Decision No. 43/1 of 24 August 2026 regarding the preliminary request filed by IM CA GRAWE CARAT ASIGURARI SA contesting CNPF Letter No. 05-5/2813

REPUBLIC OF MOLDOVA
NATIONAL FINANCIAL MARKET COMMISSION
77 Stefan cel Mare si Sfant Blvd, Chisinau, MD 2012, tel: (373 22) 859 401, www.cnpf.md, e-mail: office@cnpf.md DECISION 24 August 2026 No. 43/1 Regarding the Preliminary Request filed by IM CA "GRAWE CARAT ASIGURARI" SA, contesting Letter No. 05-5/2813 of the National Financial Market Commission dated 03.07.2026 regarding the completion of the administrative procedure, initiated by the petition of IP "National Single Emergency Call Service 112" of the Ministry of Internal Affairs

On 29.07.2026, within the National Financial Market Commission (CNPF/supervisory authority), the Preliminary Request No. 4566 dated 29.07.2026 (Preliminary Request) was registered (with No. 6507), filed by IM CA "GRAWE CARAT ASIGURARI" SA (insurer/Company).

In this case, please note that, in order to ensure a full, objective, and transparent investigation that offers the real possibility of analyzing the claim, the insurer is informed that the examination of the factual and legal circumstances relevant to the case, in preliminary order, is carried out by distinguished executors within the CNPF.

In fact, following the road accident on 16.02.2026, occurring between the "Mitsubishi Galant" vehicle with license plate [...], driven by Mr [...], belonging to IP "National Single Emergency Call Service 112" (petitioner), and the "Lincoln MKZ" vehicle with license plate [...], driven by Mr [...]. The establishment of facts, circumstances of the road accident, and the culpable person was documented through the amicable settlement procedure, according to which Mr [...] admitted his guilt.

According to the information in the "Amicable Accident Report" form, Mr [...] held a motor third-party liability insurance policy (RCA) issued by IM CA "GRAWE CARAT ASIGURARI" S.A. No. RCAI [...] valid from 13.07.2025 to 12.07.2026.

Under this policy, on 16.02.2026, the petitioner submitted a claim for compensation to the insurer.

On the same day, damage file No. [...] was opened and the Damage Assessment Report was completed.

Subsequently, on 12.03.2026, the vehicle was presented again to the insurer, and a new photographing of the vehicle was carried out.

At the same time, the "Lincoln MKZ" vehicle with license plate [...] was transferred to the possession and use of "Exligro" SRL company, based on a lease contract, and was used in transport activity in taxi mode. For this vehicle (insured by "Exligro" SRL), a mandatory RCA insurance contract was concluded, issued by CA "ACORD GRUP" SA, series RCAI No. [...] dated 22.10.2025, valid on the date the accident occurred.

Based on the circumstances indicated above, the Damage Assessment Report of 16.02.2026 was signed by Mr [...], Mr [...], the insurer's representative, and the representative of CA "ACORD GRUP" SA.

Since the repair of the vehicle was not initiated by 16.04.2026, the petitioner addressed the insurer requesting "urgent examination of the situation and ordering the repair of the car in the shortest possible time."

Only as a result of this request, on 27.04.2026, the insurer transmitted to the petitioner, via email, response No. 1607, dated 10.03.2026, by which it rejected the Claim for Compensation, reasoning that, under Art. 8 para. (3) of Law No. 106/2022 on mandatory third-party liability insurance for damages caused by vehicles (Law No. 106/2022), civil liability for the vehicle involved was covered by the RCA policy issued by CA "ACORD GRUP" SA, thus the injured person should have addressed this insurer.

Subsequently, on 11.05.2026, the petitioner received, via "Poșta Moldovei" State Enterprise, letter No. 1607 of 10.03.2026 and No. 2613 of 21.04.2026.

Following the investigations carried out in the context of the respective administrative procedure, and the analysis of the materials/evidence presented by the participants in the procedure, within the framework of the normative framework applicable to the contractual relations, the CNPF, on 03.07.2026, issued Letter No. 05-5/2813 regarding the completion of the administrative procedure, initiated by the petition of IP "National Single Emergency Call Service 112" of the Ministry of Internal Affairs (Letter No. 05-5/2813/Contested Letter).

According to the aforementioned letter, the CNPF found, primarily, that "the insurer did not communicate the decision regarding the resolution of the compensation claim in compliance with the requirements provided by Art. 20 para. (2) of Law No. 106/2022", as well as that the insurer "under Art. 8 para. (2) and para. (3), and also Art. 14 para. (1) and para. (3) lit. b), Art. 20 para. (1) lit. f) of Law No. 106/2022, was supposed to regularize the damage file and pay the insurance compensation to the injured person."

Disagreeing with the CNPF's findings, the insurer filed a Preliminary Request, requesting the re-examination of the findings in the Contested Letter, invoking, in this regard, the fact that "it considers that the findings exposed in Letter No. 05-5/2813 contradict the materials of the damage file and the applicable legal norms."

Analyzing the arguments exposed in the Preliminary Request, within the framework of the legal provisions applicable to the case, it will be assessed whether they are of a nature to overturn the findings of the supervisory authority, as follows:

1. In law, Art. 19 of the Administrative Code provides that "The Preliminary Request is the institution that offers a pre-litigation path for the resolution of administrative disputes," and Art. 162 para. (1) and para. (3) of the same law stipulate that "(1) The preliminary procedure aims to verify the legality of individual administrative acts. [...] (3) The Preliminary Request may be directed towards: a) annulment in whole or in part of an illegal or null individual administrative act; b) issuance of an individual administrative act."

In accordance with Art. 20 of the Administrative Code, "If an administrative activity violates a legitimate right or a liberty established by law, this right may be claimed through an administrative litigation action, [...]", and according to Art. 17, "Damaged right is any right or liberty established by law to which/which is affected by administrative activity."

In this case, Art. 78 para. (1) of the Administrative Code establishes that "(1) The administrative procedure is finalized by carrying out an administrative operation or by issuing an individual administrative act, namely concluding an administrative contract."

At the same time, according to Art. 15 of the Administrative Code, administrative operations are defined as "[...] manifestations of will or activities of public authorities that do not produce legal effects per se. Administrative operations can be contested only concurrently with the individual administrative act, with the exception of executive administrative operations or those directed against a third party."

Under the conditions of Art. 166 of the Administrative Code, "The Preliminary Request can only be filed if the person claims rights violated by the issuance or rejection of the issuance of an individual administrative act," and in accordance with Art. 167 para. (1) and para. (3) of the same law, "(1) If it considers the preliminary request to be admissible and well-founded, the issuing public authority annuls in whole or in part the contested individual administrative act or issues the requested individual administrative act. [...] (3) The issuing public authority resolves the preliminary request within 15 calendar days. The provisions of Art. 60 para. (2)-(5) apply correspondingly."

2. At the same time, from the systematic interpretation of Art. 17, Art. 20, Art. 166, and Art. 207 of the Administrative Code, it results that the admissibility of a preliminary request is determined by the claim of a damaged right through administrative activity.

Thus, from the aspect of its legal nature, the Contested Letter presents the characteristics of an administrative operation, in the sense of Art. 15 of the Administrative Code, because it does not produce direct legal effects on the rights and obligations of the petitioners per se.

At the same time, given the content of what was formulated by the insurer and, based on the need to ensure an effective, transparent, and exhaustive examination, the supervisory authority will proceed to verify the arguments invoked through the Preliminary Request, including regarding the correctness of the assessments exposed in the Contested Letter.

3. In this case, please note that, through the Preliminary Request, the insurer, in principle, contests only the conclusions of the supervisory authority, which concern the obligation to pay insurance compensation.

Specifically, the insurer's arguments start from a fragmented interpretation of the legal insurance relationship and, essentially, confuse two distinct legal issues: on one hand, the existence and extent of insurance coverage conferred by the RCA contract initially concluded by the physical person, and, on the other hand, the relationships between insurers, due to the existence of another RCA policy related to the use of the vehicle in taxi mode.

Or, these two planes must be analyzed separately, because the existence of a potential problem of subrogation in rights and regression between insurers cannot be opposed to the injured person to restrict or eliminate the protection conferred upon them by Law No. 106/2022.

Article 8 of Law No. 106/2022 regulates inter alia the legal effects of the RCA contract in relation to vehicle users. Thus, Art. 8 para. (2) of Law No. 106/2022 establishes that "The mandatory RCA insurance contract is concluded between the insurer and the insured, without indicating the persons admitted to use the vehicle (unlimited number of users)", and subsequently provides expressly that "under the mandatory RCA insurance contract, the risk of any vehicle user is covered regardless of whether it is concluded by physical or legal persons or in their name, with the exceptions provided by this law."

Accordingly, the norm establishes the principle according to which the risk of any user is covered under the RCA contract.

This regulation expresses, clearly, that motor third-party liability is not intended to insure a specific person, but covers the risk associated with the use of the vehicle itself, regardless of who drives it.

Thus, the central element of RCA insurance is the insured risk and not the identity of the user. Subsequently, Art. 8 para. (3) of Law No. 106/2022 establishes a special norm of continuity of protection for the injured person when the vehicle insured by a physical person is transferred to the possession of a legal person:
"The insured physical person, with the exception of individual entrepreneurs or persons who, in the sense of the Fiscal Code, provide professional services and carry out independent professional activities, transfers to possession a legal person the vehicle for which the mandatory RCA insurance contract was concluded, based on a lease contract or another legal act drawn up in accordance with the legislation."

According to Art. 8 para. (3) of Law No. 106/2022, in the case where the insured physical person transfers to possession a legal person the vehicle for which the mandatory RCA insurance contract was concluded, based on a lease contract or another legal act drawn up in accordance with the legislation, "the risk of those admitted by the legal person to use the vehicle is considered insured under the contract concluded."

This formulation indicates that the legislator has expressly regulated the situation where the person who concluded the RCA contract is no longer the effective user of the vehicle, and the vehicle is transferred to the possession of a legal person. Or, precisely this circumstance was invoked by IM CA "GRAWE CARAT ASIGURARI" SA as the main argument for excluding the effects of the insurance policy issued by it. Thus, the law establishes that the risks related to the users designated by the legal person are considered insured by the RCA contract concluded by the physical person.

In the Preliminary Request, the Company states that for the "Lincoln MKZ" vehicle with license plate [...] "there was also an RCA policy issued by IM CA "GRAWE CARAT ASIGURARI" SA to a physical person who, on the date the accident occurred, did not have the quality of owner or user of the vehicle and did not exercise any right of use over it", and subsequently concludes that "there is no legal basis under which the RCA insurance policy issued by IM CA "GRAWE CARAT ASIGURARI" SA which was concluded by a physical person and who did not have the quality of owner or user of the vehicle on the date the accident occurred to produce legal effects regarding the payment of insurance compensation."

In this case, we note that precisely this conclusion contradicts the express regulation of Art. 8 para. (3) of Law No. 106/2022. Therefore, the mere fact that the insured physical person no longer exercised, on the date the accident occurred, possession or effective use over the vehicle is not sufficient, by itself, to exclude the incidence of the RCA contract concluded by it. On the contrary, the transfer of the vehicle to the possession of the legal person is precisely the hypothesis provided for in Art. 8 para. (3), and the concrete effects of this norm must be determined by reference to the set of circumstances of the case and the other applicable provisions, the risk being considered insured.

4. Moreover, IM CA "GRAWE CARAT ASIGURARI" SA states that, "in application of the legal provisions", for each damage file analyzed, it examines the circumstances of the accident and the accumulated materials, "in order to determine the applicable RCA contract on the date the event occurred, starting from the person who had the vehicle in use". The CNPF does not contest the necessity of determining the concrete circumstances of the accident and the legal status of the user. What cannot be accepted is the transformation of this verification into an exclusive legal criterion, by ignoring the effect attributed by law to the existing RCA contract. In this case, the fact that "Exligro" SRL used the vehicle based on a lease contract does not determine, by itself, the termination or inapplicability of the RCA contract concluded by the physical person. On the contrary, this situation falls within the hypothesis regulated by Art. 8 para. (3) of Law No. 106/2022.

5. Therefore, the Company's argument, according to which "the RCA insurance policy issued by IM CA "GRAWE CARAT ASIGURARI" SA [...] [could not] produce legal effects regarding the payment of compensation", cannot be retained, because its legal effect is not determined exclusively by the quality of the person who, at the moment of the accident, drove or possessed the vehicle, but by the special norm of Art. 8 para. (3) of Law No. 106/2022, which expressly qualifies as considered insured the risk of users admitted by the legal person.

6. In this context, it follows that, both the general rule at Art. 8 para. (2) of Law No. 106/2022, and the provision at Art. 8 para. (3) of the same law, operate with similar semantic constructions. Thus, Art. 8 para. (2) of Law No. 106/2022 establishes that "the risk ... is covered", which denotes that the insurer will be obliged to pay compensation in relation to any user of the respective vehicle.

At the same time, Art. 8 para. (3) of Law No. 106/2022 extends the scope of application of the principle mentioned above, to situations where "the insured physical person, with the exception of individual entrepreneurs or persons who, in the sense of the Fiscal Code, provide professional services and carry out independent professional activities, transfers to possession a legal person the vehicle for which the mandatory RCA insurance contract was concluded, based on a lease contract or another legal act drawn up in accordance with the legislation", which constitutes a circumstance that determines the aggravation of the risk. Under such conditions, the legislator operates with the phrase "the risk ... is considered insured under the contract concluded."

The different syntactic structure denotes the legislator's intention to extend the legal effects of the RCA contract concluded by the physical person also to the users admitted by the legal person, even if their risk is not insured by the RCA contract concluded by the physical person.

7. Moreover, this regime expresses a high standard of protection, where the emphasis falls on the continuity and stability of insurance coverage, in the interest of injured persons.

Thus, the guarantee that, by the mere existence of a valid RCA policy, the injured person will benefit from insurance compensation, is a legislative solution, intended to avoid protection gaps and to maintain the purpose of insurance: rapid and efficient compensation of the injured person.

In conclusion, the normative framework highlighted above emphasizes the impersonal nature of RCA insurance – focused on risk and the protection of injured persons. The same conclusion also results from the correlation of Art. 8 para. (2) and (3) with Art. 14 para. (1) and para. (3) lit. b) of Law No. 106/2022. According to Art. 14 para. (1) of Law No. 106/2022, "the RCA insurer has the obligation to pay insurance compensation to the injured person for damages caused by an accident of the vehicle whose owner and/or user has fulfilled the obligation of mandatory RCA insurance", and according to para. (3) lit. b) of the same law, regardless of the place where the accident occurred, the RCA insurer provides compensation for the damage caused by the fault of the driver of the vehicle, whose owner and/or user has fulfilled the obligation of mandatory RCA insurance. In the analyzed situation, the insurance obligation cannot be analyzed exclusively through the prism of the person who was driving the vehicle, because Art. 8 para. (3) of Law No. 106/2022 expressly establishes that the risk of this person is considered insured under the initial contract.

Therefore, the CNPF's conclusion recorded in letter No. 05-5/2813 of 03.07.2026, according to which, under the conditions that IP "National Single Emergency Call Service 112" submitted the claim for compensation to IM CA "GRAWE CARAT ASIGURARI" SA under the RCAI policy [...], valid on the date the insured event occurred, the insurer was supposed, under Art. 8 para. (2) and para. (3), correlated with Art. 14 para. (1) and para. (3) lit. b) and Art. 20 para. (1) lit. f) of Law No. 106/2022, to regularize the damage file and pay the insurance compensation, is in conformity with the applicable normative framework.

In this context, the Company's statement, according to which the CNPF started from the "premise that the insurer initially notified with a claim for compensation is obliged to pay insurance compensation, even if the produced risk was not covered by the RCA contract issued by it", cannot be admitted. Such a presentation distorts the legal reasoning of the legal provision disposed of above. That circumstance is relevant from the aspect of the insurer's obligation to examine and resolve the claim in accordance with the law, but does not constitute, by itself, the basis for the payment obligation.

8. Another aspect, determinant for the application of Art. 8 para. (3) of Law No. 106/2022, is the fact that the legislator makes no distinction based on the circumstance whether the legal person to which the vehicle was transferred has fulfilled, in turn, its obligation of mandatory RCA insurance, nor does it establish a rule according to which the injured person would be obliged to identify and notify exclusively the insurer of the legal person. The norm is constructed by reference to the existence of the initial contract and the transfer of the vehicle to the legal person, establishing that, in this situation, the risk of the persons admitted by it to use the vehicle "is considered insured under the contract concluded". Therefore, a conditioning cannot be added by way of interpretation, which the legislator did not foresee, namely that the legal effect of this norm would exist only in the situation where the legal person does not hold another RCA policy. Such an interpretation would unjustifiably restrict the sphere of protection instituted by Art. 8 para. (3) of Law No. 106/2022 and would transfer onto the injured person the consequences of legal and contractual relationships that are not imputable to them.

9. In the same order of ideas, Art. 8 para. (3) of Law No. 106/2022 does not regulate a procedural mechanism by which the injured person would be obliged to determine, before exercising their right to compensation, which of the potential insurers must ultimately bear the cost of the damage. A

7 such an obligation does not result from either the wording of the norm or its purpose. Consequently, the insurer's conduct towards the injured person must be primarily oriented towards the resolution and satisfaction of the compensation claim, in accordance with the law, and any potential divergences regarding the final bearing of the compensation, including the existence and extent of any right of regression, represent distinct issues that are to be resolved subsequently within the relationships between the subjects of the insurance obligation. Thus, the systemic approach to Art. 8 para. (2) and (3) of Law No. 106/2022 leads to the conclusion that, at the moment the insured event occurs, the protection of the injured person prevails over the need to clarify the final economic relationships between the involved insurers. After satisfying the right of the injured person, the insurer who paid the compensation may, where applicable, enforce the rights conferred by law against the persons or entities obliged in the corresponding legal relationship. In this way, the balance sought by the legislator is achieved: the injured person benefits from an effective compensation procedure, while the issue of the final bearing of the compensation is left for subsequent resolution between insurers, without the injured person being transformed into a participant in the dispute between them.

10. Regarding the existence of the RTA policy issued by CA "ACORD GRUP" SA for "Exligro" SRL, the CNPF holds that this circumstance does not invalidate the applicability of Art. 8 para. (3) of Law No. 106/2022. In this case, this circumstance must be analyzed in the context of the distinct legal effect of the initial contract, not as a fact that would determine, by itself, the cessation of its effects.
    The CNPF emphasizes that the existence of the policy issued by CA "ACORD GRUP" SA is not devoid of legal relevance. On the contrary, it is precisely the existence of this policy that explains the subsequent mechanism for recovering the sums paid by the insurer who compensated the injured person.
    From this perspective, the argument formulated by IM CA "GRAWE CARAT ASIGURARI" SA according to which "the existence of the right of regression cannot be presumed nor extended by analogy" is correct as a general principle, but it does not invalidate the CNPF's finding regarding that aspect. In this regard, the Company's support that, since "Exligro" SRL held a valid RTA policy issued by CA "ACORD GRUP" SA, Art. 8 para. (3) combined with Art. 30 para. (1) lit. a) of Law No. 106/2022 would not be applicable, cannot be accepted in the absolute form in which it is formulated. The existence of the CA "ACORD GRUP" SA policy cannot have the legal consequence of annulling the effect of Art. 8 para. (3) of Law No. 106/2022 on the initial contract, and the question of whether the payment made by IM CA "GRAWE CARAT ASIGURARI" SA is to be subsequently recovered and to what extent constitutes a distinct issue from the primary obligation towards the injured person. In this sense, it must be borne in mind that Art. 8 para. (3) of Law No. 106/2022 establishes a special legal construction: the legislator recognizes, on the one hand, the coverage of the user's risk through the initial contract, and on the other hand, recognizes the insurer's right to file a regression action under the conditions of Art. 30 of Law No. 106/2022. This construction would be devoid of legal logic if the insurer could refuse payment to the injured person every time it finds the existence of another legal circumstance likely to generate a subsequent right of recovery. In other words, the obligation to compensate the injured person and the subsequent relationship for the recovery of the paid sum are two distinct legal relationships. The first must be resolved by reference to the effect of Art. 8 para. (2) and para. (3), as well as Art. 14 and Art. 20 of Law No. 106/2022, and the second by applying the regression mechanisms provided by law. Confusing these two levels leads to the erroneous conclusion that the existence of another policy allows the first insurer to refuse compensation, although the law establishes that the user's risk is considered insured under the initial contract. Furthermore, the statement in the letter from IM CA "GRAWE CARAT ASIGURARI" SA, according to which "the finding regarding the right of regression of an RTA Insurer against another RTA Insurer [...] is totally outside the legal framework," cannot be retained in an absolute sense. Such a conclusion does not result from the legal texts invoked by the Company. Regarding the mention concerning the insurer's right to file a regression action, it is noted that this aspect did not constitute the object of the request formulated by the petitioner, nor was it invoked in support of his claims. Under these conditions, taking into account the object of the examination and the need to delimit the findings, exposed with respect to the aspects submitted for examination, it is considered appropriate to exclude the mention
    regarding the right of regression from the content of the contested Letter, without prejudice to the rights and obligations of the parties resulting from the applicable legislation.

11. In this case, the insurer invokes that "the regulation provided for by Art. 8 para. (3) in conjunction with Art. 30 para. (1) lit. a) of Law No. 106/2022 is not applicable and excludes the right of regression found by the authority," insinuating that the lack of a regression mechanism nullifies the legal effects of Art. 8 para. (3) of Law No. 106/2022. Contradictorily, we hold that the second sentence of Art. 8 para. (3) of Law No. 106/2022 provides an exception to that paragraph. At the same time, the situation in the case effectively falls within the regulation of that norm and does not constitute an exception in this sense. Thus, that exception, which concerns the right of regression, is not relevant with respect to the situation in the case, and its interpretation by the insurer does not represent a justified criticism regarding the legality of the contested Letter.
    Therefore, the impossibility of applying the provisions of Art. 30 para. (1) lit. a) of Law No. 106/2022 is not inherent to the situation in the case nor can it exclude the legal effects established by Art. 8 para. (3) of the same normative act.
    Regarding the preliminary procedure, please note that, according to the Order of the President of the CNPF No. 613 dated 12.08.2026 regarding the extension of the preliminary procedure term, initiated by the Preliminary Request submitted by IM CA "GRAWE CARAT ASIGURARI" SA, the general term of the preliminary procedure was extended until 28.08.2026.
    Furthermore, the aforementioned Order was brought to the knowledge of the creditor by CNPF Letter No. 06-5/3527 dated 13.08.2026, sent to the email address office@grawe.md.
    Additionally, by the same letter, in accordance with the provisions of Art. 94 of the Administrative Code, IM CA "GRAWE CARAT ASIGURARI" SA was informed about the exercise of the right to be heard, regarding the circumstances relevant to the act to be adopted, as well as about the fact that the hearing is to be conducted in writing, by presenting, by 20.08.2026 (inclusive), to the address of the CNPF, the opinion for the purpose of hearing, which should contain any additional arguments to those related, relevant for the resolution of the Preliminary Request.
    Consequently, the insurer, by letter No. 4946 dated 19.08.2026, registered at the CNPF with No. 7218, reiterated the aforementioned and supported the requests from the Preliminary Request.

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From the considerations recorded above, under the terms of Art. 18 para. (3), Art. 20 para. (1), para. (6) and para. (7) and Art. 22 para. (3) of Law No. 192/1998 regarding the National Financial Market Commission, Law No. 105/2003 regarding consumer protection, Art. 164 para. (1) and para. (2) lit. b), Art. 167 para. (1) and para. (3), Art. 169 para. (2) and para. (3) of the Administrative Code, pct. 16 and pct. 19 of the Regulation regarding the organization and functioning of the National Financial Market Commission (CNPF Decision No. 57/11/2022),

The National Financial Market Commission DECIDES:

1. The Preliminary Request No. 4566 dated 29.07.2026, submitted by IM CA "GRAWE CARAT ASIGURARI" SA (registered at the CNPF with No. 6507 on 29.07.2026) regarding the contestation of Letter No. 05-5/2813 concerning the completion of the administrative procedure, initiated by the petition of the IP "National Unified Emergency Calls Service 112" of the Ministry of Internal Affairs, is partially admitted.

2. Letter No. 05-5/2813 dated 03.07.2026 concerning the completion of the administrative procedure, initiated by the petition of the IP "National Unified Emergency Calls Service 112" of the Ministry of Internal Affairs, is modified by excluding, from its content, the text "Now, in the situation where it was found the existence of an insurance policy for the same vehicle, issued by C.A. "ACORD GRUP" S.A., series RCAI No. [...] dated 22.10.2025, valid at the date of the road accident, the legal person being insured, under Art. 8 para. (3), and Art. 30 para. (1) lit. a) of Law No. 106/2022, was entitled to file a regression action within the limits of the sum paid to C.A. "ACORD GRUP" S.A.".

3. This Decision may be contested with an administrative litigation action, submitted to the Chișinău Court, Râșcani seat (MD-2068, Chișinău city, Kiev st. 3), within 30 days from the date of its communication.

4. This Decision enters into force on the date of adoption, is communicated to the recipient in accordance with the legislation, and is published on the official website of the CNPF (www.cnpf.md).

Dumitru BUDIANSCHI,
PRESIDENT