Only 39 employers registered, none authorised: who ends up without papers if companies don't enter WorkinRomania by year-end

On 24 September 2026, the public Register of Employers of Foreign Workers (R.A.S.) on WorkinRomania.gov.ro showed 39 registered companies — three pages, that's all. The Register of Authorised Employers (R.A.A.) showed none, and the Register of Placement Agencies (R.A.P.S.) stayed at 19 agencies, the same as mid-month. In a country with tens of thousands of non-EU workers and an estimated shortage of 100,000 employees, the numbers say one thing: almost everyone postponed. And since 15 September, when a court blocked the registration, authorisation and D/AM2 single-application flows, postponing became a trap — not so much for companies as for the people they would like to hire. From what we see in practice, hundreds of foreign workers whose employment contract has ended are now using up, day by day, the 90 days of legal residence in which they could be rehired — and there is no one to hire them legally, because companies are not registered, and those that want to register cannot. We explain the mechanism, what an unregistered company risks, and what can be done right now, even with the platform's buttons inactive.

What the registers show, in numbers

The registers are public, under the platform's "Registers" section. The 39 companies and 19 agencies are those that completed the procedure before the court blocked the flow. The rest stayed outside the system — and cannot enter until the flows are reactivated.

Who are the people left without papers

Not the newcomers, and not those under the art. 52 amnesty — they are covered by a different deadline. It is workers already in Romania whose individual employment contract has ended: dismissal, mutual agreement, resignation, a company that closed. For them, the law leaves a precise window:

• 90 days of legal residence after the contract ends, in which they must find a new employer and sign a new contract — art. 40 para. (6) letter a) OUG 32/2026, referring to the deadline in art. 56 para. (6) OUG 194/2002;
• when the 90 days expire without a new contract, the right of residence ends and the person becomes, on paper, an illegal resident — with everything that follows: return decision, entry ban, no possibility of being hired again.

The window exists both for workers who came under the old law (art. 51) and for those who came under OUG 32/2026 (art. 40). What differs is who can rehire them:

Even in the simplest case, the road has two mandatory conditions: the new company must be in R.A.S., and the residence-extension request is filed through the platform, as a single application (art. 56 para. 9 letter e and para. 10 OUG 194/2002). Both are exactly what is blocked now: employer registration and the single-application flow.

Why the court blockage hits precisely them

The chain is broken in three places at once:

1. The company that would hire them cannot register — the R.A.S. flow is disabled.
2. The company that would recruit directly cannot get authorised — the R.A.A. flow is disabled; that is why the register is empty.
3. Neither the agency nor the registered employer can file the single application for extension — the D/AM2 flow is disabled.

The worker, meanwhile, can do nothing alone: it is not the worker who files the request (art. 56 para. 10 OUG 194/2002 puts it on the agency or the employer). They just count the days. Someone whose contract ended in early September reaches the 90-day limit in early December; someone who lost it in August, in November. If the platform does not reopen in time — or reopens, but the company only then starts gathering its documents — they reach 31 December as people without a right of residence, even though the law had given them a way.

The court suspended Order 1073/2026 on 10–11 September, in case 5633/2/2026, with a right of appeal within 5 days of communication; the Ministry of Labour announced its appeal. No reopening date had been announced at the time of publication — on 23 September the warning was still on the platform's front page. We analysed the substance in our resource on the suspension of Order 1073/2026.

What you risk as a company if you are not registered when the platform reopens

• You cannot legally hire any foreign worker. Art. 4 para. (1) OUG 32/2026 makes hiring foreign workers conditional on registration or authorisation in the platform. Breaching it is punishable by a fine of 15,000–20,000 lei (art. 42 para. 3 letter a).
• You cannot take on a worker inside the 90 days, however qualified and available — the extension request cannot start without the company in R.A.S.
• Undeclared work costs 40,000 lei per person. Since 18 December 2025, receiving someone to work without an individual employment contract is punishable by 40,000 lei per person (art. 260 para. 1 letter e Labour Code), capped at 1,000,000 lei in total. A worker left without a right of residence whom you "keep on a bit longer until it's sorted" is exactly this case.
• Employing a foreign national without a right of residence has its own sanctions regime in OUG 25/2014, art. 36, and in the serious case — a person in illegal residence whom you know to be a victim of trafficking — becomes a criminal offence (art. 265 para. 2 Labour Code: 3 months to 2 years' imprisonment or a fine).
• You lose the race at reopening. ANOFM has up to 30 working days to approve a registration. When the flow returns, every company that waited will file in the same days. Whoever has the file ready enters the queue first; whoever only then requests a tax certificate enters last — possibly after the worker they wanted has run out of their 90 days.
• Recruiting from abroad stays closed too. Without R.A.S. you cannot sign a service contract with an agency (art. 23 para. 3 requires a registered employer), so plan B — new people — doesn't work either.

What you can do now, even with the flows stopped

The blockage stops filing, not preparation. Everything below can be done this week:

1. Open the account on hub.mai.gov.ro and obtain a qualified electronic signature for the person who will represent the company — without it you cannot designate representatives in the platform, and issuing the certificate takes time.
2. Check your tax status with ANAF and request the tax clearance certificate. Art. 5 para. (1) rejects the file for any outstanding obligation, however small; an approved payment schedule resolves the condition.
3. Check the one-year effective activity condition in fields compatible with the occupations you hire for (art. 5 para. 1) and whether you had sanctions for undeclared work or REGES-ONLINE in the last 6 months — the other two usual grounds for rejection.
4. Prepare the sworn statements of shareholders and directors required in the "Registration as employer – legal entity" form.
5. List the workers you want to take on and, for each, the end date of the old contract — the 90 days run from there. Establish under which law they came (art. 51 or art. 40), to know whether you can take them directly or only through their agency.
6. Choose the agency from R.A.P.S. now, not at reopening: only those with "Active" status; the service contract is negotiated on the framework model from Order 655/2026.
7. If you want to recruit directly, also prepare the R.A.A. authorisation file (art. 12 et seq.). R.A.A. is empty today precisely because it is the road with the most conditions — hence the most to prepare.
8. Follow case 5633/2/2026 on portal.just.ro and the warning on WorkinRomania's front page — the moment of reopening will show there first.

The calendar that matters

In short

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This resource is informational and reflects the situation at the date of publication: the register figures are those publicly displayed on WorkinRomania.gov.ro on 24 September 2026, and the estimate of affected workers comes from our current activity, not from an official statistic. Legislation and the status of case 5633/2/2026 may change; check the platform and portal.just.ro before any step. This material does not constitute legal advice.