In brief
- No exemption from the rovinietă works on a person’s word: until written confirmation arrives, the vehicle counts as not exempt. The joint order of the interim minister of transport and infrastructure and of the Deputy Prime Minister, Minister of Internal Affairs, no. 902/147 sets out which documents and which conditions are needed for exemption from payment of the rovinietă and of TollRo, the charges introduced by Law no. 226/2023, plus the procedure by which the Department for Emergency Situations obtains rovinietă certificates and route tickets for civil protection and humanitarian missions. Article 8, Article 13 and Article 16(2) of Annex no. 1 say the same thing three times over: holders may not treat their vehicles as exempt until confirmation comes in writing.
- Who is concerned. On the one hand, the institutions with fleets of their own: the Ministry of National Defence, the Ministry of Internal Affairs, the Romanian Intelligence Service, the Foreign Intelligence Service, the Protection and Guard Service, the Special Telecommunications Service, the National Administration of Penitentiaries, the community public services for emergency situations, CNAIR, the State Inspectorate for Road Transport Control and the National Society of the Red Cross of Romania. On the other hand, the operators of local public passenger transport by regular services, those authorised for school transport and the authorities that own ambulances. The order addresses whoever has a fleet to account for, not the everyday driver.
- The figures and the deadlines that matter. CNAIR has at most 5 working days from receipt of the documents to record the exemption, and the Directorate General for Driving Licences and Vehicle Registration has the same period for the marking in the national register. Applications may be filed from 30 September 2026, while the payment obligation starts on 1 October: whoever is not covered by the automatic carry-over of the old exemptions may be left without confirmation until 7 October. The order appeared 637 days after the deadline of 1 January 2025 that Article 25(3) of Law no. 226/2023 had set for it, that is after the earliest of the three deadlines the law had set itself.
Published: Official Gazette of Romania, Part I, no. 830 of 30 September 2026, pages 8-11
In force from: 30 September 2026, the date of publication; Annex no. 2 applies from 1 October 2026
An ambulance, a school bus or a vehicle belonging to a volunteer fire service does not pay the rovinietă. But the exemption comes from an entry in a database, not from the nature of the vehicle, and until that entry is confirmed in writing any check will find the charge unpaid. Joint order no. 902/147, signed by the interim minister of transport and infrastructure on 24 September 2026 and by the Deputy Prime Minister, Minister of Internal Affairs, on 29 September 2026, was published on 30 September 2026 and puts into practice Article 9(8) and Article 13(8) of Law no. 226/2023. It is the act that goes together with the implementing rules published on the same day and applies from the same date, 1 October 2026.
The structure is simple. Annex no. 1 has three chapters and 17 articles and says what has to be sent, to whom and within what time, for a vehicle to be recognised as exempt. Annex no. 2 has 4 articles and describes an altogether different procedure: how the Department for Emergency Situations obtains rovinietă certificates and route tickets for vehicles carrying out transport on civil protection or humanitarian missions on Romanian territory, or passing through Romania for that purpose. The first annex applies from 30 September 2026, that is immediately, so that applications can be filed; the second applies from 1 October 2026, under Article 4(1) and (2) of the order.
Law no. 226/2023 divides exempt vehicles into two groups, according to who keeps the records. For the units of the Ministry of National Defence, of the Ministry of Internal Affairs, of the Romanian Intelligence Service, of the Foreign Intelligence Service, of the Protection and Guard Service, of the Special Telecommunications Service, and for the National Administration of Penitentiaries, the exemption is granted by a marking in the national register of driving licences and registered vehicles, under Article 9(3) and Article 13(3) of the law. For the other categories, that is the community public services for emergency situations, CNAIR, the State Inspectorate for Road Transport Control, the Red Cross, the vehicles exempted by international treaties, local public transport, school transport and public ambulances, the exemption is granted by an entry in the database of the electronic rovinietă system, under Article 9(2).
The order follows exactly that division. Article 1 of Annex no. 1 requires those in the second group to communicate to CNAIR, on their own responsibility, the list of registration numbers, accompanied by copies of the registration certificates. Article 5 requires those in the first group to send the list to the Directorate General for Driving Licences and Vehicle Registration, for marking. Chapter II, Articles 9 to 13, repeats the mechanism for TollRo, with a shorter list, because TollRo applies only to goods vehicles over 3.5 tonnes.
Two categories receive additional requirements. Operators of school transport must send, under Article 2, the certified copy of the own-account transport certificate for the road transport of passengers and, where applicable, proof of the use of the vehicles on whatever title. Operators of local public transport must send, under Article 3, the route licence for each vehicle. For both, Article 4 ties the exemption to the documents: the vehicles are exempt for the period of validity of those documents, and CNAIR records the exemption with the expiry date of the documents in question. In other words, the exemption lapses by itself and has to be rebuilt at every licence renewal.
Article 14 sets out how the paperwork travels: by electronic means, signed with a qualified electronic signature, or by filing at the registry, and CNAIR and the directorate general publish on their own websites the addresses to which documents are sent. Article 15 adds a requirement for exemptions founded on international agreements: the application must state the agreement or treaty relied on.
The truly useful part for institutions that already held exemptions is Article 17. Vehicles entered or marked as exempt under Government Ordinance no. 15/2002, on the date of its repeal, are deemed to be entered in the new database and marked for the purposes of Article 9(3) of the law, without a fresh application. There is a single exception, and it matters: the vehicles referred to in Article 29(3) of Law no. 226/2023, that is historic vehicles, whose exemption the law has brought to an end and which CNAIR removes automatically from the database. Article 17(2) adds a further saving in paperwork: a marking made for the rovinietă also produces effects for TollRo, so the seven institutions in the first group do not file two applications.
Annex no. 2 is the most concrete part of the order and reads like a dispatch procedure. The application of the Department for Emergency Situations is sent by email and announced beforehand by telephone, as soon as word of the mission comes in. The subject line has a fixed form, „Solicitare roviniete zz.ll.aaaa” or „Solicitare tichet de rută zz.ll.aaaa, ora hh:mm”. The file is in .xls or .xlsx format, and the message may not exceed 10 MB; if it does not fit, it is sent in several messages numbered in sequence. For vehicle combinations, the number of the motor vehicle and that of the towed vehicle are entered together, in the configuration in which they travel.
The response deadlines are written in hours. For applications received between 8:00 and 20:00 on working days and between 10:00 and 14:00 on non-working days and public holidays, the unit designated by CNAIR issues on the same day the minimum number of rovinietă certificates that covers the whole period of the mission, or the route tickets requested. Outside those windows, the deadline is 11:00 on the following day. Route tickets for missions escape the general rule on advance purchase: Article 3(2) expressly provides that they may be issued at any time before the date and hour at which the journey begins, by way of derogation from the deadlines in the implementing rules, where the limit is 24 hours.
What it changes in practice
The first effect is a shift in the burden of proof. Under the regime now closing, Article 18 of the implementing rules approved by Order of the Minister of Transport no. 1.463/2018 required holders to communicate the list of registration numbers and the copies of the certificates, but it did not make the exemption conditional on a written confirmation coming from the administration. The new order does so three times over, in Article 8, in Article 13 and in Article 16(2) of Annex no. 1. In practice, a newly set-up fleet becomes exempt on the day it receives the answer, not on the day it files the papers.
The second effect is a waiting period that can be calculated. Applications may be filed from 30 September 2026, under Article 4(2) of the order, and CNAIR and the directorate general have at most 5 working days from receipt of the documents, under Article 7 and Article 16(1). Counting from 30 September 2026, a Wednesday, the fifth working day falls on 7 October. Between 1 and 7 October, a vehicle that is entitled to the exemption but has not received confirmation runs without being exempt and risks the fine in Article 18(2) of the law, set at between twice and four times the 12-month rovinietă. The practical answer is to buy a rovinietă for the waiting period.
The third effect is the one that spares most institutions any step at all. Article 17(1) carries existing exemptions over automatically, with no formality on the part of the holders. Whoever was entered or marked as exempt on 30 September 2026 stays exempt on 1 October. The effect combines with Article 39(3) of the implementing rules published on the same day, which carries over into the new system the information from the old IT system for issuing, managing, monitoring and checking the rovinietă.
The fourth effect is a loss, and it hits a small and easily forgotten category. Article 17(1) expressly excludes from the automatic carry-over the vehicles referred to in Article 29(3) of Law no. 226/2023, that is historic vehicles. For them, the exemption is not lost because of this order but because of the law, which decided to end it; the order is simply the act that says plainly that they will not be entered in the new database. From 1 October 2026, the owner of a historic vehicle has to buy a rovinietă.
The fifth effect is an exemption that now lapses. For local public transport and for school transport, Article 4 of Annex no. 1 records the exemption with the expiry date of the route licence or of the own-account transport certificate. An operator who renews a licence needs a fresh entry at CNAIR, and between the expiry of the old document and the confirmation of the new one the 5 working days in Article 7 may go by.
The sixth effect concerns the money, not the paperwork. The rovinietă certificates and route tickets issued at the request of the Department for Emergency Situations are not paid for by the applicant, under Article 41 of the implementing rules, but somebody does pay for them: Article 9(5) and Article 13(5) of the law provide for twice-yearly settlement to CNAIR from the State budget, through the budget of the Ministry of Transport and Infrastructure. Article 4 of Annex no. 2 builds the reporting chain that makes settlement possible: CNAIR draws up the statement for the previous half-year and sends it to the Department by the 5th of the first month of each half-year, the Department confirms it within 3 working days of receipt, and CNAIR sends the confirmed statement to the Ministry by the 15th. The three deadlines fit together: from the 5th plus 3 working days there is still room before the 15th.
What has changed compared with the previous situation
The order repeals, on 1 October 2026, Order of the Deputy Prime Minister, Minister of Transport and Infrastructure, and of the Minister of Internal Affairs no. 421/53/2022, published in the Official Gazette of Romania, Part I, no. 409 of 28 April 2022, that is after 1,617 days. The comparison with it shows how far the subject matter of the regulation has widened.
The 2022 order had a single thing to regulate, the procedure for issuing rovinietă certificates free of charge for civil protection and humanitarian missions, and it did so in a single annex. What is more, Article 1 of its procedure confined the application to cases where the deadlines set by Government Ordinance no. 15/2002 could not be met, so it was a fallback for emergencies. Annex no. 2 to the new order no longer carries that condition: it covers any application from the Department for Emergency Situations, urgent or not.
The form has grown longer. The 2022 model had 7 columns to fill in, numbered from 1 to 7: the registration number of the motor vehicle, the registration number of the semi-trailer or trailer, the country of registration, the start date, the end date, the number of days and the remarks. Part A of the new form has 9 columns: the trailer column disappears and in come the vehicle identification number, that is the chassis number, the vehicle category, from A to D, and the emissions class or, for electric vehicles, the entry „ELECTRIC”. Part B, for route tickets, is entirely new and has 17 columns: the country, the registration number and the chassis number of the vehicle, the emissions standard, the category of the combination, the same three items for the trailer, the actual weight, the length, the height and the width of the combination, the start and end date and hour, the point of origin, the intermediate points, the point of destination and the remarks. Article 2(5) of Annex no. 2 does, on the other hand, keep the 2022 rule under which, in the case of a vehicle combination, the number of the motor vehicle and that of the towed vehicle are entered together, in the configuration in which they travel. That rule can be applied only in Part B, which has three columns for the trailer; in Part A, the instruction for column 1 expressly asks for the registration number of the vehicle on its own.
The 2022 order said nothing about money. There was no half-yearly statement, no confirmation from the Department and no deadline for sending it on to the ministry. Article 4 of Annex no. 2 introduces all three, with fixed calendar dates, even though the law required only that the statement be sent by the 15th of the first month of each half-year. Also new is Article 3(4), which governs the amendment or cancellation of an application by the same route and specifies that rovinietă certificates and tickets cancelled before their validity begins do not enter the settlement statement.
On exemptions, the comparison is with Article 18 of the 2018 rules. There, for exemption from the usage charge, the list of registration numbers and the copies of the registration certificates were enough. Now, for local public transport the route licence for each vehicle is required in addition, and for school transport the certified copy of the own-account transport certificate and the proof of use. On the other side, a heavy file has disappeared: the one in Article 18(3) of the 2018 rules, with the identity document, the certificate from the employer or from the town hall and the marriage certificate, required of individuals who wanted exemption from the bridge toll. It has disappeared because the toll has.
One change of substance comes from the law that the order applies, and it is worth saying here because the order is where it becomes visible. Article 3(1)(d) of Government Ordinance no. 15/2002 exempted vehicles „folosite exclusiv în transportul public local de persoane prin servicii regulate pe raza teritorial-administrativă a unei localități”, that is used exclusively in local public passenger transport by regular services within the administrative territory of one locality. Article 9(1)(c) of Law no. 226/2023 says only „folosite în transportul public local de persoane prin servicii regulate”, used in local public passenger transport by regular services. The word „exclusiv” and the limit to the area of a single locality have gone, while Article 3 of Annex no. 1 to the order asks instead for the route licence for each vehicle, which moves the check from a condition of use to a document.
Advantages and disadvantages
What it improves
- Existing exemptions are carried over without a single sheet of paper. Article 17(1) of Annex no. 1 moves them into the new database automatically, with no formality on the part of the holders. Institutions with registered fleets file nothing on 1 October.
- One marking covers both charges. Article 17(2) provides that a marking made for the rovinietă also produces effects for TollRo, so the seven institutions in the first group do not have to send two lists.
- The administration’s deadlines are written down, not left to anyone’s judgement. Article 7, Article 12 and Article 16(1) set a maximum of 5 working days, and Article 16(1) adds the duty to confirm in writing to the holder.
- The file can be sent electronically. Article 14(1) allows transmission by electronic means, with a qualified electronic signature, and paragraph (2) obliges CNAIR and the directorate general to publish the addresses on their own websites.
- Emergency missions escape the 24-hour deadline. Article 3(2) of Annex no. 2 derogates expressly from the advance purchase deadlines in the implementing rules, so a route ticket for a humanitarian mission can be issued at any time before departure.
- The answer for missions has a deadline in hours, weekends included. Article 3(1) requires issue on the same day for applications received between 8:00 and 20:00 on working days and between 10:00 and 14:00 on non-working days and public holidays, and paragraph (3) sets 11:00 on the following day for the rest.
- Settlement has a complete chain of deadlines. Article 4 of Annex no. 2 links the 5th of the month, the 3 working days for confirmation and the 15th, which makes traceable an expense that the 2022 order did not regulate at all.
What remains a problem
- Between 1 and 7 October 2026 there may be a gap in exemption. Applications are filed from 30 September, the obligation begins on 1 October, and confirmation may come on the fifth working day. For anyone outside the automatic carry-over, the only answer is to pay the rovinietă for the waiting period.
- Licence renewal has no filing deadline. Article 4 ties the exemption to the validity of the documents, but no article says how long before expiry the new papers have to be filed, while Article 7 gives CNAIR 5 working days. The 2018 rules had exactly such a rule, in Article 18(4), for the toll exemption, and it has not been replaced by anything.
- Historic vehicles drop off the list of exemptions. Article 17(1) expressly excludes them from the automatic carry-over, and the list in Article 9(1) of the law no longer covers them. Their owners pay the rovinietă from 1 October 2026.
- The order appeared 637 days late. Article 25(3) of Law no. 226/2023 required it by 1 January 2025, the earliest of the three deadlines for secondary legislation that the law had set itself. It appeared last of the three.
- CNAIR gets a single day for the carry-over of its own motion. Article 17(3) requires it to enter in the TollRo database, by 1 October 2026, the heavy vehicles already exempt, and the order came into force on 30 September. The fallback in the same paragraph, of 2 working days, applied only if the order had appeared after 1 October.
- Applying by email remains a fragile answer for emergencies. Annex no. 2 keeps the 2022 mechanism, with an email message of at most 10 MB announced beforehand by telephone and with .xls or .xlsx files, inside an act that everywhere else asks for a qualified electronic signature.
- The State Inspectorate for Road Transport Control is not exempt from TollRo. It appears in the rovinietă list, in Article 9(1)(a)(x) of the law, but it is missing from the TollRo list in Article 13(1)(a), which stops at the Red Cross. That is why Article 1 of Annex no. 1 refers to points (viii) to (xi), and Article 9 only to (viii) to (x).
Practical advice
- Check first whether you are already in the database, before you file anything. Article 17(1) carries over automatically the exemptions existing on the date Government Ordinance no. 15/2002 was repealed, with no application at all. A file sent for nothing does no harm, but it takes up somebody else’s 5 working days.
- If the fleet is new or the category is new, buy a rovinietă for the waiting period. Article 8 and Article 16(2) expressly forbid you to treat the vehicles as exempt until written confirmation. A 10-day rovinietă costs less than the fine in Article 18(2) of the law, which starts at twice the annual charge.
- Send the file to the published address, not to the last one you knew. Article 14(2) obliges CNAIR and the Directorate General for Driving Licences and Vehicle Registration to publish on their own websites the addresses to which documents are sent. Check them before posting.
- Sign electronically with a qualified signature, not a simple one. Article 14(1) asks for precisely a qualified electronic signature for transmission by electronic means. The alternative is filing at the registry, which starts running from the date of registration.
- For local public transport and school transport, watch the expiry date of the document, not the date of the exemption. Article 4 records the exemption with the expiry date of the route licence or of the own-account transport certificate. File the new documents at least 5 working days before that date, so as to cover the period in Article 7.
- Report every change in the fleet, not only the arrivals. Article 6 and Article 11 oblige you to notify any change concerning the documents sent and the vehicles owned or used under a legal right. A vehicle sold and left marked as exempt is a problem for the former holder.
- If you invoke an international treaty, say which one. Article 15 requires the application to state the agreement or treaty under which the exemption is sought, both for the rovinietă and for TollRo. An application without that statement leaves nothing to check.
- With the Department for Emergency Situations, keep to the form of the email subject line. Article 2(3) of Annex no. 2 fixes it: „Solicitare roviniete zz.ll.aaaa” or „Solicitare tichet de rută zz.ll.aaaa, ora hh:mm”. The procedure is built on recognising that subject line, and messages over 10 MB are split and numbered in sequence.
- Cancel in good time an application that is no longer used. Article 3(4) provides that rovinietă certificates and tickets cancelled before their validity begins do not enter the half-yearly settlement statement, so cancelling in time reduces public expenditure, not just paperwork.
Frequently asked questions
I have an ambulance. Do I still have to do anything on 1 October?
Why is it not enough that the vehicle plainly belongs to an institution?
How long does it take to get the confirmation?
What documents does a school transport operator send?
Does my exemption expire?
Are historic vehicles still exempt?
Do I have to apply separately for exemption from TollRo?
Who pays for the rovinietă certificates issued for emergency missions?
How quickly is a route ticket issued for a humanitarian mission?
Editorial analysis
The order is well made and it shows that it was written together with the implementing rules, not separately. Article 3(2) of Annex no. 2 derogates expressly from the advance purchase deadlines in the rules, and Article 41 of the rules disapplies exactly those five provisions that presuppose a payment, in the cases where no payment exists. The references to the law check out point by point: Article 1 of Annex no. 1 covers exactly the categories that Article 9(2) places in the database, Article 5 exactly those that Article 9(3) sends to marking, and Chapter II respects the asymmetry in the law, where the TollRo list is one position shorter. Two orders published on the same day that cite each other correctly is no small achievement.
That asymmetry is nonetheless worth looking at, because it cannot be seen by reading either of the two orders from end to end. Article 9(1)(a) of Law no. 226/2023 has eleven positions and includes, at position (x), the State Inspectorate for Road Transport Control. Article 13(1)(a), the list for TollRo, has ten and stops at the National Society of the Red Cross of Romania. The Inspectorate is missing. The result is that the goods vehicles over 3.5 tonnes of the institution that checks payment of TollRo pay TollRo, and the order could repair nothing: it merely reproduces correctly what the law says, referring to points (viii) to (xi) for the rovinietă and to (viii) to (x) for TollRo.
The second observation comes out of combining the dates. Article 17(3) requires CNAIR to carry over of its own motion into the TollRo database the heavy vehicles already exempt, and the deadline is written in two versions: by the date provided for in Article 29(1) of the law, that is 1 October 2026, or, if the order enters into force after that date, within 2 working days of entry into force. The order entered into force on 30 September, so the first version applies and CNAIR has a single day. In other words, by publishing the order one day before the deadline, the issuing ministers gave the operator less time than they themselves considered reasonable in the event of delay. It is not a contradiction in the text, it is a consequence of the calendar, but it is a measurable one.
The third observation also concerns the calendar, but on a different scale. Law no. 226/2023, published on 18 July 2023, set in Article 25 three deadlines for secondary legislation: 1 January 2025 for this joint order, 31 March 2025 for the implementing rules and 31 March 2025 for the charge orders as well. The joint order had the earliest deadline and appeared last, 637 days late. Throughout that time, the only practical consequence was that nobody could file an exemption file for the new regime: Article 4(2) ties filing to the entry into force of the order, so the filing window opened on 30 September 2026, one day before the obligation.
The fourth observation concerns a rule that existed and disappeared without a replacement. Article 18(4) of the 2018 rules said that, in order to ensure continuity of the exemption, users were obliged to send the documentation before validity expired, but not more than 30 days before, and that, if the documentation was registered fewer than 5 working days before expiry, CNAIR did not undertake to ensure continuity. It was an ugly rule, but an honest one: it told the operator exactly how far ahead to plan. The new order ties the exemption to the validity of the documents, in Article 4, but says nothing about renewal, even though Article 7 gives CNAIR 5 working days and Article 8 forbids use of the exemption until confirmation. The combination of the three articles produces an interval in which a school bus with a freshly renewed licence is not exempt, and nobody is warned about it.
Finally, it is worth noting that the order keeps, almost untouched, a mechanism from 2022 that belongs to dispatching rather than to electronic administration: the application by email, announced beforehand by telephone, with an .xls or .xlsx file and a limit of 10 MB per message. The choice is not groundless, because a mechanism that works at 3 in the morning on a public holiday is worth more than an elegant one, and the procedure has worked for four and a half years. But it sits in the same act which, in Article 14(1), asks for a qualified electronic signature for an exemption file sent with no urgency at all.
What should be changed
- Part A of the form should get the towed vehicle column back, or Article 2(5) should be confined to Part B. The rule on pairing registration numbers sits in the common part of Article 2, so it applies to both types of application, but the rovinietă form has nowhere to apply it, and the instruction for column 1 asks for a vehicle on its own. The 2022 model had a column for the semi-trailer or trailer; losing it leaves a rule without a field.
- The exemption should take effect from the date the complete application is registered, not from the confirmation. Article 8, Article 13 and Article 16(2) shift onto the holder the risk of an administrative deadline that the holder does not control. A wording of the kind „the exemption is granted from the date on which the complete documentation is registered” would keep the check and remove the interval in which a vehicle entitled to exemption runs without being exempt. The model exists in Article 18(5) of the 2018 rules, which granted the exemption from the date requested by the user, but no earlier than the registration of the documentation.
- Renewal of the route licence and of the own-account transport certificate should be given a filing deadline. A rule of the kind „the new documents are sent at least 10 working days before the expiry of those in force” would cover the 5 working days in Article 7 and would close the gap that Article 4 creates without naming it.
- The written confirmation should have a deadline too, not merely an existence. Article 16(1) obliges the directorate general to confirm the marking, and Article 7 obliges CNAIR to complete the database within 5 working days, but it does not say within what time it confirms. Since it is precisely the confirmation that opens the right, it ought to be bound by the same deadline as the entry.
- The list of exemptions from TollRo should be re-examined in the law. The absence of the State Inspectorate for Road Transport Control from Article 13(1)(a) is a difference from the rovinietă list for which the text offers no visible explanation. Either it is a choice, and then it deserves to be stated, or it is an omission, and then it is repaired by a one-line addition.
- The carry-over of its own motion should be given a deadline tied to entry into force, not to a fixed date. The wording in Article 17(3) produced, through publication one day before the deadline, exactly the result that the fallback version was meant to avoid. A single deadline of 2 working days from entry into force, whatever the date, would have been simpler and more realistic.
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. 830 of 30 September 2026, pages 8-11 16 pages PDF, 113 KB the act starts on page 8
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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.
