6 Matei Millo +40 31 432 6170

Physical Security Risk Analysis modified by Emergency Ordinance 37/2026

Through the emergency ordinance for the amendment and completion of Law no. 333/2003 on the guarding of objectives, goods, values and protection of persons, published in the Official Gazette no. 381 of May 6, 2026, substantial changes are introduced regarding the licensing of security firms, the physical security risk assessment procedure, and companies’ reporting obligations.

What does it stipulate?

The main change concerns the physical security risk assessment. This becomes mandatory only for units falling into certain categories with minimal security requirements (which will be established by methodological norms). For all other companies, the formal risk analysis is replaced by a simplified procedure, called “security sheet”, which the company can draw up based on its own assessment. This measure reduces costs and administrative complexity for a large number of economic operators that do not present high risks.

Operating licenses for security and protection companies, as well as for those installing alarm systems, are now issued for an indefinite period, eliminating the periodic renewal procedure. In return, a reporting obligation is introduced: every 3 years, these firms must inform the police that they continue to meet the licensing conditions. Also, any change in the structure or organization of the activity must be communicated to the authorities within 15 calendar days.

The ordinance introduces a strict rule to prevent conflicts of interest. The physical security risk assessor cannot perform analyses for a company if their firm (or the firm they are employed by) already has security or alarm system installation contracts with that company. Furthermore, after the analysis is completed, the assessor’s firm cannot enter into such contracts during the implementation of the measures. Risk analyses performed in violation of this rule are considered null and void.

Administrative procedures are simplified through digitalization. For objectives with unarmed guarding, the guarding plan and risk analysis (or security sheet) are transmitted exclusively in electronic format to the competent police unit. Similarly, the burglar alarm system project is also transmitted electronically. Police approval becomes mandatory only for guarding plans involving armed personnel, eliminating a bureaucratic step for most companies.

To whom does it apply?

The changes directly target the following categories:

  • All legal entities which, according to the law, have the obligation to ensure the guarding of goods or values (credit institutions, pawn shops, postal units, jewelry stores, casinos, gas stations, etc.).
  • Specialized security and protection companies and those that design, install, or maintain burglar alarm systems.
  • Physical security risk assessors, registered in the National Register.

What should you do?

  • Assess the necessity of a risk analysis: Check if, according to the new norms (when published), your company falls into the category with minimal security requirements, for which a formal risk analysis remains mandatory. Otherwise, prepare to implement the simplified procedure based on the security sheet.
  • Select an independent risk assessor: Ensure that the firm performing the risk analysis is not and will not become your provider of security services or alarm system installation. Review existing contracts to avoid conflict of interest situations that could lead to the annulment of the analysis.
  • Update internal procedures: Adapt workflows to allow for the electronic transmission of the guarding plan and alarm system projects to the police, in accordance with the new requirements.
  • Review the guarding plan: If you have an unarmed guarding plan, note that police approval is no longer required for its elaboration or modification, but only the electronic transmission of the document.

Source: Official Gazette, Part I, no. 381 of May 6, 2026.

Note: This material is strictly for informational purposes and does not constitute legal, tax, or business advice. As the interpretation and application of legal provisions may vary significantly depending on the specific circumstances of each entity, we recommend seeking specialized legal assistance before adopting any operational decisions based on these changes.

BACK