The Moscow Migration Center (Миграционный центр Москвы), the authority that handles migration-related matters in Moscow, has announced a new registration procedure for adult foreign nationals who entered Russia without a visa and are staying in Moscow or the Moscow Region. From 1 September 2026, these foreign nationals will arrange registration independently through the “Amina” mobile app.
Which Employees Are Covered by the New Procedure
The experiment does not apply to all foreign employees without exception. According to the Moscow Migration Center, it applies to adult foreign nationals who entered without a visa and are staying in Moscow or the Moscow Region. Therefore, the HR department should not apply the new procedure to employees for whom at least one of these criteria has not been confirmed.
For the employer, the practical task is to distinguish between cases. The foreign national’s age, whether the entry was visa-based or visa-free, and the region of stay should be assessed separately. The source material does not explain exactly how these circumstances should be confirmed within the app, so internal procedures should not be supplemented with assumptions about documents or verification methods.
What Has Changed for an Employer That Owns the Apartment
The key change concerns owners of accommodation who act as the host party. The source states that apartment owners no longer need to submit a notification of migration registration to the territorial bodies of the Ministry of Internal Affairs of Moscow and the Moscow Region (территориальные органы МВД Москвы и Московской области). At the same time, the foreign national independently arranges registration through “Amina”.
For a company that provides an employee with an apartment it owns, this means that it needs to review how responsibilities are divided between the HR function, the real estate department, and the employee. The cancellation of the notification requirement is stated specifically for apartment owners in the capital region. The material does not disclose the specifics of other accommodation arrangements, so no conclusions about them should be drawn.
How to Incorporate the Change into HR Controls
It is useful for the employer to record in its HR process which cases require an assessment of whether the experiment applies. This does not mean creating a new list of mandatory documents: the source does not provide one. The issue is a working check of the initial conditions, so that registration through the app is not confused with situations not described in the Moscow Migration Center’s announcement.
If the organization owns the apartment provided, it is important to coordinate the actions of the employees responsible with the foreign employee. The foreign national is responsible for arranging registration independently through the app. The published material does not describe the employer’s role as arranging registration on behalf of the employee, so this function should not be treated as established.
What to Rely on When Checking the Procedure
As the legal basis, the Moscow Migration Center cites Federal Law dated 23.05.2025 No. 121-FZ (Федеральный закон от 23.05.2025 № 121-ФЗ). An employer that provides accommodation should compare its internal procedure with this law and check whether the experiment applies to the specific situation. This comparison is especially important before changing the usual process for interacting with the territorial bodies of the Ministry of Internal Affairs.
The start date of the new regime is stated expressly: 1 September 2026. The source contains no other time limits. In particular, the announcement does not specify the time limit for arranging registration through the app or the procedure for confirming that registration has taken place. These gaps should not be replaced with corporate interpretations as if they had been officially established.
What Should Not Be Inferred from the Announcement
The source material does not describe the consequences of failing to comply with the new procedure. It also contains no information about fines, additional employer obligations, the list of documents, or the technical steps in the app. Therefore, internal memos and instructions are best built around the confirmed conditions of the experiment rather than unconfirmed scenarios.
The new procedure primarily changes the registration process for the covered category of foreign nationals and relieves apartment owners of sending the relevant notification to the Ministry of Internal Affairs of Moscow and the Moscow Region. For the employer, the safest approach is to determine its role as the owner of the accommodation, check the employee’s criteria, and not apply the change more broadly than follows from the published information.
What to Check
- Determine whether the employer owns the apartment provided to the foreign employee.
- Check whether the employee is an adult and entered Russia without a visa.
- Confirm whether the foreign national is staying in Moscow or the Moscow Region.
- Compare the internal procedure with Federal Law dated 23.05.2025 No. 121-FZ (Федеральный закон от 23.05.2025 № 121-ФЗ).
- Take into account that, under the experiment, the foreign national personally arranges registration through “Amina”.
- Do not include unspecified time limits, documents, sanctions, or methods of confirming registration in internal instructions.