D/AM1 Hires Are Quota-Free, But WorkinRomania.gov.ro Registration Still Isn't Optional

Employers hiring highly skilled non-EU professionals in Romania sometimes assume that because the D/AM1 route is quota-free, it carries lighter administrative requirements overall. That assumption creates a gap. D/AM1 hires are exempt from Romania's 90,000-worker national quota and from the Shortage Occupations List that governs D/AM2 applications, but employers sponsoring them still must be registered on WorkinRomania.gov.ro before a single application can be filed. Since the platform became fully operational on 8 August 2026, skipping or delaying that registration step stalls a hire just as effectively as a missing quota slot would.

Government Emergency Ordinance No. 32/2026 restructured non-EU work authorisation into two distinct tracks. Understanding where D/AM1 genuinely differs from D/AM2, and where the two converge on the same platform obligations, is the difference between a hiring timeline that holds and one that slips by weeks.

What D/AM1 actually exempts employers from

D/AM1 covers highly qualified workers and specialists, roughly the equivalent tier to what many employers think of as an EU Blue Card pathway. Workers sponsored under this category are not counted against the national 90,000-worker quota, and employers do not need to check whether the role appears on the current Shortage Occupations List before filing. For a specialist, senior manager, or technical expert hire, this removes two of the more time-consuming verification steps that D/AM2 sponsors must complete.

It is easy to read that exemption as a broader signal that D/AM1 hiring is lightly regulated. It is not. The exemption applies narrowly to quota and occupation-list checks. Every other obligation under GEO 32/2026, including platform registration, remains in force.

Registration conditions employers must meet

To register on WorkinRomania.gov.ro as an employer eligible to sponsor D/AM1 workers, a company must generally demonstrate:

• No outstanding tax obligations at the time of registration
• Active economic operations for at least 12 months prior to filing
• A clean administrative record, with no relevant sanctions recorded in the prior year

This is a materially lighter bar than the full authorisation process required for D/AM2 sponsorship, which demands 24 months of prior economic activity, an average of 50 employees in the preceding year, and a financial guarantee of EUR 1,000 per worker. But lighter does not mean automatic. A newly established Romanian subsidiary, a company with a recent tax dispute, or an employer that has not yet completed 12 months of documented operations will not clear registration on the first attempt, regardless of how urgently it needs to bring in a specialist.

Why the platform requirement catches employers off guard

Before WorkinRomania.gov.ro consolidated the process, some employers hiring under what would now be the D/AM1 equivalent treated the paperwork as a formality handled late in the hiring cycle, often after an offer had already been extended and a start date discussed with the candidate. That sequencing does not work under the current system. Registration has to be current before the individual application is filed, and the platform will not accept a D/AM1 sponsorship request from an employer whose registration status is pending, lapsed, or incomplete.

This creates a practical planning problem for companies making their first Romanian specialist hire. The 12-month operating history requirement, in particular, cannot be resolved quickly. An employer that discovers this requirement only after identifying a candidate has already lost meaningful time it could have used to prepare.

Building the registration into the hiring timeline

Employers bringing highly skilled non-EU talent into Romania should treat WorkinRomania.gov.ro registration as a prerequisite to be resolved before recruiting begins, not a step to complete once a candidate is chosen. That means:

• Confirming the company's tax status and administrative record are clean well ahead of any anticipated D/AM1 hire
• Verifying the 12-month operating history threshold is met, particularly for newly established entities or recent market entrants
• Completing platform registration proactively, rather than reactively once a specific candidate and start date are on the table
• Maintaining registration status as current on an ongoing basis if the company expects to make repeat specialist hires

Treating registration as a standing compliance requirement, rather than a one-off task tied to a single hire, keeps future D/AM1 sponsorships moving without the delay of resolving eligibility gaps under time pressure.

How Nestlers Group Supports D/AM1 Employers

Nestlers Group's Work Permit and Visa Support team handles WorkinRomania.gov.ro employer registration end to end, verifying tax standing, operating history, and administrative record before a D/AM1 application is ever filed. For companies establishing a Romanian presence for the first time, our Immigration Advisory team maps out realistic timelines against the 12-month operating history requirement, so specialist hiring plans are built around the platform's actual constraints rather than assumptions carried over from the pre-2026 system.

Our Employer of Record service offers an alternative path for companies that need to bring in a specialist before they meet the registration threshold independently, allowing the hire to proceed under Nestlers' existing Romanian entity while the client's own registration is completed in parallel.

Sources: Government Emergency Ordinance No. 32/2026 (Official Gazette No. 335, 27 April 2026); WorkinRomania.gov.ro platform employer registration guidance; ANOFM authorisation requirements for D/AM2, 2026