Law No.189 of 19 November 2025 amends Law No.176 of 1 September 2010 and several other normative acts, aiming to establish a unified legal framework for restrictions related to the “revolving door”.

The law covers a broad range of individuals: members of the government and senior executives of central authorities, locally elected officials, managers and controllers in the public education and healthcare systems, management of state-owned companies and enterprises with state participation, staff managing programmes financed from the budget or external sources, employees involved in evaluating funding applications and in public procurement procedures, persons issuing licences, accreditations and permits, lawyers representing public authorities in court, internal auditors, as well as presidential advisers and government advisers.

For these persons, the Law introduces two types of restrictions connected with transitions between the public and private sectors. Both apply during the legally defined “cooling-off period” (perioadă de reflecție).

1. Pre-employment restrictions (pre-angajare). For 12 months from the date of appointment, election or hiring, individuals covered by the Law are prohibited from exercising supervision or control and from concluding contracts on behalf of the state with private organisations in which they worked (including on an unpaid basis) during the 12 months prior to taking office.
If a conflict of interest arises, the official must recuse themselves, and their powers must be reassigned to another person.

Compliance with this requirement during the 12-month cooling-off period and for an additional 6 months thereafter is monitored by the respective public authorities and organisations themselves.

2. Post-employment restrictions (post-angajare). For 12 months after the end of a mandate or dismissal, individuals covered by the Law are prohibited from working in a private organisation if the new activity overlaps with their former duties and may affect the transparency and impartiality of relations between public authorities and the private sector.

For post-angajare, no additional 6-month monitoring period is envisaged; oversight is carried out only during the cooling-off period through the system of declarations and checks by the National Integrity Agency (Agentia Nationala de Integritate – ANI).

All affected individuals must submit two declarations:

• within 15 days of taking office;
• within 15 days after the end of the mandate or dismissal.

Declarations must be completed and submitted electronically, signed with a qualified electronic signature, and uploaded to the electronic communication system (e-DAI) via a designated responsible person (unit). Copies of the declarations are added to the official’s personal file and are used when allocating official duties and when assessing the admissibility of private-sector activities during the cooling-off period.

Each authority or organisation employing persons covered by the Law must appoint a responsible person (unit) which:

• informs officials of the established restrictions and obligations;
• receives and registers declarations;
• keeps a record of activities performed during the previous 12 months;
• records and processes recusals;
• uploads information to e-DAI;
• sends reasoned notifications to ANI if declarations were not submitted or if there are doubts regarding compliance with restrictions upon taking up private-sector employment.

ANI, in turn, verifies compliance with pre-/post-angajare restrictions based on these reasoned notifications. It assesses individual cases using a point-based system and may prohibit or restrict the relevant activity*. If ANI does not issue a report within 30 days of receiving a notification, the activity is deemed authorised.

Failure to comply with the new regime results in administrative fines ranging from 2,000 to 10,000 lei, including for:

• failure to submit mandatory declarations;
• carrying out professional activity in a private organisation during the cooling-off period without filing a declaration or contrary to restrictions imposed by ANI;
• failure of public authorities to appoint a responsible person/unit to monitor pre-/post-angajare restrictions (after 12 months from the law’s entry into force).

To evaluate the risk of conflict of interest when an individual takes up private-sector employment, ANI uses four criteria, assigning points to each type of activity:

Criterion 1. Nature of the new activity (degree of connection with previous duties). Range: 0–3 points:

• 0 – activity is irrelevant or unrelated to previous tasks;
• 1 – limited connection;
• 2 – significant relevance;
• 3 – high relevance, direct contact with risk areas (e.g., regulation of a sector and employment by a regulated entity).

Criterion 2. Level of involvement in previous duties. Range: 0–3 points:

• 0 – no involvement;
• 1 – rare involvement;
• 2 – involvement in multiple tasks;
• 3 – constant, key involvement.

Criterion 3. Position level (the higher the rank, the higher the risk). Range: 1–3 points:

• 1 – operational staff;
• 2 – management;
• 3 – senior official.

Criterion 4. Geographical scope of authority (if several levels apply, the highest score is used). Range: 0–3 points:

• 0 – not applicable;
• 1 – local level;
• 2 – regional level;
• 3 – national level.

After summing all points, ANI assigns a risk category:

• 1–4 points – no violations. The new activity is considered safe and does not affect the transparency or integrity of interactions between the state and the private sector → activity permitted.
• 5–9 points – potentially risky. There is a likelihood of affecting transparency and impartiality → ANI may authorise the activity but impose restrictions (e.g., prohibition on participation in certain projects, narrowing of functions, limiting interaction with public authorities).
• 10+ points – high risk. The new activity may harm state interests → ANI must prohibit the activity.