How to Renew a D/AM2 Work Permit in Romania

A D/AM2 permit does not renew itself, and letting one lapse creates an immediate compliance gap: the worker's right to stay and work in Romania is tied directly to the validity of that document. For HR teams managing permanent, seasonal, or cross-border non-EU staff under the framework introduced by GEO 32/2026, the renewal window is where most avoidable errors happen, usually because someone assumes the process mirrors the initial hire when it does not.

The D/AM2 category, created by Government Emergency Ordinance No. 32/2026 (Official Gazette No. 335, published 27 April 2026), covers non-EU workers who fall outside the highly skilled D/AM1 track and instead work under Romania's national employment quota, set at 90,000 admissions for 2026. Because D/AM2 hiring is quota-bound and tied to an authorised employer, renewal is not a simple paperwork refresh. It touches the employer's ANOFM authorisation status, the worker's residence documentation, and the underlying employment contract, all of which need to be current and mutually consistent before the extension request is filed.

This guide sets out what HR and mobility teams need to track to keep a D/AM2 worker legally employed past the expiry of their current permit, and where the process differs from the standard initial application.

What Actually Needs Renewing

A D/AM2 worker in Romania is holding two linked but separate authorisations that both need attention:

• The employer's ANOFM authorisation to employ non-EU workers under the D/AM2 category, which is granted for a defined validity period and must itself be kept current
• The worker's individual temporary residence right for employment purposes, issued and extended by the General Inspectorate for Immigration (IGI)

Renewal failures typically happen when one of these two is renewed and the other is overlooked. An employer can hold a valid ANOFM authorisation while an individual worker's residence permit quietly expires, or vice versa. Both need independent tracking, ideally on separate calendar entries rather than a single combined deadline.

Employer-Level Renewal: ANOFM Authorisation

Employers hiring under D/AM2 must first obtain ANOFM authorisation before recruiting non-EU staff, based on conditions introduced under GEO 32/2026:

• A minimum of 24 months of continuous economic activity in Romania
• An average of at least 50 employees over the prior year
• A financial guarantee of EUR 1,000 per foreign worker to be hired

Because this authorisation underpins every D/AM2 hire the company makes, its expiry is a business-critical date, not just an HR administrative item. If the authorisation lapses before renewal, the employer loses the legal basis to keep employing D/AM2 workers under that authorisation, which can stall renewals for every affected employee at once. Employers should treat the authorisation renewal application as a standing item on the compliance calendar well before the validity period ends, and confirm the financial guarantee and headcount conditions still hold, since ANOFM checks these again at renewal rather than only at first application.

Worker-Level Renewal: Extending Temporary Residence for Work Purposes

For the individual worker, the D/AM2 permit itself is expressed through a temporary residence right for employment purposes, administered by IGI under the foreigners' regime rules (OUG 194/2002, as amended). Renewal follows the general extension mechanism for temporary residence rather than a fresh visa application, provided the worker is already resident in Romania on a valid permit.

Key conditions that must still be met at renewal:

• The original conditions for entry and stay continue to apply, and no grounds for refusal have arisen during the stay
• A valid travel document is held
• The worker has legal occupancy of their declared residence address
• Health insurance coverage remains valid
• Means of subsistence are documented, consistent with the underlying employment contract

Extensions are granted for successive periods of up to one year at a time, so a D/AM2 worker on a multi-year assignment should expect to go through this renewal cycle annually rather than once for the full term.

Documents Typically Required

The renewal application file generally includes:

• Valid travel document, original and copy
• Proof of the current employment relationship, consistent with the ANOFM authorisation and the registered employment contract
• Proof of legal residence at the declared address
• Valid health insurance documentation
• Proof of means of subsistence
• Payment confirmation for the extension fee and related consular tax
• Any updated employer documentation confirming the position, salary, and duration of the assignment remain unchanged or have been properly amended

Employers should confirm the employment contract registered through the relevant channels reflects the current terms before submitting, since a mismatch between the contract on file and the renewal application is a common cause of delay.

Does Renewal Count Against the Annual Quota

This is the question HR teams ask most often, and the distinction matters for workforce planning. The 90,000 annual quota applies to workers newly admitted to the Romanian labour market under the D/AM2 category. A renewal, by contrast, extends the stay of a worker already admitted and already counted in a prior cycle, rather than introducing a new admission. Employers should not assume this automatically, however, particularly where an assignment involves a change of employer, a break in continuous employment, or a change of role that could be treated as a new authorisation rather than a straightforward extension. Where any of these apply, it is worth confirming the classification with ANOFM or IGI before assuming the renewal will proceed outside the quota count.

Timing: When to Start the Renewal Process

Renewal applications for temporary residence extensions should be filed before the current permit expires, since an overstay, even a brief one, creates immigration compliance exposure for both the worker and the employer. Given that document collection, employer confirmation, and processing time all take weeks rather than days, HR teams should begin preparing the renewal file at least 30 to 45 days ahead of expiry, and earlier if the employer's own ANOFM authorisation is also nearing its renewal point. Building in this buffer avoids the scramble that happens when a permit expiry date is only flagged once it is already close.

How Nestlers Group Supports D/AM2 Permit Renewals

Nestlers Group's Work Permit and Visa Support team tracks D/AM2 expiry dates for both the employer's ANOFM authorisation and each individual worker's residence permit, building renewal timelines that account for document collection lead times and IGI processing windows. The team prepares and files the extension request through the correct channel, checks the employment contract and supporting documentation for consistency before submission, and liaises directly with ANOFM and IGI where clarification is needed on quota treatment or authorisation status.

The Payroll and HR Compliance team keeps the underlying employment contract and payroll records aligned with what is on file for the permit renewal, so there is no mismatch between the registered terms of employment and the documentation submitted to authorities. The Immigration Advisory team assesses more complex renewal scenarios, such as a change of role, employer, or assignment structure, and advises whether a case should proceed as a renewal or requires a fresh D/AM2 authorisation under the quota. For employers who prefer not to hold the ANOFM authorisation themselves, the Employer of Record team can take on the legal employment relationship for D/AM2 workers directly, removing the authorisation and renewal burden from the client's own entity while keeping the worker compliant.

*Sources: Government Emergency Ordinance No. 32/2026 (Official Gazette No. 335, 27 April 2026); Government Emergency Ordinance No. 194/2002 on the regime of foreigners in Romania, as amended; WorkinRomania.gov.ro platform guidance; General Inspectorate for Immigration (IGI) guidance on temporary residence extension; PwC Romania tax and legal alert on GEO No. 32/2026; KPMG Romania tax newsflash on the immigration ordinance.*