In brief

  • Hospitals with beds enter the third accreditation cycle on 23 September 2026, against a list of 589 items. We counted the rows of the table in Annex no. 1: 3 references, 30 standards, 123 criteria and 433 requirements. The codes start from 01, although the preamble speaks of a continuation of the 2nd edition.
  • Requirements appear that had no counterpart until now: artificial intelligence and the environmental footprint. The hospital has to keep a record of the artificial intelligence systems used in clinical or administrative work, to keep the decision with a human being, to track the systematic errors of the algorithms and to offer alternatives to patients without access to technology. Separately, it needs a plan for reducing carbon emissions and monitoring of its consumption of energy, water, materials and medicines.
  • What score a hospital will get cannot be established yet, and the standards are not in the ordinary issue of the Official Gazette of Romania (Monitorul Oficial). Article 42 of the methodology refers to 14 acts to be approved separately, and among them are the very framework of the measurable elements, the calculation algorithm and the accreditation categories with their thresholds. The two annexes appeared only in issue no. 808 bis, which is bought from the Public Relations Centre.
Act: Order of the President of the National Authority for Quality Management in Healthcare no. 139/2026 approving the 3rd Edition of the ANMCS Standards for the accreditation of healthcare units in the 3rd accreditation cycle and the Methodology for the evaluation, re-evaluation, accreditation and re-accreditation of healthcare units and for monitoring the implementation of the quality management system for healthcare services and patient safety
Published: Official Gazette of Romania no. 808 of 23 September 2026
In force from: 23 September 2026, the date of publication, because Article 4 does not provide for a later date

The National Authority for Quality Management in Healthcare (ANMCS), the institution that accredits Romanian hospitals, published on 23 September 2026 the rules under which the third accreditation cycle will run. Order no. 139/2026 approves two documents: the 3rd edition of the standards, a table with 589 items, and a methodology of 43 articles describing a hospital’s path from registration to certificate. Among the new requirements are objectives on the quality of working life of the staff, seven weeks after penalties for attacks on medical staff were toughened by Law no. 166/2026.

The order itself has four articles and fits on a single page. Article 1 approves the standards in Annex no. 1, Article 2 approves the methodology in Annex no. 2, Article 3 states that the annexes form an integral part of the order, and Article 4 provides for publication in the Official Gazette of Romania and on the authority’s website. Both articles specify that, wherever the text says „unități sanitare”, healthcare units, it is to be read as „unități sanitare cu paturi”, healthcare units with beds. The legal basis invoked is Article 13(6) of Law no. 185/2017 on quality assurance in the health system, and underneath it stand two decisions of the authority’s Governing Board, no. 3 of 5 August 2026 and no. 7 of 21 September 2026, neither of them published in the Official Gazette of Romania.

The substance itself, namely what a hospital has to do and how it will be checked, sits in the annexes, and the annexes appeared only in issue no. 808 bis of the same day, on pages 3 to 56. The bis issue is not distributed together with the ordinary one: the note on page 9 sends the reader to the Public Relations Centre at șos. Panduri no. 1, block P33, sector 5, Bucharest. What appeared in the issue everybody reads was therefore the announcement, while the rules stayed at the counter.

What it changes in practice

The first effect is felt by the hospital drawing up its own list of tasks. The table of standards has three columns, „Enunț”, „Cod” and „Tip”, that is statement, code and type, and four levels of detail, recognisable from the letter in the „Tip” column and from the depth of the code. R is the reference, the broad domain, and its code has two digits. S is the standard, with a code of the form 01.01. Cr is the criterion, the specific objective through which the standard is reached, with a code of the form 01.01.01. C is the requirement, the concrete statement the hospital has to meet, with a code of the form 01.01.01.01. The three references are strategic and organisational management, with 11 standards, clinical management, with 16 standards, and medical ethics and patients’ rights, with 3 standards.

The second effect is the way the verdict is reached, and it takes the score out of the evaluator’s hands. Every applicable requirement is analysed along four dimensions, called measurable elements: EM1 capacity, EM2 implementation, EM3 results and EM4 improvement. The evaluator awards no points and does not establish the level of the requirement. The evaluator assigns each measurable element one of seven ratings, „Conform”, „Conform parțial”, „Neconform”, „Neaplicabil”, „Nu a fost cazul”, „Neevaluabil” or „Documentat insuficient”, that is compliant, partially compliant, non-compliant, not applicable, not the case, non-assessable or insufficiently documented, and the result is calculated exclusively through the national algorithm, applied identically to all hospitals, with no intermediate rounding. Article 24(3) forbids evaluators to change the values, the weightings, the thresholds or the rules of the algorithm.

The third effect is the calendar, and it is a long one. The process has eight stages and procedures: registration, enrolment, planning, evaluation, drawing up of the accreditation report, post-accreditation monitoring, and then, where applicable, re-evaluation and re-accreditation. Registration is done with the health operating authorisation, a declaration by the manager and a registration form, and ANMCS opens the account in the CaPeSaRo application within 10 working days. The preparation stage lasts at least 6 months and comprises two self-assessments, the initial self-assessment form, completed within 30 days of the signing of the contract, and a second application of the same form, at least 60 days before the end of the stage. A hospital going through the process for the first time cannot receive the visit earlier than 12 months from enrolment.

The fourth effect is the visit, which is given detailed rules. It opens with a kick-off meeting and takes place with all members of the committee necessarily present. The permitted techniques are document analysis, the interview, which is held in confidence and without audio or video recording, direct observation, the focus group, the simulation of certain processes and the Tracer technique, through which the committee follows the real path of a patient through the hospital. The simulation is announced at the kick-off meeting, without saying when and where it will take place. At the end of each checklist, the evaluator is obliged to show the person interviewed the rating given and the observations recorded, and any disagreement is noted as a divergent point of view. The last day closes with a 60-minute information meeting, at which the main findings are presented but at which it is forbidden to communicate the accreditation category or the level of fulfilment of the requirements.

The fifth effect appears when something goes wrong during the visit. The methodology lists seven critical safety situations, from the transfer of a patient between the ward and the operating suite in conditions that do not prevent contamination, through to uncontrolled access to the electrical panels or to the oxygen sources and the improper storage of medical waste. A finding of that kind stops the visit immediately, is recorded in a report communicated to the hospital’s legal representative and to the authority, and the hospital has to take protective measures without delay. The evaluator’s guide may set out only how these situations are checked, without adding others.

The sixth effect concerns the means of challenge, and here the deadlines are short and mutually exclusive. After the draft evaluation report, the hospital has 5 working days for objections, otherwise it loses the right. After the draft accreditation report it again has 5 working days, but has to choose: an objection, only on the measurable elements changed by the authority, or a complaint, on anything else. The two cannot be used together, and each can be supported only with documents issued before the date on which the visit ended. The outcome is final in the administrative procedure, and beyond it there remains the administrative court.

The seventh effect comes after accreditation. The certificate and the descriptive supplement are issued within no more than 30 days of the communication of the order, the list of accredited hospitals is published in the Official Gazette of Romania, and the hospital has 30 days from that publication to display the insignia of accreditation. The category obtained, the score and the measurable elements found non-compliant or partially compliant are sent to the supervising authority, to the public health directorate, to the health insurance house the hospital has a contract with and, where applicable, to the Ministry of Health. Accreditation may be suspended for at most 6 months, with weekly reporting of the remedial measures, and within three days of the communication of the order the hospital has to display the words „acreditare suspendată”, accreditation suspended, over the insignia. If the non-conformities have not been remedied when the suspension expires, accreditation is withdrawn.

What has changed compared with the previous situation

The first change shows in the structure of the table. Decision no. 3 of 5 August 2026 of the Governing Board, cited in the preamble, said that the 3rd edition „se va elabora prin actualizarea și revizuirea ediției a II-a a standardelor ANMCS prin continuarea acesteia cu trei referințe”, would be drawn up by updating and revising the 2nd edition of the ANMCS standards and continuing it with three references. The annex as published has exactly three references, numbered 01, 02 and 03, and all the codes beneath them start afresh. Had it been a continuation, the numbering would have gone on from the last reference of the 2nd edition. In its published form, Annex no. 1 is the complete set of standards of the third cycle, not an addition on top of the old one.

The second change brings into accreditation two subjects that were not checked at a hospital until now. Standard 01.11 requires the management of information and digital risks and of artificial intelligence systems: an inventory of the applications used in care, including remote monitoring and virtual consultations, an assessment of the need and of the risks before any new system is introduced, a record of the artificial intelligence systems with the stated purpose of each, the maintenance of human oversight, with the decision remaining the professional’s responsibility, monitoring of the systematic errors of the algorithms, and alternatives for patients without access to technology. Standard 01.10 requires environmental sustainability and climate resilience: a strategic plan with measurable objectives for reducing carbon emissions, deadlines for the switch to renewable sources, monitoring of the consumption of energy, water, materials and medicines, and measures to reduce waste.

The third change raises ethics to a reference of its own. Reference 03 has three standards, patient autonomy, equity and the principles of beneficence and non-maleficence, and beneath them sit concrete requirements that used to get lost in other chapters. The hospital has to regulate the exercise of the right to a second medical opinion and must not raise unjustified barriers to it, including where the patient seeks that opinion outside the hospital. It has to regulate separately the photographing and video recording of patients, by distinct purposes, and the use of employees’ personal devices to photograph or transmit information about patients. A patient’s refusal to be photographed cannot lead to differential treatment. The ethics council carries out an annual risk analysis of ethical vulnerabilities and examines the patient feedback questionnaires.

The fourth change is one of principle and is set out in Article 4 of the methodology. The existence of a document does not in itself prove implementation, and the absence of a document with a predetermined name does not lead to an unfavourable rating if the objective can be proved otherwise. The text expressly forbids turning a requirement or a checklist into an obligation to draw up separate documents, except where the law requires a particular document. To this are added the principle of uniqueness, under which a requirement receives a single assessment even where the evidence comes from several processes, and the prohibition on asking repeatedly for information the hospital has already supplied or that can be found in public systems.

The fifth change moves the evaluation from structures to processes. Checking is organised around „evaluable processes” and „evaluation pathways”, one process may supply evidence for several requirements and one requirement may be checked through several processes. The list of evaluable processes is, however, approved by a separate act, and the methodology specifies that they are tools of the evaluator, not a compulsory model for the hospital’s internal organisation.

The sixth change concerns hospitals that are already accredited. The order leaves them, until their cycle II certificate ceases to be valid, under the authority’s internal rules, while the methodology says, in its last paragraph, that hospitals with a valid cycle II certificate and without a certificate of enrolment in the third cycle are monitored until their certificate expires against the standards on the basis of which they were accredited. The two wordings do not say the same thing, and the difference has practical consequences, so we have put it under errors.

Advantages and disadvantages

What it improves

  • The score leaves the evaluator’s margin of appreciation. The evaluator assigns ratings to measurable elements, and the result is calculated through the national algorithm, identical for all hospitals, with no intermediate rounding and with the obligation of being reproducible from the ratings and the version of the rules applied.
  • Documentary formalism is forbidden on paper. Article 4 states that a document does not prove implementation and that the absence of a document with a particular name does not attract an unfavourable rating if the objective can be demonstrated otherwise. A hospital no longer has to write procedures merely to have something to show.
  • Unpublished rules cannot be used. Article 1(7) and Article 41(2) forbid a technical instruction, a checklist or a change in the application from altering the subject matter of the evaluation or the procedural rights if it was not published before being applied.
  • The standards, the measurable elements, the weightings, the rules and the thresholds approved for a cycle can no longer be changed during it. A hospital that has prepared for two years does not arrive at the visit facing requirements other than those it read at the outset.
  • The interview is held in confidence and without audio or video recording, the patient’s participation is voluntary, and access to patient data is preferably anonymised, with no directly identifiable data in the evaluation file. Evaluators are forbidden to take photographs or make recordings on personal devices.
  • Methodological guidance exists, but cannot be used against the hospital. It produces no ratings, does not guarantee the outcome and cannot be invoked later, and the pre-visit may not turn into advice on how to obtain a particular result.
  • Rescheduling caused by a lack of resources at the authority costs the hospital nothing and does not affect the continuity of its accreditation, and the authority exceeding the deadlines placed upon it cannot produce unfavourable effects for the hospital.

What remains a problem

  • The standards are not in the ordinary issue of the day. The annexes appeared only in no. 808 bis, which is bought separately from the Public Relations Centre, although Article 41(1) obliges ANMCS to publish the standards „într-o formă accesibilă”, in an accessible form.
  • The half that produces the score is missing. The framework of the measurable elements, the algorithm, the register of dependencies, the list of evaluable processes, the accreditation categories and the thresholds are approved by separate acts, 14 of them, listed in Article 42. Without them, a hospital knows what is asked of it but cannot find out what score that produces.
  • The essential requirements are identified nowhere. Failing to meet them suspends accreditation and cannot be offset, but the table of standards does not mark them, and the methodology defines them only in the abstract.
  • The deadlines are not symmetrical. The hospital has 3 or 5 working days, and loses the right if it is late, whereas the accreditation report stage has 3 months that can be extended by a simple written notification, with no limit written into the text.
  • Capacity is capped. Planning cannot exceed 20 hospitals a month, so at most 240 a year, nor 50% of the active evaluators registered by speciality. The second cap can bite well below the first, in the specialities with few evaluators.
  • For a hospital entering for the first time, the visit cannot take place earlier than 12 months from enrolment, although the preparation stage has a minimum of 6 months. That leaves half a year in which the minimum duration of preparation has been served but the visit still cannot take place.
  • The regime of hospitals that are already accredited is described twice, in the order and in the methodology, in terms that do not coincide.
  • The internal cross-references are wrong in ten places, most of them out by one paragraph, including in the articles on exclusion, on the suspension of accreditation and on stopping the visit.

Practical advice

  1. Obtain issue no. 808 bis or watch for the publication of the annexes on www.anmcs.gov.ro. The order in the ordinary issue contains no requirement at all, only their approval, so a hospital that reads no. 808 alone learns nothing of what it has to do.
  2. Gather your evidence along the four dimensions of each requirement, not by documents. EM1 asks for capacity, EM2 for application in real processes, EM3 for the results tracked and EM4 for their use in improvement. An approved procedure covers the first dimension and says nothing about the other three.
  3. Take stock now of your digital systems and of your artificial intelligence systems. Requirements 01.11.01.01 and 01.11.02.01 ask for a record with the stated purpose of each system, while 01.11.02.03 asks for monitoring of the systematic errors of the algorithms and for non-digital alternatives for patients without access to technology.
  4. Do not write new procedures merely for accreditation. Article 4(2)(i) and Article 4(4) forbid turning a requirement into an obligation to draw up a separate document, and the improvement measures can be built into the operational, clinical or internal control plans already in use.
  5. Upload into CaPeSaRo, in the „Documentele calității” section, the quality documents, everything you want taken into account before the pre-visit begins. The application blocks uploading at the start of the evaluation stage, on the ground that new rules can no longer be implemented in the time left.
  6. Choose carefully between an objection and a complaint against the draft accreditation report. You have 5 working days, the two paths are mutually exclusive, the objection concerns only the measurable elements changed by the authority, and both can be supported only with documents issued before the date on which the visit ended.
  7. Record disagreements on the spot during the visit. Consensus on a measurable element is taken to have been reached only if the rating was presented to you and you did not record a divergent point of view, and errors in the checklists can be flagged only up to the end of the day of the visit.
  8. If your hospital holds a valid cycle II certificate, ask the authority in writing which regime applies to it from 23 September 2026. The order and the methodology give different answers, and the difference decides the standards against which you will be monitored and re-evaluated.

Frequently asked questions

From when do the new accreditation standards apply?
From 23 September 2026, the date of publication in the Official Gazette of Romania. Article 4 of the order provides only for publication in the Official Gazette of Romania and on the authority’s website, without a later date, and Article 12(3) of Law no. 24/2000 on legislative drafting rules, republished, provides that orders of the heads of specialised central public administration bodies enter into force on the date of publication unless they provide otherwise. The three-day period from publication concerns laws and ordinances, not orders.
Where do I find the text of the standards?
In the Official Gazette of Romania no. 808 bis of 23 September 2026, pages 3 to 56. The bis issue is not distributed together with the ordinary one, and the note on page 9 of issue no. 808 sends the buyer to the Public Relations Centre at șos. Panduri no. 1, block P33, ground floor, sector 5, Bucharest. Article 41(1) of the methodology obliges the authority to publish the standards in an accessible form, so they should also appear on www.anmcs.gov.ro.
How many requirements does a hospital have to meet?
The table in Annex no. 1 has 589 items: 3 references, 30 standards, 123 criteria and 433 requirements. The requirements are the concrete level, the one that is checked; references, standards and criteria are levels of grouping. Each applicable requirement is analysed along four dimensions, called measurable elements, so the number of individual assessments is larger than 433.
Who gives the score and how is it calculated?
The evaluator gives no score. The evaluator assigns each measurable element one of seven ratings: „Conform”, „Conform parțial”, „Neconform”, „Neaplicabil”, „Nu a fost cazul”, „Neevaluabil” or „Documentat insuficient”, that is compliant, partially compliant, non-compliant, not applicable, not the case, non-assessable or insufficiently documented. The result, the level of implementation and the accreditation category are calculated through the national algorithm, identical for all hospitals. The components of the algorithm, the categories and the thresholds are to be approved by separate acts, so on 23 September 2026 they are not yet published.
How long does the process take, from enrolment to certificate?
For a hospital entering for the first time, at least 17 months. The visit cannot take place earlier than 12 months from enrolment. After the visit closes, 25 working days add up for the draft evaluation report, the objections, the replies, the evaluation report and the handover of the file. The accreditation report stage takes 3 months, and the certificate is issued within no more than 30 days of the communication of the order.
What happens to a hospital already accredited in the second cycle?
It depends which text you read, and that is the problem. Article 2(3) of the order says that, until the cycle II certificate ceases to be valid, monitoring, re-evaluation and re-accreditation are carried out under the authority’s internal rules in force on the date of the evaluation. Article 43(4) of the methodology says that hospitals with a valid certificate and without a certificate of enrolment in the third cycle are monitored against the standards on the basis of which they were accredited. The first points to tomorrow’s rules, the second to yesterday’s.
What stops an evaluation visit while it is under way?
A critical safety situation, that is a shortcoming generating a serious and immediate risk, the loss of a mandatory condition for taking part in the evaluation, significant discrepancies between the declared and the observed situation, restriction of the committee’s access, or the impossibility of applying the evaluation techniques for reasons attributable to the hospital. The visit may be suspended, if the situation can be remedied without affecting the period provided for, or it may be interrupted. Interruption does not mean that the hospital has been declared non-compliant and is not an accreditation outcome.
Can I challenge the result, and within what time?
Yes, within 5 working days of receiving the draft accreditation report, but you have to choose: an objection, only on the measurable elements changed by the authority, or a complaint, on any other element. The two paths are mutually exclusive, and failing to send either in time extinguishes the right. The outcome is final in the administrative procedure. The order classifying the hospital in an accreditation category can be challenged before the administrative court, under Law no. 554/2004.

Errors and inconsistencies in the published text

  • Article 2(3) of the order against Article 43(4) of the methodology. The order says that, for hospitals accredited on the date it enters into force, until their cycle II certificate ceases to be valid, monitoring, re-evaluation and re-accreditation are carried out „în conformitate cu reglementările interne ale Autorității Naționale de Management al Calității în Sănătate, în vigoare la data evaluării acestora”, in accordance with the internal rules of the National Authority for Quality Management in Healthcare in force on the date of their evaluation. The methodology says, in its last paragraph, that hospitals with a valid cycle II certificate and without a certificate of enrolment in the third cycle are monitored until their certificate expires „cu aplicarea standardelor și reglementărilor legale și normative adoptate de ANMCS, pe baza cărora au fost acreditate”, applying the standards and the legal and regulatory provisions adopted by ANMCS on the basis of which they were accredited. The benchmark differs: the first text points to the rules of the day of the evaluation, which from 23 September 2026 are those of this order, the second to the rules of the 2nd edition. On top of that, Article 43(2) provides that internal rules conflicting with the methodology are to be read in the sense of the methodology, which empties the reference in the order of content. And for re-evaluation and re-accreditation a third answer appears: Article 38(1) says that re-evaluation uses the standards and thresholds applied at the initial evaluation. A hospital accredited in the second cycle cannot establish from the text the standards against which it will be monitored and re-evaluated.
  • The essential requirements, Article 27(3)(c) and Article 34(3). Failure to meet an essential requirement is a ground for suspending accreditation and is checked separately, with no possibility of offsetting. Which requirements are the essential ones cannot be established from the published act. Article 27(3)(c) refers to requirements „definite conform prezentei metodologii”, defined in accordance with this methodology, and the methodology defines them only in the abstract, in Article 2(fff), as requirements whose non-fulfilment may generate a major risk and which trigger limiting effects „stabilite anticipat prin algoritmul național de evaluare”, established in advance through the national evaluation algorithm. The table in Annex no. 1 does not mark them: the „Tip” column has only four values, R, S, Cr and C. Nor does Article 42, which lists the 14 subsequent acts, provide for an act that would identify the essential requirements. At the same time, Article 41(2) forbids the use of validation criteria or rules not published before the evaluation. The result is a sanction whose factual condition cannot be determined from any published text.
  • Article 25(5), Article 25(6)(b) and Article 25(7). All three refer to „alin. (3) lit. f)” and to „alin. (3) lit. a) – e)”, paragraph (3) letter f) and paragraph (3) letters a) to e). Paragraph (3) of Article 25 is a single sentence about the consequences of the accreditation process ending, and it has no letters. Letters a) to g) belong to paragraph (4), the one listing the cases of exclusion. The wrong references decide two things with direct effect: in which case the authority may order exclusion without notifying the hospital and without granting it the 5 working days for explanations, and in which cases the 30-day ban on re-enrolment applies. As drafted, neither of the two has an identifiable case.
  • Article 19(1)(a). The text obliges the committee to stop the visit immediately upon „o situație critică de siguranță definită conform art. 18 alin. (27)”, a critical safety situation as defined in accordance with Article 18(27). Paragraph (27) of Article 18 contains no definition but an open list, „pot constitui situații critice de siguranță, următoarele situații”, the following situations may constitute critical safety situations, with seven letters. The definition is in paragraph (26) of the same article and, in identical terms, in Article 2(hh). Two readings follow: that stopping the visit is triggered only in the seven listed cases, or that it is triggered by any shortcoming meeting the general definition. In the same sentence, the duty to inform refers to „art. 18 alin. (30)”, which concerns the measures taken by the hospital; the communication of the report to the legal representative and to the authority sits in paragraph (29).

Editorial analysis

The 3rd edition is, as a text, better than the one it replaces. The ban on documentary formalism, the rule that a document does not prove implementation, the uniqueness of the assessment of a requirement, the ban on asking twice for the same information and the obligation that every rule be published before being applied all answer long-standing grievances of the quality management departments in hospitals. Standards 01.10 and 01.11, the environment and artificial intelligence, are natural additions in 2026 and, at 01.11.02.02, the text does something few Romanian acts do: it states expressly that the clinical decision remains the responsibility of the professional, however good the algorithm that assists them.

The first observation that does not show up on a straight read of the act is that what has been published is half a mechanism. We counted the references to acts to be approved separately: Article 42 lists 14, and among them are the national framework of measurable elements and the calculation algorithm, the register of measurable elements and of dependencies, the list of evaluable processes and the checklists, the accreditation fee, the model certificate and, at letter l), the setting of the accreditation categories. Article 5(5), Article 16(3), Article 24(2), Article 24(6) and Article 34(2) each confirm separately that the part producing the figure is not in this order. The practical consequence is that, from 23 September 2026, a hospital can go through registration, enrolment, planning, preparation, the visit and the evaluation report, but the process cannot reach a result: Article 23(2)(b) requires the results to be calculated through the national algorithm, while Article 1(7) and Article 41(2) forbid the use of unpublished rules. The longest stage of the procedure has a minimum of 6 months, so ANMCS has a window in which it can publish what is missing without blocking anything. The window exists, but it is nowhere written down as a deadline.

The second observation comes out of adding up the deadlines. For a hospital enrolling for the first time, at least 17 months pass between enrolment and certificate: 12 months to the earliest date on which the visit can take place, under criterion 5 in Article 10(5), then 25 working days from the chain that follows the visit, that is 5 for the draft evaluation report, 5 for the hospital’s objections, 5 for the committee’s replies, 5 for the evaluation report and 5 for the handover of the file. On top of those come 3 months for the accreditation report stage and a further 30 days for the certificate. Put on a calendar, starting from an enrolment on 23 September 2026, the certificate arrives at the end of February 2028 at the earliest. Within that calendar, the allocation of time is visibly uneven. The hospital has 3 working days to complete its file at enrolment, 5 to formulate objections to the draft evaluation report, 5 to the draft accreditation report, 5 to give explanations before exclusion and 5 to send the action plan after a suspension, and at three of those deadlines lateness means losing the right. On the other side, the accreditation report stage has 3 months that are extended by a written, reasoned notification stating the new deadline, and the text limits neither the length nor the number of extensions. Article 43(1) provides that the exceeding of deadlines placed upon ANMCS cannot produce unfavourable effects for the healthcare unit, but for a hospital whose old certificate is expiring, a stage extended indefinitely is precisely the unfavourable effect that the paragraph forbids.

The third observation concerns the upkeep of the text. We checked the internal cross-references of the methodology one by one and found ten that lead somewhere other than where the sentence making them says. In Article 15(5), the obligations and prohibitions of the committee coordinator are sent to paragraph (14), which deals with the criteria for setting up the committee, instead of paragraph (17), which contains the prohibitions, while the flagging of conflicts of interest is sent to paragraph (7) instead of (8). In Article 19(1), both references to Article 18 are out by one paragraph. In Article 25, three references land on the letters of a paragraph that has no letters. Article 27 contradicts itself: paragraph (10) correctly sends the action plan to paragraph (6), while paragraphs (12)(b), (13) and (14) send it to paragraph (5), where there is nothing of the kind. The constant one-paragraph offset, in both directions, is the signature of a renumbering carried out without rereading the references. The same lack of upkeep shows in the glossary: letter kk) assigns the acronym CR to the reception committee, letter t) assigns Cr to the criterion, and in Annex no. 1 item 02.05.03 is printed „CR”, although it is a criterion. Letter eee) uses NC for the rating „Neconform”, non-compliant, while Article 29(o) uses NC for „notă de constatare”, a finding note. None of these alone changes a legal solution, but together they say something about how close to the printing press the text was closed.

The fourth observation concerns capacity and is a simple multiplication. Criterion 1 in Article 10(5) caps planning at a maximum of 20 hospitals a month, so at 240 a year, and at the same time requires that 50% of the number of active evaluators registered by speciality in the ANMCS register not be exceeded. The second cap works as a second constraint, and in the specialities with few evaluators it is reached well before the cap of 20. Criterion 4 shows where the difference goes: the places left free after criteria 2 and 3 have been applied are filled with the hospitals that in the previous cycle were excluded, withdrew or received the category „neacreditat”, not accredited. The order of priority in planning is therefore set by what is left free once the statutory deadlines have been observed, not by the age of the application and not by the risk to the patient.

What should be changed

  • The annexes ought to be published free of charge and in searchable form on the ANMCS website, not only in the bis issue. Article 41(1) already requires the standards to be published in an accessible form, and Article 4 of the order provides for publication on www.anmcs.gov.ro. As long as the only place where the 589 items can be found is an issue bought over the counter, the act’s transparency obligation is met on paper alone.
  • The acts listed in Article 42 ought to be given a deadline written into the methodology. A 90-day deadline for the framework of measurable elements, for the algorithm and for the accreditation categories would turn the present tacit window into a verifiable obligation and would spare the hospitals scheduled first the risk of a visit that cannot produce a result.
  • The essential requirements ought to be marked in the table of standards itself, through a fifth column. For as long as they sit inside the algorithm, a hospital cannot know which of the 433 requirements can suspend its accreditation, and Article 34(3), which says that failing to meet them cannot be offset, applies to a list its addressee cannot see.
  • The regime of hospitals that are already accredited ought to be written once, in a single place. One sentence in the order, stating that until the cycle II certificate expires the standards and rules on the basis of which the hospital was accredited apply, to monitoring as well as to re-evaluation and re-accreditation, would close the contradiction between Article 2(3) of the order and Articles 43(4) and 38(1) of the methodology.
  • The extension of the accreditation report stage ought to be capped. A single extension, of no more than 30 days, together with an obligation to tell the hospital the new deadline before the original one falls due, would give Article 43(1) practical content. As things stand, the only consequence of overrunning is a notification.
  • The ten wrong references and the three overlapping acronyms ought to be put right by a corrigendum. Three of them sit in the article deciding when a hospital may be excluded without being heard, and two in the article obliging the committee to stop the visit. These are places where the text produces immediate effects, not mere drafting slips.
  • Article 23(8) needs one word changed. The text says that the report settling the objections is issued „de către cel care a soluționat contestația”, by the person who settled the complaint, although paragraph (11) makes the objection and the complaint two mutually exclusive paths. Whoever has lodged objections has no complaint settled, so the act closing the procedure is left without an identifiable issuer.

Original text of the legal act

The text below is reproduced in Romanian, the official form of publication.

The full text, as published in the Official Gazette of Romania

Official Gazette of Romania no. 808 of 23 September 2026 16 pages PDF, 97 KB the act starts on page 9

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The other editions cited: nr. 808 bis/2026

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