Romania's Ministry of Labour has opened a public consultation on the draft order approving the List of Shortage Occupations provided for under Emergency Ordinance 32/2026 (OUG 32/2026), which governs non-EU nationals' access to the Romanian labour market. The consultation window is just 10 calendar days, 24 July to 2 August 2026, and submissions can be sent to [email protected]. For every employer recruiting outside the EU, the final list will shape hiring in construction, hospitality (HoReCa), road transport and care work for the next quota cycle.

The stakes go well beyond a routine list update. OUG 32/2026 has completely rewritten the architecture governing non-EU workers' access to the Romanian labour market, and the List of Shortage Occupations is the mechanism through which the Ministry of Labour decides, in practice, which roles remain open for recruitment from third countries and under what conditions. Put simply: what appears on the list can be filled. What is left off becomes, operationally, blocked.

Why the list matters for workforce planning strategy

OUG 32/2026 repealed the former Ordinance 25/2014 and abolished the requirement to obtain individual employment and secondment authorisations. Recruiting a non-EU worker now runs through a long-stay D-type visa, either D/AM1 or D/AM2, applied for directly by a registered employer or by a placement agency licensed by ANOFM (the National Agency for Employment). The distinction is structural: D/AM1 is reserved for highly qualified specialists and special-status categories, while D/AM2 covers permanent, seasonal and cross-border workers, conditional on employment in sectors classified as shortage sectors.

That distinction has direct consequences for the recruitment pipeline. D/AM2 workers fall under the annual quota for newly admitted workers. D/AM1 workers and posted workers are excluded from the quota. In practice, placing an occupation on the list, or leaving it off, moves the role between two very different availability regimes: one capped, one uncapped. For companies with high recruitment volumes from Nepal, Sri Lanka, Bangladesh or other non-EU markets, this classification determines how quickly vacancies can be closed and how predictable the pipeline becomes.

The exposed sectors: construction, hospitality, transport and care

The four sectors most visibly dependent on non-EU labour are in the most vulnerable position with respect to this list. In construction, the pace of infrastructure projects does not align with the local supply of qualified bricklayers, carpenters or plumbers. In hospitality (HoReCa), seasonality and high staff turnover make dependence on seasonal workers a structural reality rather than an exception. Road freight transport operates on a chronic shortage of professional drivers. The care sector, with an ageing population and a growing network of private residential facilities, needs auxiliary staff that the domestic market can no longer supply.

For HR teams in these sectors, the immediate question is not whether the list will change, but how. An occupation removed or redefined completely rewrites the recruitment plan for 2026–2027. An occupation added opens opportunities for companies that have until now been building parallel pipelines. And the technical wording on the list matters: the methodology sets the criteria for inclusion and review, which means that arguments submitted during the public consultation must be grounded in labour-market data, not perceptions.

Implications for recruitment and compliance teams

The shift to the D/AM1 and D/AM2 system moves the employer's administrative burden from one area to another, but does not reduce it. Applications are filed electronically; the requirement for a bilingual employment contract (Romanian plus the worker's native language or a language they know) remains in force following the amendment to the Labour Code (Codul Muncii); and medical insurance of at least €30,000 becomes a standard requirement for all visa applications. Mobility and compliance teams need to remap their internal workflows for each type of non-EU recruitment.

For recruitment teams, the less obvious implication is employer branding in source markets. In a context where the quota caps access to D/AM2 visas and the list defines which roles are open, employers that build a credible presence in candidates' home countries become favoured destinations. The time between posting a role and the worker's actual arrival remains a competitive differentiator, and a reputation for fair pay and sound contractual practice travels through expatriate communities faster than any recruitment campaign.

What to do before 2 August

The 10-calendar-day window leaves no room for lengthy internal deliberations. Three actions are useful for any organisation with exposure to non-EU labour:

, Quick internal mapping: compile a list of the occupations your organisation recruits or plans to recruit from outside the EU over the next 12 months, with estimated volumes. Without this map, any position taken in the public consultation will be too generic to carry weight.

, Check with employer associations: industry confederations and sector organisations put forward consolidated positions. An individual employer has far more traction through a sector-wide submission than through an isolated comment.

, Submit your proposals: observations backed by labour-market data, recruitment benchmarks and salary trends should be sent to [email protected] by 2 August. The most effective argument is one that demonstrates that domestic supply does not meet demand, not one that simply describes difficulties.

What happens after publication in the Official Gazette

Once approved, the List of Shortage Occupations will be published in the Monitorul Oficial (Romania's Official Gazette) and will become the operational reference for authorisations, visa applications, quota allocations and placement procedures. The list can be revised periodically, so it is not a fixed snapshot. For strategic HR functions, tracking revisions becomes a routine task, not a one-off exercise.

The broader significance of this cycle is that OUG 32/2026 has shifted the non-EU labour market from a case-by-case authorisation regime to a list-and-quota regime. In such a system, workforce planning on an 18-to-24-month horizon is no longer optional for exposed sectors. Companies that enter 2027 without a clear map of which roles are recruitable and what domestic alternatives exist will deliver projects late or lose contracts.

The public consultation that closes on 2 August is the first operational test of the new framework. Employers who participate now gain two things: a list better calibrated to their sector's reality, and a working relationship with the Ministry of Labour ahead of the revisions that will follow. Those who do not participate will live with the list that others built.