Intra-Corporate Transfers to Romania in 2026: How the ICT Permit Works Under GEO 32/2026

For multinational groups, the most common way to bring a non-EU manager or technical specialist into a Romanian subsidiary has long been a secondment from a sister company abroad. Government Emergency Ordinance No. 32/2026, published in Official Gazette No. 335 on 27 April 2026, changed that picture. The ordinance repealed Title I of Government Ordinance No. 25/2014, abolished the separate secondment notice issued by the General Inspectorate for Immigration (IGI), and moved all work-based applications onto the WorkinRomania.gov.ro platform, which became fully operational on 8 August 2026.

The reform also narrowed what counts as a "seconded employee". According to Fragomen's analysis of the ordinance, classic posting status is now limited to non-EU nationals sent to Romania by an employer established in an EU or EEA Member State or Switzerland. For a group company based outside Europe, the intra-corporate transfer (ICT) route is now the only way to move staff into Romania without hiring them onto a local employment contract.

That makes the ICT permit far more important for global mobility teams than it was a year ago. This guide sets out who qualifies, how long a transfer can last, how the new single application works, and where employers most often go wrong.

What the ICT permit is

The ICT permit comes from EU Directive 2014/66/EU on intra-corporate transfers, which Romania transposed in 2016 through Government Ordinance No. 25/2016. It allows a third-country national who works for a company established outside the EU to be transferred temporarily to a Romanian entity of the same company or group, while remaining employed by the sending entity.

The permit covers three categories of transferee:

• Managers, who direct the host entity or a department of it
• Specialists, who hold knowledge that is essential to the host entity's activity, techniques or management
• Trainee employees, who hold a university degree and are transferred for career development or training

The defining feature is that the worker stays on the home company's employment contract. The Romanian entity hosts the assignment; it does not become the employer.

Who qualifies

The eligibility conditions follow the directive closely. The EU Immigration Portal's page on Romania sets out the minimum prior service with the sending company or group, counted immediately before the application:

• Managers and specialists: at least 6 uninterrupted months
• Trainees: at least 3 uninterrupted months

Under the rules as transposed in 2016, a specialist must also show at least three years of professional experience relevant to the host entity's field, techniques or management. The Romanian entity must belong to the same undertaking or group as the sending company, and employers should expect to evidence that relationship with corporate documents such as extracts, organisation charts and shareholding records.

How long a transfer can last

The temporary residence right for ICT purposes runs for the duration of the transfer, capped at:

• 3 years for managers and specialists
• 1 year for trainees

These are total caps counted from the date of entry into Romania. If the group extends an assignment, the residence right can be extended, but never beyond those limits. Employers planning a longer stay need a different route from the outset, typically local employment under a D/AM1 visa for highly qualified workers.

What changed under GEO 32/2026

Before the reform, the Romanian host entity applied in person at the IGI's territorial office for a secondment notice. Only then could the worker apply for a long-stay visa for secondment at a Romanian consulate.

GEO 32/2026 replaced the employment and secondment notices with a single application filed exclusively through WorkinRomania.gov.ro. Leroy Law's analysis of the ordinance notes that the employer files the single application for ICT workers, highly qualified workers and other special categories under the D/AM1 visa, and that applications are processed within 30 days, with priority for highly qualified profiles. PwC Romania's alert adds that the ordinance provides a simplified procedure for seconded and ICT workers who meet the eligibility criteria.

Two practical consequences follow for the Romanian host entity:

• It must be registered on WorkinRomania.gov.ro, in the Register of Employers of Foreigners, before it can file anything
• It is exposed to the ordinance's sanctions regime, with fines of RON 5,000 to RON 30,000 for breaches of the obligations it sets

Registration is not a formality. The ordinance requires, among other conditions, no outstanding debts to the state budget and a clean record on undeclared work and immigration sanctions.

Short-term and long-term mobility within the EU

One advantage of the ICT framework is mobility between Member States. A worker who already holds an ICT permit issued by another EU country can be sent to Romania in two ways.

Short-term mobility

For short stays, the Romanian host entity sends a prior notification to the IGI as soon as the assignment is planned. The IGI can object within 20 days of receiving the notification, and it communicates any objection to the host entity and to the authorities of the first Member State.

Long-term mobility

For longer stays, the worker's ICT residence right is extended in Romania for the length of the Romanian assignment. That extension cannot exceed the stay planned in the first Member State or the validity of the ICT permit issued there.

Using the wrong mechanism, or missing the prior notification, is a common compliance gap for groups that rotate specialists across European subsidiaries.

Family members

ICT permit holders can apply for family reunification, and the EU Immigration Portal confirms that family members have the right to work in Romania without first obtaining a long-stay visa for that purpose. Fragomen notes that family reunification applications sit outside the WorkinRomania.gov.ro platform and still go through in-person IGI procedures, so they need to be planned as a separate workstream alongside the main application.

Common pitfalls for employers

In practice, ICT files tend to fail on preparation rather than on the law itself. The issues we see most often:

• Treating a non-EU posting as a classic secondment, when only ICT or local employment is now available
• Counting prior service incorrectly, especially where the worker moved between group entities shortly before the transfer
• Weak evidence of the group relationship between the sending and host entities
• Filing before the Romanian entity has completed its own registration on WorkinRomania.gov.ro
• Letting an assignment drift past the 3-year or 1-year cap without a plan to convert to local employment
• Overlooking payroll and social security, since the assignee stays on a foreign payroll while working in Romania and may remain covered at home under a bilateral social security agreement or owe Romanian contributions, depending on the home country

How Nestlers Group supports intra-corporate transfers

Nestlers Group's Work Permit and Visa Support team handles ICT transfers to Romania from start to finish. That covers checking eligibility against the manager, specialist and trainee criteria, registering the Romanian host entity on WorkinRomania.gov.ro, preparing the group-relationship evidence and filing the single application. The team also manages short-term mobility notifications to the IGI and long-term mobility extensions for assignees arriving from other EU Member States.

Our Payroll and HR Compliance team reviews the tax and social security position of each assignee, including shadow payroll where a foreign-paid employee creates Romanian withholding obligations. Where an assignment needs to continue beyond the ICT caps, we advise on converting it to local employment, either directly with the Romanian entity or through our Employer of Record service for groups without a suitable local employer. Our Global Mobility and Relocation team supports the assignee and their family with housing, schooling, registration and the separate family reunification process.

Sources: Government Emergency Ordinance No. 32/2026, Official Gazette of Romania No. 335, 27 April 2026; Directive 2014/66/EU on intra-corporate transfers; Government Ordinance No. 25/2016 amending Government Ordinance No. 25/2014 and GEO 194/2002 (KPMG Romania People Services Newsflash, September 2016); European Commission EU Immigration Portal, Romania: Intra-corporate transferee (ICT), 2026; PwC Romania, Changes on foreigners' access to the Romanian labour market: GEO 32/2026, May 2026; Leroy Law, GEO 32/2026 on the access of foreign workers to the Romanian labour market, April 2026; Fragomen, Romania: New Unified Work Permit System and Online System Implemented, May 2026