–(2)).
- The agency must be a Romanian legal entity or an EU, EEA or Swiss entity whose representatives, administrators and shareholders are EU, EEA or Swiss citizens (Art 2 and 24(1)). An Indian agency cannot be the Romanian placement agency.
- The agency lodges a guarantee of €75,000 for up to 250 placed workers, plus €50,000 for each further 250 (Art 25).
- Authorisation lasts two years and can be renewed for two-year periods (Art 29).
- Authorisation can be suspended if, for example, visas were refused for more than 30% of the foreigners the agency placed in the last six months (Art 30).
- The agency's services are paid for only by the employer, under the service contract between them, and the agency may not take commissions, fees or deposits from the workers it places (Art 23(4) and (6)).
What must employers do once workers arrive?
Article 7 of GEO 32/2026 lists the employer's duties (OUG 32/2026):
- pay the salary into the worker's bank account
- sign the employment contract in Romanian and in a language the worker understands
- give health and safety training in a language the worker understands
- notify the placement agency and IGI within five working days of an unjustified absence of more than three working days, or of the end of the contract
- provide Romanian-language courses for at least six months from the start date registered in REGES-ONLINE, at least six hours a week
- keep the worker's travel or residence document copy and supporting records for at least 5 years after the employment ends
- if the employer provides housing, charge no more than 25% of the worker's net pay in rent.
The worker is also tied to the arrangement for a time. A D/AM2 worker cannot initiate a change of employer for six months from the start date in REGES-ONLINE, except for a serious breach by the employer. From then until two years after the start date, a change of employer goes only through the placement agency that is party to the placement contract (Art 40(2)–(4)). Separately, the long-stay (D) visa fee is €300 (Art 47); it applies to all long-stay visas, not only work visas.
Where does an Indian sourcing partner fit?
The Romanian placement agency or the authorised employer stays legally responsible for the hire. Indian agencies can source and prepare candidates, but they cannot take that role.
GEO 32/2026 also sets conditions for foreign recruiters. Where an authorised employer contracts a recruitment provider abroad, that provider must be authorised, accredited or registered under the law of its home country, must not be flagged for security threats, its representatives must have no final convictions for listed offences, and it must not charge workers commissions, fees or deposits beyond the limits set by its home country's law (Art 12(8)).
Testiy does not replace the Romanian authorisation your placement agency or your company needs. Testiy helps on the Indian side: you work only with Indian agencies whose licence, office and documents have been checked. Testiy checks each agency's registration number against India's official e-Migrate list of licensed recruiting agents, among other checks. This does not replace the Romanian checks, and it is not a check against Romania's rules on what workers may be charged.
What can employers do while filings are frozen?
You cannot file a new D/AM2 application for now, and no reopening date has been given. What you can do is prepare:
- confirm whether you will hire through an ANOFM-authorised placement agency or apply for authorisation yourself
- line up Indian sourcing partners whose registration you have checked
- prepare candidate files in advance. Testiy checks candidates' police clearance certificates and apostilles, and candidate documents are reviewed by an officer
- watch the WorkinRomania homepage and the Labour Ministry's announcements for changes.
Use the pause to line up verified partners and checked candidate files. Employer sign-up is free.
Planning Romanian hires for when filings reopen? Create your free employer account and meet verified Indian agencies.