In brief

  • Forestry machinery goes into a national electronic register. The commission that accredits harvesting companies, a body operating within the Romanian Forest Employers’ Association (ASFOR), is setting up the National Electronic Register for the record of specific harvesting machinery. Entry in it takes the place of the paper record and proves the annual technical capacity. The register has to be operational within no more than 60 days from 14 October 2026, that is by 13 December 2026.
  • The accreditation file gains two new items. The registration number of the machinery in the register and a sworn statement that neither the company nor its directors have been indicted for illegal felling, theft of trees, damage to young growth above the percentage allowed by the technical standards or corruption offences. Proof that the machinery is registered becomes compulsory in the file only from 1 March 2027.
  • Certificates already issued stay valid until the date written on them. The minimum annual capacity remains 2,500 cubic metres, but an employee with specialist training can no longer be counted for more than one company. The Commission also receives a deadline of its own, 30 working days from the meeting, within which it has to hand over the certificate.
Act: Order of the Minister of Environment, Waters and Forests no. 2.078/2026 amending and supplementing the Regulation on the organisation, operation and composition of the Commission for the accreditation of economic operators for timber harvesting activity, as well as the accreditation criteria for timber harvesting activity, approved by Order of the Minister of Waters and Forests no. 1.106/2018
Published: Official Gazette of Romania, Part I, no. 861 of 14 October 2026, pages 6-11
In force from: 14 October 2026, the date of publication, because the act provides only for publication in the Official Gazette of Romania (Monitorul Oficial), in Article IV, and sets no later date for entry into force. Two obligations do have deadlines of their own: 13 December 2026 for the machinery register and 1 March 2027 for proof of registration in the accreditation file.

The companies that fell timber and take it out of the forest will prove their machinery from an electronic register instead of a pile of certificates. Order of the Minister of Environment, Waters and Forests no. 2.078/2026, published in the Official Gazette of Romania, Part I, no. 861 of 14 October 2026, amends in 14 points the regulation under which economic operators in timber harvesting are accredited, that is the set of rules deciding who is entitled to work on felling sites („parchete”) and for what annual volume. In recent months the ministry has also stepped into the organisation of forest rangers, through Order no. 1.766/2026, which sets how much land one ranger guards, and it now reaches the other end of the chain, the companies that carry out the felling.

The substantive novelty is a register. The new Article 111 of the regulation sets up, at the level of the Accreditation Commission, the National Electronic Register for the record of specific harvesting machinery, and the act states plainly what it is for: it provides the digital record of the machinery held by companies, „necesară calculului capacității anuale de exploatare”, needed for calculating the annual harvesting capacity, replacing the record kept on paper. The accreditation criteria are rearranged around this register, a new document appears in the file, a new ground for withdrawing the certificate is added and an obligation to hold annual training courses is introduced. The Commission operates within ASFOR, a private employers’ association, and ASFOR is the one that will build and keep the register.

What it changes in practice

For a company seeking accreditation, the file looks different from 14 October 2026. Article 12(1) gains a point g1), which calls for the registration number of the machinery in the National Electronic Register, and states that entering the machinery „face dovada asigurării capacității tehnice anuale pentru activități de exploatare forestieră”, proves that the annual technical capacity for timber harvesting activities is secured. The threshold stays at a minimum of 2,500 cubic metres a year. It is worth saying here what cannot be seen if you read only today’s order: the 2,500 cubic metre threshold is not new, it already existed in the old point g) of the same paragraph, in the version checked on the legislative portal. The figure stays the same, the mechanism of proof changes. Until now the volume was demonstrated with the documents showing ownership of the machinery; from now on it is demonstrated with an entry in an electronic register, and the documents remain in the file as an annex to that entry.

Point g) has been rewritten as well, with a clarification that looks small but changes the way the file is filled in: ownership of the machinery is proved with certificates issued by the administrative-territorial unit, submitted in the original, or with copies of the leasing contracts and of the document for the last payment, and the type of forestry machine has to be stated. For draught animal teams, that is traction with animals, two certificates are required, one from the town hall and one from the veterinarian, stating the number of animals fit for draught work. For small mountain companies that use horses to extract the timber, this means one more trip to the veterinary surgery before every submission.

The second new document is a sworn statement, introduced as point k) of Article 12(1), with its own template published as Annex no. 5 to the regulation. Through it, the director, the chairman of the board or, at forest districts, the head of the district declares that neither they nor the company have been indicted for illegal felling on unauthorised felling sites, for illegal felling on sites authorised for harvesting, for damage to usable young growth above the percentage allowed by the technical standards, for theft of trees or for corruption offences. The statement is given under the sanction of Article 326 of the Criminal Code, the article that punishes false statements, and the template in the annex also contains a box for the opposite situation, where the number of the criminal case file, the prosecutor’s office, the court and the stage of the proceedings are entered. The signatory also takes on a duty to update: any change in the situation declared has to be communicated to the Commission in writing, within 10 working days of learning of it, throughout the period of validity of the certificate.

On staffing capacity there is a restriction that will be felt in the market straight away. Article 12(2), rewritten, keeps the list of accepted qualifications, from a high school graduate specialising in forestry or timber harvesting up to an engineer, but adds a sentence that closes an old practice: specialist staff „poate fi luat în calcul în vederea emiterii certificatului de atestare/reatestare doar pentru un singur operator economic”, may be taken into account for the issue of the accreditation or re-accreditation certificate for one economic operator only. In other words, the same technician can no longer appear in the files of two or three companies in order to lift all of them above the capacity threshold.

The list of grounds for withdrawing the certificate grows longer. Besides the rewriting of points b), d) and g) of Article 21(1), a point k) is added: the Commission withdraws the certificate at the request of the institution the enforcement officer belongs to, where that officer has established the harvesting of timber from contracted felling lots without a harvesting permit or without a handover report for the felling site, and where the administrative offence report records the complementary penalty of withdrawing the certificate. The condition is that the report has been communicated and not challenged within the time limit set by Administrative Litigation Law no. 554/2004. What is new is that an unchallenged forestry offence can put a company out of business, where until now a final criminal judgment was needed. And the three-year ban that follows withdrawal, provided for in Article 21(3) and (4), is expressly extended to this new point k) as well, including for companies whose directors or shareholders are the same persons.

In the opposite direction, the duty to notify the Commission narrows. Forestry staff in the ministry concerned, in the National Forest Guard and its structures, in the Romsilva National Forest Administration and the heads of the non-state forest districts have to inform the Commission, within 20 days of establishing the facts, about the situations in points b), d) and e) of Article 21(1). In the previous version, checked on the legislative portal, the list was points a), b) and d). The dissolution of a company thus drops out of the duty to inform, and in its place comes the failure to carry out the revision after a change in the conditions.

The Commission also acquires a deadline it did not have. Article 19(2), in its new wording, states that accreditation or re-accreditation certificates are issued „within no more than 30 working days of the date of the meeting” and are collected from the ASFOR headquarters in Bucharest or from the territorial structures. Rejection notices are sent by post or courier, with acknowledgement of receipt. The old wording governed only the place of collection and the manner of communication, with no deadline at all, so the appearance of the 30 working days is a gain in predictability for companies.

On the composition of the Commission, Annexes nos. 1-3 to the regulation are replaced in full. The Accreditation Commission has 13 members: 10 from the Ministry of Environment, Waters and Forests, one from ASFOR and two from the Association of Forest Administrators of Romania. The secretariat numbers eight people, five from the ministry, one from the Romsilva National Forest Administration and two from ASFOR. Annex no. 3, the standard application form for the issue of the certificate, is republished with the table for calculating the annual capacity and with the list of attached documents, and the note at the end of the calculation keeps the sizing rule: the total annual capacity is the smaller of the volume resulting from the machinery and the volume resulting from the specialist staff. Finally, Article 27 is amended to take the regulation from four annexes to five.

What has changed compared with the previous situation

The regulation approved by Order no. 1.106/2018 is in force and has been amended several times, most recently, before today’s text, by Orders no. 386/2026 and no. 912/2026. The overlap with the order of 14 October 2026 occurs only on the annexes: today’s text replaces Annexes nos. 1-3 in full, so the lists of people brought into force by the two earlier 2026 orders are rewritten. On the body of articles there is no overlap. The consolidated version on the legislative portal shows that the last intervention in the articles of the regulation recorded there is Order no. 838/2021, published on 11 June 2021, and that the orders from 2024, 2025 and 2026 preceding today’s text worked on the annexes, that is on the composition of the Commission and of the secretariat. Order no. 2.078/2026 is therefore the first substantive amendment of the accreditation criteria since 2021.

The hardest change to spot is the shift of the 2,500 cubic metre threshold. In the previous version it sat in point g) of Article 12(1), next to the obligation to prove the machinery, and was demonstrated through documents. Today point g) keeps only the documents, while the threshold and the evidential force move to point g1), tied to an entry in the register. For an operator preparing the file, the practical conclusion is that a cupboard full of contracts is no longer enough: what counts is whether the machine is entered in the register and under which type, and the act expressly provides that clarifying documents may be requested in order to identify the type of machine.

The second change of regime concerns re-accreditation. Article 13(a) now refers to the documents in Article 12(1) points a), e) to i) and k), which means that the sworn statement on indictment is repeated at every renewal. By contrast, a company that is already accredited does not have to do anything now: Article III(1) provides that certificates issued before 14 October 2026 keep their validity until the expiry of the term written on them or until their withdrawal under the conditions of the regulation. The difference for that company is the moment of re-accreditation, when it will come under the new rules, plus its exposure to the new ground for withdrawal in point k). And files submitted to the Commission’s secretariat are examined under the provisions in force on the date the application was submitted, under Article III(4).

The third novelty is vocational training, which until now was missing altogether. Under Article 261, the professional association within which the Commission operates is required to organise courses for company directors and for specialist staff, with the declared aim of improving knowledge of the legislation and of the harvesting rules, lasting at least 8 hours a year and ending with a certificate of participation for each participant. The timetable, however, is a long one. The methodology for the courses is drawn up and approved within no more than 60 days of entry into force, that is by 13 December 2026, organisation starts within 30 days of the approval of the methodology, and each course is announced on the association’s website at least 15 days in advance. If the methodology is approved on the last day of the deadline, the first course cannot be announced before 12 January 2027 and cannot start before 27 January 2027.

Advantages and disadvantages

What it improves

  • A single place where the machinery is checked. With a national electronic register, the situation in which the same chainsaw or the same forestry tractor turns up in the files of several companies, with no way for the Commission to see the overlap, disappears.
  • The Commission receives a measurable deadline. The 30 working days from the meeting to the issue of the certificate, roughly six calendar weeks, replace a wording from which no time limit at all could be derived.
  • The „one specialist, one company” rule closes a simple way of inflating harvesting capacity artificially, and the declared capacity comes closer to what the company can actually carry out.
  • The sworn statement with a published template forces out information that used to come to light late. An indictment is now known when the file is submitted, not after a final judgment, and a false statement brings in Article 326 of the Criminal Code.
  • Companies that are already accredited are not caught on the wrong foot: certificates stay valid until their term, and files under examination are judged on the rules in force when they were submitted.
  • An unchallenged forestry offence carrying the complementary penalty of withdrawal becomes an express ground for withdrawing the certificate, which shortens the road from a finding in the field to the economic consequence.

What remains a problem

  • The register does not exist yet. Point g1), which calls for the registration number, has been in force since 14 October 2026, while the register has 13 December 2026 as its operational deadline and becomes compulsory in the file only on 1 March 2027.
  • The promise of doing away with paper cannot be seen in the file. The new Article 111 says the register replaces the record kept on paper, but the same machinery is still proved with an original certificate from the town hall, with equipment documents and with photo sheets, under the list in Annex no. 3.
  • For the „one specialist, one company” rule, the instrument that would make it verifiable is missing. The electronic register covers the machinery alone, so the Commission is left with a manual comparison between files.
  • The 8 hours of courses a year are tied to nothing. The certificate of participation does not appear among the documents required for accreditation or re-accreditation, and the act provides no consequence for whoever fails to attend.
  • The deadlines are asymmetrical. The signatory of the statement has 10 working days to report any change, forestry staff have 20 days to notify the Commission, and the Commission reserves 30 working days for itself to hand over a certificate already approved in a meeting.
  • Building and running the register falls on a private employers’ association that holds one seat out of 13 on the Accreditation Commission. The act says nothing about public access, registration fees, a time limit for dealing with an application for entry or a way of challenging a refusal to register.

Practical advice

  1. If you hold a valid certificate, do not submit anything now. Note the expiry date in your calendar and prepare the re-accreditation file under the new rules at least three months in advance, because entering the machinery in the register becomes compulsory from 1 March 2027.
  2. Take stock of your machinery with the exact type of each machine. The act provides that clarifying documents may be requested in order to identify the type of machine, and a vague description in the file translates into further requests and days lost.
  3. Check whether any employee with specialist training also appears in another company’s file. From 14 October 2026 that person can be counted for one operator only, so two companies in the same group can no longer lean on the same technician.
  4. If you work with draught animal teams, obtain the certificate from the town hall and the one from the veterinarian in good time, with the number of animals fit for draught work. They are two separate documents, not one.
  5. Prepare the sworn statement separately for each director. The note in the published template provides that, where the company has more than one director, the statement is submitted separately by each of them.
  6. If you receive a forestry administrative offence report recording the complementary penalty of withdrawing the certificate, challenge it within the time limit in Law no. 554/2004 if you have grounds. The new point k) of Article 21(1) is triggered only for a report that has been communicated and not challenged in time.

Frequently asked questions

Is my accreditation certificate still valid after 14 October 2026?
Yes. Article III(1) provides that accreditation or re-accreditation certificates issued before the order entered into force keep their validity until the expiry of the term written on them or, as the case may be, until their withdrawal under the conditions of the regulation. Nothing further has to be submitted at this point.
Do I have to register my machinery straight away?
It is not possible yet, because the register is still to be developed and made operational within no more than 60 days from 14 October 2026, that is by 13 December 2026. The obligation to put proof of registration in the accreditation, re-accreditation or revision file runs from 1 March 2027, under Article III(2).
Has the minimum volume for which I can be accredited changed?
No. The annual timber harvesting capacity remains at a minimum of 2,500 cubic metres. What has changed is where the threshold sits, moved to the new point g1) of Article 12(1), and the way it is proved, through entry of the machinery in the electronic register and not only through the documents of ownership.
How is the annual capacity calculated, on machinery or on people?
On both, and the final result is the smaller of the two. The note in Annex no. 3 is explicit: the total annual capacity is the smaller volume resulting from comparing the total capacity given by the machinery with the one given by the specialist staff. From 14 October 2026 a specialist can be counted for one company only, so the staffing side is harder to lift.
A director of the company has been indicted. What happens next?
The fact has to be declared, with the number of the criminal case file, the prosecutor’s office, the court and the stage of the proceedings, in the sworn statement introduced as point k) of Article 12(1). The order does not expressly provide what the Commission decides in such a case at accreditation. For a company that already holds a certificate, indictment is dealt with separately in Article 21 of the regulation, and false information in the statement brings withdrawal of the certificate and the penalty for false statements.
Am I required to attend the vocational training courses?
The obligation written in the new Article 261 belongs to the professional association within which the Commission operates: it has to organise courses of at least 8 hours a year for directors and for specialist staff and to issue certificates of participation. The act provides neither an obligation for the operator to attend nor any consequence for not attending, and the certificate of participation does not figure among the documents in the accreditation file.
I own forest and contract out the harvesting. What changes for me?
Your partner has to be accredited, and from 1 March 2027 its capacity will be tied to machinery entered in an electronic register, so the figure on the certificate becomes harder to inflate. A new risk of the contract being interrupted has also appeared: an unchallenged forestry administrative offence report recording the complementary penalty can lead to withdrawal of the certificate, and the company cannot be accredited again for three years after withdrawal.

Errors and inconsistencies in the published text

  • Article I point 3, point g1) of Article 12(1), read against Article III(2) and (4). Point g1) requires the registration number from the National Electronic Register in the file and has been in force since 14 October 2026, together with the rest of the order. Article II(1) gives the association no more than 60 days to develop and make this register operational, that is until 13 December 2026, while Article III(2) states that proof of registration of the machinery enters the file „from 1 March 2027”. Article III(4) adds that files are examined under the provisions in force on the date the application is submitted. Combined, the three provisions leave two incompatible conclusions open for an application submitted between 14 October and 13 December 2026: either the file is incomplete without a number that no company can obtain, because the register does not exist, or point g1) is inapplicable until 1 March 2027, even though it is in force and even though the rule in Article III(4) refers precisely to the provisions in force at submission. Since the admissibility of the file hangs on this, the text needs an express transitional provision stating from what date point g1) applies.
  • Article I point 2, point h) of Article 12(1), against Annex no. 3, section VIII, item 9. Point h) in its new wording requires the criminal record certificate, in the original, only for the director or directors of the company or for the chairman of the board, and at forest districts for the head of the district. The list of documents attached to the application, in Annex no. 3 as republished by the same order, requires at item 9 „Cazierul judiciar al administratorului/administratorilor și al operatorului (original)”, the criminal record certificate of the director or directors and of the operator, in the original, therefore one document more, the criminal record of the legal person, which the article does not provide for. Both texts are brought into force by this order, on the same date, and the divergence decides whether a file is complete or not. The form and the article should be aligned, in either direction.

Editorial analysis

The order is well built where it touches the behaviour of companies. The „one specialist, one company” rule, the sworn statement with a published template and the new point k) of Article 21(1) strike at exactly three known practices in timber harvesting: capacity inflated with borrowed employees, silence about a criminal case under way, and the long distance between an administrative offence report and a real consequence. The 30 working days the Commission sets for itself in Article 19(2) are, in turn, a gain for operators, because the old wording contained no deadline at all.

The problem is not what the order does, but how quickly it does it. The electronic register, its centrepiece, is in force as an obligation from 14 October 2026, has 13 December 2026 as its construction deadline and becomes compulsory in the file on 1 March 2027, that is 138 days after publication. Between 13 December 2026 and 1 March 2027 a window of 78 days opens in which the register ought to be working, yet nobody is obliged to enter it, and the Commission has no way of using it to calculate capacity for the files submitted in that interval. The same kind of delay shows up with the courses: the methodology by 13 December 2026, organisation within 30 days of approval, the announcement 15 days in advance, so the earliest possible course, if every deadline is used in full, falls as late as 27 January 2027. For an obligation of 8 hours a year, that means 2026 passes without a single course.

Then there is an asymmetry of deadlines that deserves to be stated in figures. The company signing the statement has 10 working days to inform the Commission of any change in the situation declared, forestry staff have 20 days to notify the Commission, and the Commission has 30 working days to hand over a certificate it has already approved in a meeting. The ratio between the administration’s deadline and the recipient’s is three to one, in the administration’s favour, for an operation that no longer involves any assessment, just issuing and handing over a document. The institutional architecture follows the same logic of imbalance: the Commission has 13 members, 10 of them from the Ministry of Environment, Waters and Forests, that is 76.9% of the seats, while ASFOR, the association within which the Commission operates and which will build and run the register, has a single seat, 7.7%. In the secretariat the proportions change, five seats out of eight for the ministry and two for ASFOR, but the conclusion stands: the technical task and its cost fall on the entity with the smallest representation in the body that decides.

Finally, in today’s text the promise of digitalisation remains half kept. The new Article 111 says the register replaces the record kept on paper, but the list of documents attached to the application, republished by the same order, still contains, for the same machinery, an original tax certificate from the town hall, documents on the equipment and photo sheets, to which the rewritten point g) adds the originals or the leasing copies. Four paper proofs for an asset that, from 1 March 2027, will have a number in an electronic register anyway.

What should be changed

  1. Introducing a transitional provision stating expressly that point g1) of Article 12(1) applies to files submitted from 1 March 2027. The result: the risk that a file submitted in the autumn of 2026 is rejected for lack of a register number that cannot be obtained disappears.
  2. Aligning item 9 of the list of documents in Annex no. 3 with the text of point h), either by removing the criminal record certificate of the economic operator or by adding it to the article. In practice, the applicant then knows from the form exactly what to submit, and a file can no longer be declared incomplete on the basis of a difference between the article and the annex.
  3. Tying the vocational training courses to a consequence. Either the certificate of participation goes among the documents in Article 13 for re-accreditation, or it is stated plainly that attendance is optional. The result: the obligation of 8 hours a year stops being a cost for the association and an option for companies.
  4. Cutting the deadline in Article 19(2) to 10 working days for certificates approved in a meeting, keeping the 30 days only for cases that call for clarifying documents. In practice, a company that has passed the Commission can sign contracts three weeks sooner.
  5. Setting the minimum rules of the register by order: the time limit for dealing with an application for entry, whether it is free or carries a fee, the level of access forest owners have in order to check an operator, and the way to challenge a refusal to register. The consequence: proof of technical capacity no longer depends on the unwritten internal procedure of a private association.
  6. Extending the register, at a later stage, to specialist staff, with a record showing which operator each employee is counted for. Practical effect: the „one specialist, one company” rule becomes verifiable automatically, instead of through a manual comparison of files.

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. 861 of 14 October 2026, pages 6-11 16 pages PDF, 100 KB the act starts on page 6

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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.