Moldova has an official list of permits that the government is authorized to require from businesses. However, a review of the legislation revealed approximately 180 additional permit-based requirements that are not included in this list. Now, government agencies will have to justify the necessity of each of these requirements. If they fail to do so, such requirements will lose their permissive status as of January 1, 2027.
A review of the legislation identified approximately 180 permit-based requirements that are not included in the official List of Permissive Documents (Nomenclatorul actelor permisive). It is now proposed to amend 71 laws and 29 government decrees, and to repeal or convert approximately 80 already known permissive acts to a notification-based system.
The problem was not immediately apparent. In 2024, the List included 139 permissive acts, but even then, at least 57 additional permissive documents had already been identified outside of it. A subsequent inventory revealed "well over a hundred" such requirements, and the ministry's latest materials cite a figure of 180.
This results in a strange structure. The government created a special law and an official List so that entrepreneurs would understand which permits they are legally required to obtain. But at the same time, sector-specific legislation has retained a second layer of approvals, opinions, certificates, and other requirements that effectively serve the same function.
The revision affects labor relations, fire safety, healthcare, pharmaceuticals, veterinary medicine, free economic zones, transportation, environmental regulation, and other sectors. Here are a few specific examples that illustrate just how different such requirements can be.
1. Mandatory staffing plan for employers. Currently, its approval is mandatory. The draft proposes making this a right: a company will be able to have and modify a staffing plan if necessary, but the specific requirement will be eliminated.
2. Separate written notification to the employee prior to hiring or transfer. Currently, the employer must separately inform the employee of the terms and conditions of employment. The draft proposes that this obligation be considered fulfilled upon the signing of an employment contract or a supplementary agreement, provided that the necessary information is already contained therein.
3. Annual notification of employees regarding accrued vacation time. The draft proposes removing from the Labor Code the employer's obligation to annually notify each employee in writing of the number of accrued and unused vacation days and the deadline for using them.
4. Annual fire safety declaration. It is proposed to exempt micro-, small, and medium-sized enterprises with a low fire risk from this requirement, provided they do not operate high-risk facilities and use non-flammable or low-fire-risk equipment, materials, and substances.
5. Training for the person responsible for fire safety must be conducted only at a state-run center. Current regulations effectively restrict such training to a single state agency. The draft proposes allowing other accredited providers and exempting some low-risk enterprises from this requirement altogether.
6. Paper-based occupational safety training record card. Currently, completion of training is documented on an employee's personal record card. The draft allows for maintaining and storing this record electronically, including electronic confirmation of training completion.
7. Separate logbook for recording occupational safety instructions. Currently, instructions must be recorded in a special logbook of a prescribed format. The draft proposes eliminating the separate logbook and having instructions approved by the employer's decision.
8. Refresher training after a 30-day absence. Currently, additional training is required if an employee has been absent for more than 30 calendar days. The draft proposes extending this period to 90 days.
9. Sanitary permits where a notification might suffice. The draft proposes a clearer distinction between activities that genuinely require a prior sanitary permit and cases where it is sufficient for a business to notify the government of the commencement of operations. In other words, some procedures should shift from a prior approval system to a notification-based system.
10. A separate permit for each type of activity in a free economic zone. Currently, a FEZ resident must not only enter into an agreement with the zone's administration but also obtain a separate permit for the relevant type of activity. The draft proposes eliminating the second document: the right to engage in this activity will stem directly from the agreement with the zone's administration.
This is not a list of ten of those 180 "hidden" permits—a published, itemized list of all 180 documents does not yet exist. These are examples from two current deregulation packages. They demonstrate that the administrative burden consists not only of documents officially designated as licenses or permits.
Sometimes it is a certificate that the law continues to require even after the system itself has changed. Sometimes it is a mandatory opinion or approval. In some cases the government requires prior authorization in cases where reformers believe it is sufficient to establish general rules and monitor compliance with them. In other cases, two procedures verify virtually the same thing.
There are also simpler examples of administrative burdens. It is proposed to relieve employers of the obligation to annually notify each employee in writing of the number of accrued and unused vacation days. For tourist and agritourism guesthouses, it is proposed to amend the regulations governing the sale of homemade alcoholic beverages, as such activities are currently subject to some of the requirements intended for industrial production.
That said, it would be wrong to consider all 180 identified requirements as pointless bureaucracy. Prior authorization may indeed be necessary when it comes to public health, safety, the environment, or other significant risks. Therefore, the government is not proposing to automatically repeal the entire set of identified requirements.
The approach is changing. A government agency will have to justify why a specific type of activity requires prior authorization and what risk cannot be controlled by simpler means. If no such justification exists, the requirement must either be eliminated or converted into a less burdensome procedure.
For businesses, the difference is significant. Under a permit-based system, an entrepreneur first completes the established procedures and waits for government approval before beginning a specific activity. Under a notification-based system, a company notifies the government of the start of its activities and operates provided it complies with established requirements. Regulatory oversight remains, but the need to obtain individual approval from a government official in advance is eliminated.
For businesses, the cost of obtaining a permit is determined not so much by the government fee as by the time involved. Documents must be prepared, approvals must be obtained, and decisions must be awaited. And if operations cannot begin without such approval, the administrative procedure effectively becomes a delay in production, sales, or investment. Therefore, a free permit does not mean there are no costs involved.
And this is where the reform's weak point becomes apparent. The published materials lack an overall assessment of how much the approximately 180 identified requirements cost businesses, which of them generate the highest costs, and how many will ultimately be abolished. Therefore, the impact of the reform cannot be measured solely by the number of laws that have been revised or documents that have been eliminated.
At present, the focus is on the prepared deregulation packages and consultations; the reform is not yet complete. However, starting January 1, 2027, those requirements for which government agencies cannot justify the need are to lose their permissive nature.
The review revealed the weakness of the previous deregulation model. While the official list of permits can be shortened, the administrative burden does not necessarily decrease if similar requirements continue to exist under different names in dozens of sector-specific regulations.
If the government requires an entrepreneur to obtain its prior consent, it must explain why this authorization is necessary. This is precisely what the current review is intended to verify. //September 05, 2026 – InfoMarket.