In brief

  • Parliament approved the ordinance on tax consultancy with a single change of its own, and that change has nothing to do with tax consultancy. Law no. 188/2026 rewrites Article III of Government Emergency Ordinance no. 49/2025 and extends until 30 September 2027 the right of the Ministry of Internal Affairs to recall reserve officers to active service and to fill posts without a competition, for migration and asylum, emergency situations and public order.
  • The old deadline expired on 30 September 2026, that is, five days after the law was published. The law enters into force on 28 September 2026, the third day after publication, so it catches the deadline with two days to spare. The measure had been designed in March 2022 for at most three years, and the new deadline takes it to 2,032 days, with a gap of 205 days in the middle.
  • Everything concerning tax consultancy stays as it has been since 29 September 2025. The approved ordinance had widened the list of tax consultancy services, opened the examination to law graduates, regulated the recognition of consultants from States that have adhered to the OECD codes, and provided for a protocol of cooperation between the Chamber of Tax Consultants, the Ministry of Finance and the National Agency for Fiscal Administration. Those concerned are candidates for the tax consultant examination, firms in the field and, separately, the staff of the Ministry of Internal Affairs.
Act: Law no. 188/2026 on the approval of Government Emergency Ordinance no. 49/2025 amending and supplementing Government Ordinance no. 71/2001 on the organisation and practice of tax consultancy, and laying down certain measures, and Decree no. 772/2026 for the promulgation of that law
Published: Official Gazette of Romania, Part I, no. 820 of 25 September 2026, page 2
In force from: 28 September 2026, the third day after publication, because Article 12(1) of Law no. 24/2000 on legislative drafting rules provides that laws enter into force 3 days after publication in the Official Gazette of Romania (Monitorul Oficial), unless they themselves contain a later date, and Law no. 188/2026 does not

A law approving an emergency ordinance usually goes unnoticed, because most often it confirms what has already been in force for months. This one does not merely confirm. Law no. 188/2026, published on 25 September 2026, approves Government Emergency Ordinance no. 49/2025, the one that changed the rules of the tax consultant profession and on the basis of which the Chamber of Tax Consultants set the syllabus and the date of the examination of 31 October 2026. The approval comes, however, with one amendment, and the amendment concerns something else entirely: appointments without a competition in the Ministry of Internal Affairs.

The text of the law has a single article. It approves the ordinance published on 29 September 2025 in Official Gazette of Romania, Part I, no. 889, with one change, to Article III. That article does not speak about tax consultants. It fixes the date until which the measures laid down in Articles II and III of Government Emergency Ordinance no. 20/2022 apply, the ordinance on support and humanitarian assistance adopted at the beginning of the war in Ukraine. In the form given by the Government, the date was 30 September 2026. In the form given by Parliament, it is 30 September 2027.

What exactly is being extended. Article II of Government Emergency Ordinance no. 20/2022 allows the Ministry of Internal Affairs to recall to active service or to reappoint, without a competition and with their consent, military personnel and police officers placed in the reserve, for a fixed term of one year, renewable annually. The third article allows it to appoint staff without a competition for activities in the fields of migration and asylum, emergency situations, and public order and safety, also for a fixed term. Both had been designed as crisis measures, linked to the influx of people from Ukraine, and capped at no more than three years from the entry into force of the ordinance, that is, until 8 March 2025.

The chain of extensions is short and easy to follow. Emergency Ordinance no. 20/2022 entered into force on 8 March 2022, with a three-year cap. Emergency Ordinance no. 49/2025 restarted the clock from the date of its own entry into force, 29 September 2025, and carried the measures to 30 September 2026. Through the law published on 25 September 2026, the date reaches 30 September 2027. The wording remains the one from the ordinance, so the new text says that the measures apply from the entry into force of the ordinance, the one of September 2025, until 30 September 2027.

The part about tax consultancy is left untouched and has applied since 29 September 2025. The ordinance widened the list of services a tax consultant may provide, with assistance and representation before the tax authorities and with the preparation of documents for challenges. It opened the entry examination to graduates in law, not only to graduates in economics. It regulated the recognition of tax consultants from States that have adhered to the OECD codes of liberalisation of capital movements and of current invisible operations, on terms similar to those for consultants from the European Union. And it provided for a protocol of cooperation between the Chamber of Tax Consultants, the Ministry of Finance and the National Agency for Fiscal Administration, for taxpayers’ compliance. Parliament changed none of those provisions.

Decree no. 772/2026, signed by the President of Romania on 25 September 2026, promulgates the law under Article 77(1) and Article 100(1) of the Constitution and orders its publication. The law was adopted in compliance with Article 75 and Article 76(2) of the Constitution, that is, as an ordinary law, and was signed by Natalia-Elena Intotero, for the President of the Chamber of Deputies, and by Mircea Abrudean, President of the Senate.

What it changes in practice

The first effect is felt by the Ministry of Internal Affairs. From 28 September 2026 until 30 September 2027, the ministry may go on appointing staff without a competition for migration and asylum, emergency situations, and public order and safety, and may recall reservists to active service. Without this law, the instrument would have disappeared on 30 September 2026, and the posts would have been filled only by competition, with the usual deadlines and stages.

The second effect concerns contracts currently running. Appointments made under Articles II and III are for a fixed term and are renewed annually, with the consent of the person concerned. A contract that would have come to an end in the autumn of 2026 can go on, because its legal basis stays in force for another year.

The third effect is the one produced by any approving law: it stabilises the ordinance. Until 28 September 2026, the rules on tax consultancy rested on an emergency ordinance that Parliament could still reject or substantially amend. Now they are confirmed by law, so consultancy firms and candidates for the examination know which text they are working on. The examination of 31 October 2026 is organised on confirmed rules, with no risk of a change in the middle of the session.

What has changed compared with the previous situation

Compared with the Government’s text, one date has changed: 30 September 2026 became 30 September 2027. Nothing else in the ordinance was amended, supplemented or removed. In terms of content, the approving law is a law with one word changed, and that word is a year.

Compared with the situation of March 2022, the nature of the measure has changed. The three-year cap had been put there precisely because this was a crisis measure. The extension of September 2025 and the one of September 2026 take the total duration to 2,032 days, that is, more than five and a half years from the first day. Between 8 March 2025, when the initial cap expired, and 29 September 2025, when the ordinance that restarted the period entered into force, there are 205 days in which the text does not show on what basis appointments without a competition could have been made.

For the tax consultant profession nothing changed on 25 September 2026. The real change there had taken place a year earlier, through the ordinance, and the law merely confirms it.

Advantages and disadvantages

What it improves

  • It catches the deadline before it expires. The law produces effects from 28 September 2026, and the old date was 30 September 2026, so there is not a single day on which the ministry is left without a legal basis.
  • It fixes a calendar date, not a condition. The text says 30 September 2027, a reference point anyone can check, instead of a formula tied to how long a state of affairs lasts.
  • It confirms by law the rules of the tax consultant profession, which until now rested on an emergency ordinance that had not been approved. Candidates for the examination of 31 October 2026 no longer risk a change of rules in the middle of the session.
  • Parliament added nothing on top of the ordinance. No new tax provisions appear, which with approving laws happens fairly often.
  • The amendment is visible on a first reading. The replaced text appears in full in the law, so the reader does not have to reconstruct the new form from cross-references.

What remains a problem

  • The title of the law says nothing about the only change it brings. Anyone looking for an extension of the appointments without a competition in the Ministry of Internal Affairs will not find it in an act named after tax consultancy.
  • A measure capped at three years reaches more than five and a half, through successive extensions placed in acts that are about something else entirely. The initial cap loses its meaning if it can be moved at any time.
  • The law does not say how many people are currently appointed under Articles II and III, nor in what posts. Without that figure, the extension cannot be weighed by anyone outside the ministry.
  • It remains unclear what happens to the condition in the 2022 ordinance, which ties the measures to the situation of a massive influx of people from Ukraine and gives them at most 90 days after it ends. A fixed date and a factual condition can lead to different answers.
  • There is no published evaluation of how the instrument has worked over the nearly four years of actual use, even though this is the second extension in a row.

Practical advice

  1. If you hold a fixed-term post in the Ministry of Internal Affairs under Government Emergency Ordinance no. 20/2022, ask the human resources unit in writing to confirm that the basis of your contract is extended until 30 September 2027.
  2. If you are preparing for the tax consultant examination, work on the form of the ordinance of 29 September 2025. The approving law changed none of the rules on entry into the profession.
  3. Check the date of 28 September 2026 when you calculate the effects. The law does not produce effects from the day of publication, but from the third day, under Article 12(1) of Law no. 24/2000.
  4. If you are a law graduate and want to sit the examination, read the seniority conditions in Government Ordinance no. 71/2001 in its consolidated form, because the 2025 ordinance also changed the fields of experience that are accepted.
  5. When you read an approving law, go straight to the formula that follows the number of the ordinance. If it says that it is approved with amendments, the only real novelty sits there, and the rest of the text merely confirms what was already being applied.

Frequently asked questions

What has this law actually changed?
A single calendar date. Article III of Government Emergency Ordinance no. 49/2025 said 30 September 2026, and now says 30 September 2027. The deadline concerns appointments without a competition in the Ministry of Internal Affairs, not tax consultancy.
Does anything change for tax consultants?
No. The new rules on consultancy services, on access to the examination for law graduates and on the recognition of consultants from States that have adhered to the OECD codes have applied since 29 September 2025, when the ordinance entered into force. The law merely confirms them.
From when does the law apply?
From 28 September 2026, the third day after publication. Article 12(1) of Law no. 24/2000 provides that laws enter into force 3 days after publication in the Official Gazette of Romania, unless they themselves provide a later date.
What does appointment without a competition mean?
Filling a post without the usual selection procedure by competition. The 2022 ordinance allowed it for situations linked to the influx of people from Ukraine, on fixed-term contracts, in the fields of migration and asylum, emergency situations, and public order and safety.
What is the role of the decree published alongside the law?
Decree no. 772/2026 is the act by which the President of Romania promulgates the law and orders its publication, under Article 77(1) of the Constitution. Without promulgation, the law cannot be published and produces no effects.
Can the deadline be extended again after 2027?
Yes. Nothing in the published text prevents a further extension by a subsequent act, as happened in 2025 and in 2026.

Editorial analysis

The law is correctly drafted and contains no faulty references. The ordinances it cites exist, their numbers and dates check out, and the replaced article is reproduced in full, which spares the reader any reconstruction. The discussion starts elsewhere: from a calculation the text does not make.

The measure started on 8 March 2022, with the entry into force of Government Emergency Ordinance no. 20/2022, which gave the Ministry of Internal Affairs a crisis instrument with an explicit three-year cap, that is, until 8 March 2025. The next extension came through Emergency Ordinance no. 49/2025, which entered into force on 29 September 2025, that is, 205 days after the cap expired. The text of that ordinance does not even try to cover the gap: it says that the measures apply from its own entry into force, a wording that reads as a restart, not as a continuation. The law published on 25 September 2026 carries the date to 30 September 2027, and from the first day to the last there are 2,032 days, more than five and a half years for a measure that had been limited to three.

The second observation comes out of the calendar. The law was adopted by Parliament and promulgated on the same day, 25 September 2026, published on the same day, and enters into force on 28 September 2026, a Monday. The deadline it extends expired on Wednesday, 30 September 2026. The margin is two working days. For an ordinance whose effects show up in staff appointments, a week’s delay in promulgation would have left the ministry without a legal basis, and the contracts that are renewed annually would have had to be renegotiated on another footing.

The third observation has to do with where the provision ended up. A reader who wants to find out until when the Ministry of Internal Affairs may hire without a competition has to open, in this order: a law about tax consultancy, an emergency ordinance about tax consultancy and an emergency ordinance about humanitarian assistance from 2022. Three acts with three different subjects for a single calendar date. The problem does not come from Parliament, because Article III had been put there by the Government back in 2025, but the approving law was the moment when it could have been moved to where it belongs.

What should be changed

  • Extensions of crisis measures belong in acts that bear their name. An ordinance or a law on the organisation of the Ministry of Internal Affairs would be the natural place, and anyone looking for the rule would find it on the first search.
  • Every extension should come with a public report. How many people have been appointed on this basis, in what posts, in which structures, and how many of those posts have meanwhile been advertised for competition. Without figures, automatic extension becomes the rule and competition the exception.
  • The fixed date should be reconciled with the factual condition. The 2022 text ties the measures to the influx of people from Ukraine and gives them at most 90 days after it ends. The date of 30 September 2027 should say expressly whether it replaces the condition or is added to it.
  • The title of the approving act should mention the amendment. If a law changes a provision belonging to another field, the title should say so, as required by the rule that the name of an act reflects its subject matter.
  • A review deadline with every extension. The measure could be made conditional on a plan for filling the posts in question by competition, with stages and deadlines, so that the crisis instrument would run out of its own accord.

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. 820 of 25 September 2026, page 2 16 pages PDF, 115 KB the act starts on page 2

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This article is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed attorney or tax advisor.