D/AM1 vs D/AM2 Romania 2026: Every Eligible Category, the Medical Insurance Rule, and How to Choose the Right Route

Government Emergency Ordinance No. 32/2026 restructured Romania's work visa framework around two distinct routes — D/AM1 and D/AM2 — each with its own eligible worker categories, employer conditions, application procedures, and compliance obligations. Choosing the wrong route does not produce a slow approval. It produces a rejected application and a wasted processing cycle that can set a hire back by two to three months.

The choice between D/AM1 and D/AM2 is not optional and not a matter of preference. It is determined by who the worker is — their qualification level, their country of nationality, their occupation category — and by whether the position appears on Romania's national shortage occupations list. Employers who understand both routes before beginning the hiring process can structure their approach correctly from day one.

What Changed in 2026: The End of the Single D/AM Route

Before OUG 32/2026, Romania's long-stay work visa was a single category: the D/AM visa, which covered most non-EU employment scenarios. The Ordinance, published in Official Gazette No. 335 on 27 April 2026 and operational from 8 August 2026, split this into two routes with meaningfully different rules:

D/AM1 covers workers who are hired outside the national quota, without the need for ANOFM authorisation, through a registration notice submitted by the employer directly on WorkinRomania.gov.ro.

D/AM2 covers quota-based workers who require either an authorised placement agency or a directly authorised employer to submit the application, with a prerequisite ANOFM authorisation and the national annual quota (90,000 positions in 2026) determining availability.

The distinction matters because it determines the employer's own eligibility obligations, the application pathway, the documents required, and the processing institution.

The D/AM1 Route: Who Qualifies

D/AM1 applies to a specific set of worker categories defined in OUG 32/2026. The defining characteristic is that these workers are admitted outside the national quota — their hire does not consume one of Romania's 90,000 positions for 2026.

Highly Qualified Workers

Highly qualified workers are non-EU nationals who will be employed in a role that meets the salary and qualification threshold for the EU Blue Card in Romania. The offered gross annual salary must be at least 1.5 times the average gross salary in Romania for the relevant economic sector. For most sectors in 2026, this corresponds to a gross monthly salary of approximately RON 12,000 to RON 15,000 or above. The position must require a higher education qualification — a university degree or equivalent — recognised in Romania. Highly qualified workers are the primary category for IT, engineering, finance, and management roles.

EU Blue Card Applicants

EU Blue Card applications in Romania are processed under the D/AM1 route. The Blue Card is the EU-level combined work and residence permit for highly qualified non-EU nationals and is issued in Romania by IGI after the work authorisation notice is granted. The Blue Card grants more rights than a standard single permit — including facilitated family reunification and an easier path to long-term residence — and is the preferred route for senior hires where the employer wants to offer a stronger legal status.

Intra-Company Transferees: Specialist Employees

Intra-company transferees who move to Romania in a specialist employee capacity are covered under D/AM1. A specialist employee is defined as a person who holds specialised knowledge essential to the receiving entity's areas of activity, research techniques, or management functions, and who has been employed by the sending entity for at least 12 months before the transfer. The receiving entity in Romania must be part of the same corporate group as the sending entity.

Intra-Company Transferees: Senior Employees

Senior employees transferred intra-company are also under D/AM1. A senior employee is a person who primarily manages the activities of the receiving entity in Romania, manages a department, exercises supervision or control over the work of other employees, and has authority to hire and dismiss. Both subcategories require prior employment of at least 12 months with the sending entity.

Full-Time Employees from Moldova, Ukraine, and Serbia

Citizens of the Republic of Moldova, Ukraine, and Serbia who will be employed full-time in Romania are covered under D/AM1 under the bilateral arrangements referenced in OUG 32/2026. This provision removes the need for quota allocation for citizens of these three neighbouring states in full-time employment roles. Part-time contracts or service agreements do not qualify under this provision.

Workers in Public Interest, Academic, Scientific, Teaching, and Cultural Activities

Foreign nationals employed in activities of public interest, academic positions, scientific research roles, teaching functions in accredited Romanian institutions, or cultural activities recognised by the relevant Romanian ministry are eligible under D/AM1. This covers university lecturers and researchers, scientists at national research institutes, and cultural workers at institutions recognised by the Ministry of Culture.

Professional Athletes and Sports Coaches

Professional athletes and their coaches employed by Romanian sports clubs or federations are covered under D/AM1 in all recognised sports disciplines.

The D/AM2 Route: Who Qualifies

D/AM2 covers all non-EU workers who do not fall within the D/AM1 categories, drawing from the national annual quota of 90,000 positions for 2026.

Permanent Workers

Non-EU nationals employed on standard individual employment contracts for roles not covered by D/AM1. This is the default route for most blue-collar and lower-to-mid-level white-collar hiring — construction workers, manufacturing operatives, drivers, logistics staff, hospitality workers, and similar roles. The critical eligibility check is the shortage occupations list: the position must correspond to an occupation on Romania's national shortage occupations list for the relevant year.

Seasonal Workers

Seasonal workers are non-EU nationals employed for a fixed period not exceeding 6 months in a 12-month period in an economic activity that is seasonal in nature. Primary sectors include agriculture, horticulture, food processing linked to harvests, peak-period construction, and tourism. The position must appear on the shortage occupations list applicable to seasonal roles, and the employment contract must specify the seasonal nature and maximum duration.

Cross-Border Workers

Cross-border workers are non-EU nationals resident in a country sharing a border with Romania who work in Romania while returning to their country of residence at least once a week. This category applies primarily to workers resident in Moldova, Ukraine, Serbia, Bulgaria, or Hungary.

Trainees

Non-EU nationals employed in Romania for the purpose of vocational training under a recognised training programme are eligible under D/AM2.

The Shortage Occupations Requirement for D/AM2

The requirement that D/AM2 positions appear on the national shortage occupations list is one of the most practically significant conditions in OUG 32/2026. The list is approved annually by the Ministry of Labour following consultations with ANOFM, sectoral bodies, and employer organisations. It specifies occupations by COR code — Romania's national occupation classification system — and identifies which roles experience a shortage of local workers sufficient to justify non-EU hiring.

For 2026, the shortage occupations list includes roles in construction (steel fixers, concrete workers, formwork carpenters), manufacturing (welders, machine operators, food production workers), transport (HGV drivers, forklift operators), agriculture (seasonal pickers, agricultural machine operators), and certain service sectors (cleaning, hospitality). The list is updated annually, meaning a role that qualifies in 2026 may not qualify in 2027.

Employers must verify that the specific COR code corresponding to their role appears on the current year's shortage occupations list before beginning any D/AM2 application. Submitting an application for a role not on the list wastes the application fee, the processing time, and the candidate's time invested in document preparation.

The Medical Insurance Requirement: What EUR 30,000 Coverage Means in Practice

All work and posting visa applications under OUG 32/2026 — both D/AM1 and D/AM2 — require the foreign national to provide travel medical insurance valid for the relevant period. The minimum coverage is EUR 30,000, covering emergency medical treatment, hospitalisation, repatriation for medical reasons, and death.

The insurance must be valid from the date of the visa application at the consulate through to at least the expected date of arrival and initial registration in Romania. A policy that expires before the single permit is issued — or that has a lower coverage limit than EUR 30,000 — will be rejected by the consulate.

Once the worker is in Romania and the single permit is issued, the mandatory Romanian social health insurance (CASS) takes over as the primary health coverage. The travel insurance is a bridge document for the visa application and entry phase, not a permanent replacement for social insurance.

Employers who arrange the insurance on behalf of the worker should ensure the policy specifically names the non-EU worker, covers Romania as a destination country, and meets the EUR 30,000 minimum on a per-incident basis rather than in aggregate. Aggregate policies that could be depleted below EUR 30,000 by a single prior claim do not reliably meet the requirement.

The cost of a compliant policy for the visa application period (typically 3 to 6 months) is generally EUR 50 to EUR 200 depending on the worker's age and the insurer. It is a minor cost relative to the overall hiring investment but a disproportionately common source of consulate rejections when the policy terms do not precisely meet the Ordinance's requirements.

Employer Eligibility Differences Between D/AM1 and D/AM2

For D/AM1, the employer must be registered on WorkinRomania.gov.ro and meet the base registration conditions under Article 5 of OUG 32/2026 — no outstanding fiscal obligations, at least one year of economic activity, no sanctions in the preceding 12 months for illegal employment or undeclared work. There is no workforce size minimum and no financial guarantee required for D/AM1.

For D/AM2, two employer models are possible. The first is an authorised employer — a company that has obtained ANOFM authorisation to hire foreign workers directly, requiring at least 24 months of economic activity, an average of at least 50 employees in the preceding year, and the financial guarantee of EUR 1,000 per worker under Article 13. The second is a registered employer working through an authorised placement agency — in this model, the registered employer does not need its own authorisation but must be registered on the platform and work through a placement agency that holds a valid ANOFM authorisation.

The practical consequence: companies with fewer than 50 employees or less than 24 months of Romanian economic history cannot directly hire through D/AM2 and must use an authorised placement agency for that route. They can hire directly through D/AM1 if the worker falls into one of the D/AM1 categories.

Application Processing: D/AM1 vs D/AM2

For D/AM1, the employer submits a registration notice directly through WorkinRomania. IGI processes the registration notice within 30 calendar days, with a possible 15-day extension. The D/AM1 route does not consume a quota slot.

For D/AM2, the employer or placement agency submits through WorkinRomania after ANOFM has issued its authorisation. ANOFM processes the quota slot allocation and eligibility check; IGI then processes the work authorisation notice. D/AM2 is therefore a two-institution process at the authorisation stage. In practice, experienced employers report D/AM1 WorkinRomania processing in 3 to 5 weeks versus 4 to 7 weeks for D/AM2, not counting the ANOFM authorisation prerequisite.

A Practical Decision Framework for Employers

Before beginning any non-EU hiring process under OUG 32/2026, work through the following sequence:

First, identify the worker's profile: nationality, qualification level, and specific role. If the worker is a citizen of Moldova, Ukraine, or Serbia in a full-time role — D/AM1. If the worker holds a higher education qualification and will be paid above the Blue Card threshold — D/AM1. If the worker is an intra-company transferee with at least 12 months at the sending entity — D/AM1. If none of these apply — D/AM2.

Second, for D/AM2, check the current shortage occupations list for the specific COR code of the role. If the code is not on the list, the D/AM2 route is not available for that role in the current year.

Third, confirm employer eligibility for the chosen route. For D/AM1 — platform registration and Article 5 conditions. For D/AM2 — either own authorisation (24 months activity, 50 employees, financial guarantee) or partnership with an authorised placement agency.

Fourth, verify the medical insurance policy terms before the candidate collects it. Minimum EUR 30,000 coverage, Romania as destination, validity covering the visa application and entry period, per-incident rather than aggregate coverage.

How Nestlers Group Handles D/AM1 and D/AM2 Applications

Nestlers Group's Work Permit and Visa Support team advises employers on route identification, manages both D/AM1 registration notice filings and D/AM2 authorisation and application processes, and coordinates the full document preparation sequence across ANOFM, IGI, and the Romanian consulate network.

For employers approaching a new hire under OUG 32/2026, our Immigration Advisory team begins with a route assessment before any documents are prepared or any platform steps are taken — confirming the applicable category, checking the shortage occupations list for D/AM2 roles, verifying employer eligibility, and establishing a realistic timeline from the characteristics of the specific hire.

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Sources: Government Emergency Ordinance No. 32/2026, Official Gazette No. 335, 27 April 2026 — Articles 2, 3, 4, 5, 6, 7, 9, 10, 13, 17; WorkinRomania.gov.ro platform documentation 2026; IGI General Inspectorate for Immigration — D/AM1 and D/AM2 processing procedures; ANOFM National Agency for Employment — shortage occupations list 2026 and employer authorisation conditions; Ministry of Labour Order No. 655/2026; EU Blue Card Directive 2021/1883 as transposed in Romanian law; OUG No. 194/2002 on the regime of foreigners in Romania, as amended