Revisal Registration Deadlines for Non-EU Employment Contracts in Romania: The 2026 Compliance Timeline

An employer who registers a non-EU employee's contract in Revisal one day too late is not looking at a warning letter. Under HG 905/2017, failing to transmit a new employment contract's core elements by the day before the employee starts work carries a fine of 20,000 lei per person identified, capped at 200,000 lei per inspection. For companies bringing in workers from outside the EU under GEO 32/2026, that deadline sits at the end of a chain of immigration steps that can each slip by days or weeks, and every slip narrows the window an HR team has left to register correctly.

This is the part of non-EU hiring that gets the least attention and causes the most exposure. Employers focus heavily on getting the D/AM1 or D/AM2 authorisation and the long-stay visa approved, and treat Revisal registration as a formality to handle once the worker lands. In practice, the Revisal deadline is fixed by law regardless of how the immigration file progressed, which means the registration clock and the permit clock have to be managed together, not sequentially.

This article sets out how the Revisal deadline works, how it interacts with the GEO 32/2026 permit sequence for non-EU workers, and what the Labour Inspectorate can fine for getting it wrong.

The Legal Deadline for Registering a New Employment Contract

Romanian labour law requires every new individual employment contract to be entered into the General Registry of Employees, historically known as Revisal and now operated as REGES-Online, before the employee's first day of work. The obligation is set out in Legea 53/2003 (Codul Muncii) and detailed procedurally in HG 905/2017.

• Contract identification data, job title, start date, contract type and salary must be transmitted no later than the day before the employee begins activity.
• The obligation falls on the employer, regardless of whether the work is performed by a Romanian citizen, an EU citizen, or a non-EU national.
• The registration is made through the Labour Inspectorate's electronic system, and every territorial labour inspectorate (ITM) can audit the timing of the entry against the actual start date on file.

For non-EU hires, this deadline does not shift or extend. The complication is that the employer often cannot confirm the legally permitted start date until the immigration formalities clear, so the Revisal deadline effectively becomes the last step in a longer chain rather than a standalone HR task.

How GEO 32/2026 Changed the Sequence Before Revisal Even Applies

GEO 32/2026 (Government Emergency Ordinance No. 32/2026, published in Official Gazette No. 335 of 27 April 2026) restructured how non-EU workers are authorised to work in Romania, and that restructuring directly affects when a Revisal entry can lawfully be made.

• Employers must register and process hiring through WorkinRomania.gov.ro, the digital platform integrated into hub.mai.gov, for all non-EU recruitment.
• D/AM1 authorisation applies to highly skilled workers and is a registration-only process, not subject to the national quota.
• D/AM2 authorisation applies to permanent, seasonal, or cross-border workers and requires full ANOFM authorisation within the 90,000 national quota.
• Only once the relevant D/AM1 or D/AM2 approval and the worker's entry into Romania are confirmed can the employer set a lawful start date and open the Revisal countdown.

Because the Revisal deadline is anchored to the day before work starts, and the start date is itself gated by permit issuance, employers cannot pre-file the Revisal entry speculatively. The practical result is a compressed window at the end of the immigration process where HR, payroll and legal teams have to be ready to register the contract within a single working day of confirmation.

Where Employers Lose Time

• Waiting for final confirmation of D/AM1 or D/AM2 approval before assigning internal responsibility for the Revisal entry.
• Treating the bilingual employment contract, now mandatory under Order 655/2026, as a document to finalise after the worker arrives rather than in parallel with the permit application.
• Assuming the same internal team that manages Revisal for local hires will automatically catch the non-EU-specific timing without a dedicated handoff from the immigration file.

Penalties for Late or Missing Revisal Registration

The Labour Inspectorate enforces Revisal deadlines under HG 905/2017, and the sanctions scale with the severity of the failure.

• Non-transmission of a new contract's required elements by the day before the employee starts work: a fine set at 20,000 lei per person identified, with a cumulative cap of 200,000 lei per control.
• Late transmission of contract data for work already performed, or delayed modifications to salary, job function, or contract type, fall into a lower penalty band under the same decision.
• Incomplete, erroneous, or improperly completed entries, including entries made by unauthorised personnel, are sanctioned separately from late-registration violations.
• Employers may pay half the minimum fine within 48 hours of receiving the sanction notice, but this does not remove the compliance finding from the inspection record.

For non-EU contracts, a Revisal violation compounds with immigration-side exposure. Under GEO 32/2026, employers with sanctions for undeclared work or labour law violations in the prior 24 months can lose eligibility for authorised-employer status, which affects every future non-EU hire, not just the one caught in the audit.

The Bilingual Contract Requirement and Its Own Deadline Pressure

Order 655/2026 introduced a mandatory standard-form employment contract template for non-EU workers, drafted in Romanian and in a language the worker understands. This is a separate obligation from Revisal registration, but it sits on the same timeline.

• The bilingual contract must exist and be signed before the Revisal entry is made, since the contract data being transmitted has to match the signed document.
• Employers who fail to provide the required bilingual version risk a fine, reported at 6,000 lei, distinct from any Revisal-specific sanction.
• Because the contract template is standardised, employers should prepare it during the WorkinRomania.gov.ro application stage rather than after arrival, to avoid a last-minute drafting delay that pushes back the Revisal filing.

How Nestlers Group Supports Revisal Compliance for Non-EU Hiring

Nestlers Group's Payroll and HR Compliance team manages the Revisal and REGES-Online filing itself, tracking the confirmed start date against the day-before deadline and preparing the contract data in advance so the entry can be submitted the moment the immigration file clears. This team also maintains the documentation trail that labour inspectors request during an audit, covering contract elements, timing of submission, and any subsequent modifications, so employers are not assembling records under pressure after a control notice.

The Work Permit and Visa Support team runs the GEO 32/2026 side of the process in parallel, from the WorkinRomania.gov.ro application and the choice between D/AM1 and D/AM2 authorisation through to visa issuance and arrival, and flags the confirmed start date to the compliance team as early as the file allows. This coordination is what closes the gap between permit issuance and the Revisal deadline, rather than leaving HR to discover the start date only after the worker has landed.

Nestlers Group's legal and documentation specialists also prepare the bilingual employment contract required under Order 655/2026 alongside the permit application, so the signed contract is ready before registration is due rather than becoming the final bottleneck in the sequence.

Sources: Government Emergency Ordinance No. 32/2026, Official Gazette No. 335, 27 April 2026; HG 905/2017 on the General Registry of Employees (Revisal/REGES-Online); Legea 53/2003, Codul Muncii; Order 655/2026 on the mandatory employment contract template for non-EU workers; Romanian Labour Inspectorate (Inspectia Muncii) enforcement provisions under HG 905/2017