A concrete reason, in writing.
People’s safety, protecting property, preventing theft. “Just in case” is not a purpose. The purpose decides everything else: where the camera goes, what it sees and how long you keep footage (Art. 5).
A guide for employers, after August 23, 2026
Video cameras in the workplace. What is allowed, what is not, and what Law 195/2024 requires.
Yes, an employer may film in the workplace. But Law No. 195/2024 has no article on cameras and none on monitoring employees: the rules come from the law’s general principles, from Articles 91–94 of the Labor Code, and from the practice of the National Center and the European Court. Below we have gathered them in one place, with the articles cited — what you need in writing, where you must never film, and the most common mistakes.
This page summarizes the text of Law No. 195/2024, the Labor Code and the practice published by the National Center for Personal Data Protection. It is not legal advice; for your specific situation, ask a lawyer.
The short answer
Cameras are allowed if you tick six boxes.
None of them costs money or new equipment. All of them have to be written down before the cameras are switched on, not after the first complaint.
Legitimate interest, weighed.
For cameras, the usual basis is the employer’s legitimate interest (Art. 6(1)(f)), which has to be balanced against employees’ private life. A consent form signed by the employee does not replace a legal basis.
A sign at the entrance, a notice signed by staff.
The sign says who is filming, why and how long footage is kept (Art. 13). Employees also receive the document about the cameras and sign that they have read it (Labor Code, Art. 91(h)).
Never in private spaces.
Toilets, locker rooms, break rooms — no. Nor a camera pointed all day at one person’s desk, without a reason that justifies it.
A number of days, chosen by purpose.
The law gives no number. Set one yourself, write it into the document and delete automatically when it runs out. The longer the period, the better you have to explain why.
A record, and sometimes an impact assessment.
Continuous surveillance is not occasional, so it goes into the record of processing activities (Art. 30). Monitoring employees usually also requires an impact assessment (Art. 35).
Legal basis
Why employee consent does not protect you.
The most common mistake is a form signed at hiring: “I agree to be filmed.” It looks like protection. In fact it moves the processing onto a legal basis that barely works between employee and employer.
It must be free. Here it is not.
The law defines consent as a freely given, specific, informed and unambiguous indication of wishes (Art. 4) and lets it be withdrawn at any time (Art. 7). An employee who depends on a salary cannot refuse freely, and if they withdraw consent tomorrow, the camera would have to be switched off. The settled interpretation of the GDPR, which Law No. 195/2024 transposes, is that between employee and employer consent is valid only in exceptional cases.
It works, but it has to be weighed in writing.
Article 6(1)(f) allows processing for the employer’s legitimate interest, unless the employee’s rights override it. In practice: write down why you need the camera, why a less intrusive measure is not enough and what limits you have set. Employees keep the right to object (Art. 21), and then you have to show compelling reasons.
Labor CodeArticle 91(a) lists the purposes for which an employer processes an employee’s data, including the employee’s personal safety, monitoring the volume and quality of work, and protecting company property. An allowed purpose does not exempt you from proportionality: a camera on the warehouse door is not the same as a camera on the cashier’s face.
Limits
Where you do not film, however good the reason.
The law has no list of forbidden rooms. The limits come from the data minimization principle (Art. 5(1)(c)) and from the practice of the Center and the European Court of Human Rights.
Toilets, locker rooms, break rooms.
In 2026 the Center found a violation over four cameras installed in a school’s toilets, and recalled that such spaces are, in principle, incompatible with the right to private life.
Only as a narrow exception.
The European Court accepted one in a well-known case, with reasonable suspicion of theft after significant losses and for a short period. As a working rule, a hidden camera on employees does not pass.
Microphone off.
Recording conversations is far more intrusive than images and needs a separate justification. Many cameras ship with the microphone on — check it before you write that you do not record sound.
Not on one desk all day.
A camera that continuously watches one person’s workstation is the hardest to justify. Where cash or expensive goods are handled, the till or counter can be filmed; the person as the object of surveillance cannot.
- May be filmed, with a sign and a written legal basis
- Not filmed
- What the camera sees
From the corridor you may film the changing-room door, if needed, but not the inside.
Common mistakes
What is often done, and how it should be done.
Each row below is a situation we see at companies that have had cameras for years, installed before the new law.
SituationWhat is often doneHow it should be done
The sign at the entranceWhat is often done“Warning! CCTV in operation.” That’s all.How it should be doneWho is filming, why, how long footage is kept and what rights people have, plus where to find the rest of the information (Art. 13).
EmployeesWhat is often doneThey find out about the cameras when they see them on the ceiling.How it should be doneThey receive the document about the cameras before they are switched on and sign that they have read it (Labor Code, Art. 91(h)).
Legal basisWhat is often doneA consent clause in the employment contract.How it should be doneLegitimate interest, written down and weighed, with the reason why a less intrusive measure is not enough.
How long it is keptWhat is often doneAs long as the disk holds.How it should be doneA number of days chosen by purpose, written down in the document, with automatic deletion.
Who watchesWhat is often doneThe factory password, known to half the company.How it should be doneNamed access for a few people, with a log of who viewed footage and who exported copies (Art. 32).
Misconduct caught on cameraWhat is often doneA penalty imposed straight from the footage.How it should be doneA written explanation requested from the employee before any penalty (Labor Code, Art. 208). Footage is evidence, not the decision (Art. 91(f)).
The locker roomWhat is often doneA camera there too, “against theft.”How it should be doneNo cameras in private spaces. If needed, film the locker room door from the hallway, not the inside.
SoundWhat is often doneMicrophone on, because that is how the camera came.How it should be doneMicrophone off, unless there is a separate, written and balanced justification.
What you need in writing
Four documents, none of them long.
The Center says explicitly that lengthy legal texts are not needed: a clear, direct message written in good faith is enough. What matters is that the documents exist before the cameras are switched on and tell the truth about them.
The sign and the privacy notice.
The employer’s identity and contact details, the purpose and legal basis, the legitimate interest pursued, who receives the footage, how long it is kept, the rights of the person filmed — access, erasure, objection — and the right to complain to the Center. The sign at the entrance can be short and point to the full notice.
The document for employees.
Where the cameras are, what they see, why, who has access and how long footage is kept. Employees sign it when they are made familiar with it (point h), and data protection measures are developed together with them or their representatives (point j).
Record of processing activities.
Companies with fewer than 250 employees are exempt, but not when the processing is not occasional. Cameras that record day after day are not occasional, so CCTV goes into the record even at a small company.
Impact assessment.
It is required for high-risk processing. The list the Center approved under the old law (Order No. 27/2022) required an assessment when two criteria are met — and employee monitoring usually combines both: systematic monitoring, and people in an unequal position toward whoever monitors them.
How long it is keptThe law sets no number of days; it requires that footage not be kept longer than the purpose needs (Art. 5(1)(e)). As a benchmark, the inspections the Center has published show periods measured in days: at a school inspected in 2026, footage was kept for seven days. Choose the period by how long it takes you to notice and report an incident.
European Court of Human Rights
Three judgments behind the rules.
The Republic of Moldova answers to the European Court, and the courts and the Center draw on its case law when they assess employee monitoring.
Employees must be told in advance.
The Grand Chamber set the criteria by which any workplace monitoring is judged: prior notice, how far the monitoring goes, the legitimate reason, whether less intrusive measures exist, the consequences for the employee, and the safeguards provided.
There is private life at work too.
Cameras in a faculty’s lecture halls violated the teachers’ right to private life. The Court held that a lecture hall is part of professional private life, and that the surveillance did not meet the conditions of national law.
Hidden cameras, only as an exception.
The Grand Chamber accepted hidden cameras at a supermarket’s checkouts, but only because there was reasonable suspicion of theft after significant losses, the filming was short and limited to the checkout area. It is not a general permission.
Sanctions
The fines are large, but they are phased in.
Article 88 provides for up to MDL 1,000,000 or 1% of turnover for the controller’s obligations — records, security, impact assessment — and up to MDL 2,000,000 or 2% for principles, legal basis and people’s rights. Whichever is higher applies.
10% of the fine.
From August 23, 2026, only a tenth of the fine set by the Center applies (Art. 90(4)).
40% of the fine.
From the second year the law applies, the share rises to 40%.
The full fine.
From the third year, 100% of the fine set applies. This year is the cheapest moment to put things in order.
Where we come in
The same cameras, without tracking people.
Vizor is video analytics on the cameras you already have. A manager’s questions — how many came in, how long they waited, where they walked — do not need anyone’s identity.
Figures by zone and hour, without identity.
The system counts silhouettes and produces figures: how many came in, how long the queue lasted, which zones were avoided. No profile is built and there are no per-person reports. Figures leave the site, not images.
Recognized employees — biometric data.
If you register employees in the system, they are recognized by face. A facial template is biometric data, where the rule is a ban and the exceptions are narrow (Art. 9). If all you need is for staff not to skew the customer count, this is not required.
Read also
Related pages.
Law 195/2024 and video cameras
What Moldova’s new personal data law requires from a business with cameras: legal basis, notice, records.
Read →Facial recognition time & attendance
Employee attendance from your existing cameras, with no readers and no cards.
Read →Video analytics for stores
Conversion by hour, bypassed zones and checkout queues, in every store in the chain.
Read →Warehouses and distribution centers
Dock occupancy, blocked aisles and the zones nobody walks into.
Read →Frequently asked questions
The questions employers ask.
Am I allowed to install video cameras in the workplace?
Yes, if you have a concrete, written purpose — people’s safety, protecting property, preventing theft — a legal basis under Article 6 of Law No. 195/2024, usually legitimate interest, and if employees are informed before the cameras are switched on. The law has no special article on cameras: the general principles apply, together with Articles 91–94 of the Labor Code and the National Center’s practice. For your company’s specific situation, ask a lawyer.
Do I need employees’ written consent for cameras?
It is not the right answer. Consent must be a freely given indication of wishes (Art. 4) and can be withdrawn at any time (Art. 7), and between employee and employer its freedom is doubtful. The usual basis is the employer’s legitimate interest (Art. 6(1)(f)), weighed in writing. What the Labor Code requires is something else: that employees are made familiar, against signature, with the document on how their data is processed (Art. 91(h)).
Where is it forbidden to install cameras in the workplace?
In toilets, locker rooms, break rooms and any space meant for private life. The law does not list them, but the National Center considers them, in principle, incompatible with the right to private life, and in 2026 it found cameras installed in a school’s toilets to be a violation. A camera continuously pointed at one person’s workstation is also hard to justify.
Can I also record sound in the workplace?
Recording conversations is far more intrusive than images and needs a separate, written and balanced justification. Most sites do not have one, so the practical rule is: microphone off. Many cameras ship with the microphone switched on — check the setting before you write in the privacy notice that you do not record sound.
Can I install a hidden camera if I suspect theft?
Only as a narrow exception. The European Court accepted one in López Ribalda v. Spain (2019), because there was reasonable suspicion of theft after significant losses, the filming was short and limited to the checkout area. As a working rule, a hidden camera does not pass; talk to a lawyer before taking such a step.
How long can I keep camera footage?
The law sets no number of days: it requires that footage not be kept longer than the purpose needs (Art. 5(1)(e)). Set the period by how long it takes to notice and report an incident, state it in the privacy notice and delete automatically when it runs out. As a benchmark, the inspections the Center has published show periods measured in days.
What must a CCTV sign say?
Article 13 requires: who is filming and how to contact them, the purpose and legal basis, the legitimate interest pursued, who receives the footage, how long it is kept, the rights of the person filmed and the right to complain to the Center. A sign that only says “Warning! CCTV in operation” is not enough — the Center found exactly this gap in a 2026 inspection. The sign can be short and point to the full notice.
Do I have to notify the National Center that I have CCTV?
No. The notification obligation was abolished back in 2021, and Law No. 195/2024 does not bring it back. Instead you have internal obligations: the record of processing activities (Art. 30), an impact assessment where the risk is high (Art. 35) and, if the assessment shows a risk you cannot reduce, prior consultation with the Center (Art. 36).
Can I discipline an employee based on a video recording?
A recording can be evidence if it was obtained lawfully. But before any penalty you must request the employee’s explanation in writing (Labor Code, Art. 208), and a decision affecting them cannot rely solely on data obtained through automated processing or by electronic means (Art. 91(f)). Using footage for a purpose not stated in the privacy notice is the surest way to lose.
Can I use cameras to track how much each employee works?
The Labor Code allows monitoring the volume and quality of work as a purpose (Art. 91(a)), but continuous surveillance of every person is hard to justify as proportionate and usually requires an impact assessment. Management questions — how many customers came in, how long they waited, where the queue formed — do not need anyone’s identity.
What fine does an employer face for cameras set up wrongly?
Article 88 provides for up to MDL 1,000,000 or 1% of turnover for the controller’s obligations, such as records or security, and up to MDL 2,000,000 or 2% for breaching the principles, the legal basis or people’s rights. Fines are phased in: in the first year after August 23, 2026, 10% of the fine set applies, 40% in the second, and the full amount from the third (Art. 90(4)).
Contact
Do you have cameras and employees? Let’s look at it together.
We do not give legal advice. But we will tell you what can be measured on your cameras without tracking anyone, and reply within 24 hours, in writing.
What happens next
Three steps, no pressure.
1We reply within 24 hours, in writing, with what can be measured at your location.
2Thirty minutes on a single location: together we look at what your existing cameras cover.
3If it makes sense for you, we propose a pilot on three locations. You can stop it at any time, with no penalty.