OUG 32/2026 · duties for employers of third-country nationalsRead the OUG 32/2026 employer guide

Practical guide for HR and employers

OUG 32/2026: employer obligations explained clearly

Who is covered, what Article 7 requires, when the Romanian language program begins, which records employers should keep and where the course provider’s role ends.

Checked: Reading time: 10 minutesPrimary sources linked
Legislative status

OUG 32/2026 was published on 27 April 2026 and introduced through transitional implementation. The approval bill remains in the parliamentary process, so the text and each employee’s circumstances must be checked periodically.

01 · Scope

Who is a “foreign worker” for this purpose?

OUG 32/2026 relies on the definition of “foreigner” in OUG 194/2002. In broad terms, it concerns a person who does not hold Romanian, EU, EEA or Swiss citizenship.

More precise wording

“Employees from third countries” or “employees from outside the EU, EEA and Switzerland” is more accurate than treating every non-Romanian citizen as automatically covered.

Employers should verify each person’s immigration and employment basis individually.

02 · Transitional situations

Does the duty apply to employees already working before August 2026?

There is no safe one-line answer for every existing employee. The ordinance contains transitional provisions, while Article 7(1)(g) links the program to the activity start date recorded in REGES-ONLINE.

Start

Employment procedure and date

Review the date and procedure under which employment began, including whether the file was already in progress.

Status

Residence and work basis

Confirm the employee’s residence and work status before deciding how the new framework applies.

REGES

Recorded activity date

Use the individual REGES-ONLINE activity date as the operational reference where Article 7 applies.

Change

Later employer changes

Do not assume that a change of employer automatically resets or removes the relevant period.

Recommended separation

The employer and its advisers determine legal applicability. The course provider can structure delivery after the company confirms the participants and reference dates.

03 · Article 7(1)(g)

What does the Romanian course requirement contain?

When does the period begin?

It begins from each employee’s activity start date in Romania as recorded in REGES-ONLINE. A general supplier agreement does not replace that individual reference date.

Who may deliver the course?

The text lists several routes: direct delivery by the employer, accredited providers, or collaboration with public institutions, nongovernmental organizations, international organizations or educational institutions identified by the ordinance. The appropriate route and supporting documents should be verified for each employer.

What does the article not expressly define?

It does not expressly establish a mandatory examination, a specific CEFR level, a universal attendance percentage, an exclusively online or physical format, the meaning of an academic hour, a general ANC-certificate requirement for every participant or a single statutory evidence template.

04 · Wider employer duties

The employer’s responsibilities extend beyond Romanian courses

The course is one part of a broader set of obligations. It does not replace employment, immigration, occupational-safety, notification or record-retention duties.

Art. 7(1)(a)

Payment into a bank account

The employee’s remuneration or salary is paid into their bank account.

Art. 7(1)(b)–(c)

Understandable contract and information

The employment contract is prepared in Romanian and in a language the employee understands, and contains the mandatory employment information.

Art. 7(1)(d)

Occupational safety and protective equipment

Safety instruction must be delivered in a language the employee understands. Romanian lessons do not replace this separate duty.

Art. 7(1)(e)

Notifications within five working days

The placement agency and immigration authority are notified of the events listed by the ordinance, including certain extended absences, contract termination and danger or exploitation.

Art. 7(1)(f)

Documents for inspections

Employers provide competent authorities with the documents and information required for verification.

Art. 7(1)(h)

Confidential complaints

Employees must have access to confidential procedures for reporting complaints and abuse.

Art. 7(1)(i)

Records kept for at least five years

Relevant travel or residence-document copies and supporting records are retained for at least five years after employment ends.

Art. 7(2)

Accommodation limit

Where the employer provides accommodation, retained rent is subject to the statutory limit and conditions in the ordinance.

05 · Article 42(2)(a)

What is the penalty for failing to provide the course?

RON 5,000–10,000

for each foreign worker placed, as applicable, for breaches that include Article 7(1)(g).

The qualification “as applicable” should be preserved. Purchasing a program does not automatically eliminate every sanction or compliance risk.

06 · Operational records

What can the program organize for HR?

✓Participant and REGES-ONLINE start-date mapping
✓A weekly plan structured around the required duration
✓Romanian language and cultural/social integration content
✓Participant lists and recorded learning activity
✓Modules, topics and assessment results
✓Periodic employer progress reports
✓Completion records and downloadable exports
Important limit

These are useful operational records. They are not, by themselves, statutory certificates or a guarantee that every aspect of the employer’s legal position is compliant.

07 · Primary sources

Official texts and current status

Note: Information was checked on and is general. It is not legal, immigration, employment, tax or occupational-safety advice.

Next step

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