Romania — Ordonanța de Urgență nr. 8/2026: Economic Relaunch, Productive Investment and Competitiveness

Mechanism

OUG 8/2026 was adopted by the Romanian Government on 24 February 2026 under emergency-ordinance powers conferred by Article 115(4) of the Romanian Constitution, signed by Prime Minister Marcel Ciolacu and countersigned by Finance Minister Alexandru Nazare. It entered into force 1 March 2026 (day after publication in Monitorul Oficial nr. 147/25-Feb-2026).

The ordinance structures its EUR 5B 2026-2032 commitment through nine distinct state-aid schemes:

Nine state-aid schemes include:

• Large-project investment instrument (EUR 200M+ per project, Strategic Investment tier at minimum RON 1 bn / ~EUR 200M project value)
• High-Tech Research Schema — 200% deduction of corporate and non-corporate R&D expenses for qualifying projects (minimum RON 5M, maximum RON 50M per project); this is a structurally novel provision materially distinct from existing CIT R&D provisions
• Competitiveness clusters scheme
• Mineral resource development scheme
• Defence industry capacity-building scheme
• Additional sector-specific grant and tax-credit instruments

Investment and Development Bank (BID) recapitalization — RON 1 bn in 2026, with ongoing recapitalization, positions BID as the operative state-aid disbursement and guarantee channel (peer to France BPIFrance, Italy CDP, Germany KfW, Poland BGK national-development-bank architectures). BID will administer guarantee schemes, investment vehicles, and capital funds operationalizing the EUR 5B envelope.

EximBank export-credit allocation — RON 1 bn allocated 2026-2030 to Exim Romanian Bank to support export credits, international transactions, and Romanian firms' outbound investments.

Fiscal-budgetary modifications span:

• Corporate profit tax: 10% R&D tax credit on eligible expenses; updated asset-expensing threshold raised from RON 2,500 to RON 5,000 (direct benefit for SMEs)
• Microenterprise regime modifications
• VAT on collection threshold update (RON 5–5.5M)
• Income-tax deduction enhancements for pension contributions
• 3% tax compliance bonus for taxpayers maintaining clean payment records (profit tax or personal income tax)

Public-Private Partnership (PPP) framework — establishes a favourable PPP implementation framework, creating a vehicle for co-investment with strategic-investment tier partners.

Strategic context

OUG 8/2026 is Romania's most significant horizontal industrial-policy instrument since EU accession in 2007. The Finance Ministry explicitly framed it as a pivot "from consumption to investments as the engine of economic growth" — a structural reorientation of Romania's state-aid and fiscal-incentive architecture away from consumption support (dominant in the 2020-2024 post-COVID cycle) toward productive-capacity investment.

Romania's existing register filings cover sectoral instruments: Law 164/2023 FDI screening, National Defence Industry Strategy 2024-2030, Mineral Resources Strategy HG 1464, and Hydrogen Strategy HG 855. OUG 8/2026 is the first RO horizontal umbrella industrial-policy filing — operationalising the full EUR 5B envelope across all sectors simultaneously rather than sector by sector.

The 200% High-Tech Research Schema R&D deduction is structurally consequential. No previous Romanian instrument offered an above-unity deduction for R&D. Combined with the Strategic Investment minimum RON 1 bn tier, this creates two distinct incentive entry points: large-capex greenfield/expansion projects qualifying for the strategic tier, and smaller high-tech R&D projects (RON 5M-50M) qualifying for the 200% deduction — covering both automotive/industrial-scale FDI (Renault Dacia, Ford, Continental, Bosch) and tech/R&D-scale investors (Nokia, Ubisoft, IT cluster).

Downstream implications

• Inbound FDI decisions: Strategic Investment tier (minimum RON 1 bn) directly affects location decisions for Renault Dacia Mioveni Phase 3 (next-gen EV platform), Ford Craiova electrification, Continental and Bosch manufacturing expansions — all have existing large-scale Romanian manufacturing footprints that qualify for the top tier
• Defence-industrial: Carfil, Romarm, Elbit Romania, and Star Assembly (Mercedes-Benz powertrain, dual-use) sit under the defence-industry state-aid scheme and intersect Romania's National Defence Industry Strategy 2024-2030
• High-Tech R&D: Nokia, Ubisoft, Bitdefender, UiPath (Robocopilot successor), and Romania's growing AI/IT services cluster are primary beneficiaries of the 200% R&D deduction for projects in the RON 5M-50M band
• Steel/metals: Liberty Galați (steel), Rompetrol/KMG (refining) may access large-project instruments for decarbonisation capex
• BID/EximBank architecture: RON 2 bn in combined BID + EximBank capitalisation (2026 tranches) significantly increases Romania's state-guaranteed credit capacity, enabling structured co-financing of the strategic-investment tier alongside EU Cohesion and PNRR funds

Open questions

• EU state-aid notification: OUG 8/2026 schemes require European Commission notification under TFEU Articles 107-108; timelines for individual scheme approvals will determine actual deployment pace
• Whether the 200% R&D deduction is structured as an above-the-line deduction or a below-the-line tax credit matters for after-tax IRR calculations; KPMG commentary and full statutory text confirm it is an enhanced deduction (not credit)
• MCF (Ministry of Finance) implementing regulations for the RON 1 bn BID recapitalisation tranche are expected in Q2 2026