D/AM1 vs D/AM2 Romania: Choosing the Right Visa for Non-EU Hires

# D/AM1 vs D/AM2 Romania: Which Visa Route Is Right for Your Hire?

When Government Emergency Ordinance No. 32/2026 replaced Romania's previous employment permit framework, it reorganised non-EU work authorisations into two distinct long-stay employment visa categories: **D/AM1** and **D/AM2**. For HR managers and global mobility professionals, understanding the difference is not academic — the visa category determines your compliance obligations, your timeline, your costs, and in some cases whether the hire is possible at all.

This guide explains each category, compares them side by side, and helps you identify which route applies to each position you are trying to fill.

What the Two Categories Replace

Under the old GO No. 25/2014 framework, Romania issued employment permits across several categories that were frequently confusing to apply and inconsistently administered. GEO 32/2026, which came into force on 27 April 2026, replaced these with a streamlined two-track system built around the worker's skill level and the employer's direct hiring structure.

Both tracks feed into a **single application process** through the WorkinRomania.gov.ro platform, which integrates submissions to the National Agency for Employment (ANOFM), the General Inspectorate for Immigration (IGI), and the relevant Romanian consulate. The single application is one of the most significant practical improvements of the new framework — it eliminates the old multi-step sequence of permit-then-visa-then-residence-permit.

The D/AM1 Visa: Highly Skilled Workers

The D/AM1 category is Romania's equivalent of the EU Blue Card. It is designed for **highly skilled workers** — defined under GEO 32/2026 as those whose role requires higher education qualifications or at least five years of professional experience equivalent to a higher education degree.

Key D/AM1 Eligibility Criteria

• The worker must hold a relevant higher education qualification or documented professional experience of at least five years in the relevant field

• The gross salary offered must meet the minimum threshold set by ANOFM for highly skilled roles (published periodically and available through WorkinRomania.gov.ro)

• The employment contract must be for a minimum duration and meet Romanian labour law requirements, including the bilingual contract requirement introduced by GEO 32/2026

• The employer must be registered on the WorkinRomania.gov.ro platform — **full employer authorisation is not required** for D/AM1; registration alone is sufficient

D/AM1 Advantages

The D/AM1 track offers meaningful advantages over D/AM2. It is **not subject to the national quota** in the same restrictive way as the D/AM2 track, making it more accessible when the 90,000-slot annual quota has been or is approaching exhaustion. D/AM1 holders are also eligible for a more favourable pathway to long-term residence and benefit from faster EU Blue Card-equivalent recognition for cross-border mobility within the EU.

For employers in IT, engineering, finance, legal, and other knowledge-intensive sectors, D/AM1 is typically the correct and preferable route.

The D/AM2 Visa: Permanent, Seasonal, and Cross-Border Workers

The D/AM2 category covers a broader range of employment relationships: **permanent employment, seasonal employment, and cross-border work** in roles listed on Romania's official Shortage Occupations List. This track is where most of Romania's quota-governed non-EU hiring takes place.

Key D/AM2 Eligibility Criteria

• The role must appear on the Shortage Occupations List published by the Ministry of Labour on WorkinRomania.gov.ro

• The employer must either: (a) hold **full authorisation** from ANOFM (required for direct hiring) or (b) work through an **authorised placement agency** that holds valid GEO 32/2026 agency authorisation

• For direct D/AM2 hiring, the employer must meet stricter platform requirements: at least 24 months of economic activity, an average of 50 employees in the prior year, and a **financial guarantee of EUR 1,000 per worker**

• Applications are subject to the national quota (90,000 for 2026)

D/AM2 Subcategories

GEO 32/2026 distinguishes between three types of D/AM2 employment:

**Permanent workers** — employed under a standard open-ended or fixed-term contract for roles on the shortage list. This is the most common D/AM2 scenario and the one most affected by quota competition.

**Seasonal workers** — employed for up to nine months in a calendar year in agriculture, hospitality, or other seasonal sectors. Seasonal authorisations are counted separately within the overall quota but are subject to the same shortage list requirement.

**Cross-border workers** — individuals residing in a neighbouring country who commute to Romania for work. This category is governed by specific bilateral provisions and applies primarily to workers residing in Ukraine, Moldova, and Serbia.

Side-by-Side Comparison

| Feature | D/AM1 | D/AM2 |

|---|---|---|

| Worker profile | Highly skilled / graduate-level | Shortage occupations (any level) |

| Quota sensitivity | Lower — not subject to standard quota cap | Direct quota exposure |

| Employer requirement | Registration only | Full authorisation (direct hire) or authorised agency |

| Financial guarantee | Not required | EUR 1,000/worker (direct hire) |

| Shortage list required | No | Yes |

| Salary threshold | Yes (ANOFM minimum for skilled roles) | Standard Romanian minimum wage |

| Processing route | Single application via WorkinRomania.gov.ro | Single application via WorkinRomania.gov.ro |

| Long-term residence pathway | Favourable (EU Blue Card equivalent) | Standard |

Choosing the Right Route: A Decision Framework

**Use D/AM1 when:**

• The role requires a university degree or five-plus years of specialised experience

• The position is in IT, engineering, finance, medicine, architecture, or another graduate-level profession

• Quota risk is a concern and you want to avoid dependence on the 90,000-slot national cap

• The worker may want to use EU Blue Card portability to move within EU member states

**Use D/AM2 when:**

• The role is in a sector relying on shortage-list occupations (construction, manufacturing, agriculture, food processing, hospitality)

• The worker does not have graduate-level qualifications for the position

• You are hiring at scale and are working with an authorised placement agency

• You are hiring seasonal or cross-border workers

**When in doubt:** Check the Shortage Occupations List on WorkinRomania.gov.ro first. If the role is listed, D/AM2 is the applicable track. If the role requires higher education qualifications and the salary meets the D/AM1 threshold, D/AM1 is available and should be considered for its quota advantages.

Common Mistakes to Avoid

**Attempting D/AM2 without verifying the shortage list.** The single application will be blocked at the platform level if the role does not appear on the list at the time of submission. Verify before initiating the hiring process.

**Assuming D/AM1 exempts you from all quota obligations.** While D/AM1 is less constrained by the quota, ANOFM still monitors the pipeline of highly skilled worker applications. Processing times can extend if volumes surge.

**Using an unauthorised placement agency for D/AM2.** The agency must hold valid GEO 32/2026 authorisation on WorkinRomania.gov.ro. If the agency's authorisation lapses or its financial guarantee is enforced and not replenished within 30 days, all pending applications through that agency are suspended automatically.

**Misclassifying a role to access D/AM1.** Classifying a construction worker or assembly line worker as a "skilled engineer" to circumvent the quota is a compliance risk. IGI and ANOFM cross-check employment contracts, job descriptions, and salary levels. Misclassification carries fines of up to RON 40,000 per breach and a six-month employer lock.

How Nestlers Group Supports Both Visa Tracks

Nestlers Group works with HR teams and multinationals navigating the full spectrum of Romania's non-EU hiring framework. From assessing whether a specific role qualifies under D/AM1 or D/AM2, to preparing and submitting the single application through WorkinRomania.gov.ro, to monitoring quota availability in real time, our Work Permit and Visa Support team manages the process end to end.

For companies without a Romanian legal entity, our Employer of Record (EOR) service allows you to hire under either track without establishing a local subsidiary — we hold the employer registration or authorisation on the platform and assume the compliance obligations. Our Payroll and HR Compliance team ensures every downstream requirement — bilingual contracts, ANOFM notifications, financial guarantee management — is handled from day one.

Whether you are placing a software engineer under D/AM1 or onboarding seasonal workers under D/AM2, the compliance requirements are different, the timelines are different, and the risks are different. Getting the categorisation right at the start saves significant time and cost down the line.

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Sources: Government Emergency Ordinance No. 32/2026 (Official Gazette No. 335, 27 April 2026); WorkinRomania.gov.ro platform documentation; National Agency for Employment (ANOFM) guidance on employer registration and authorisation; Ministry of Labour, Shortage Occupations List, 2026; General Inspectorate for Immigration (IGI), 2026.