The Moscow Migration Center (Миграционный центр Москвы) explained that, from 1 September 2026, foreign students who are citizens of nine countries must complete migration registration (the Russian procedure for registering a foreign national’s place of stay) through the “Amina” («Амина») app. For employers, this does not automatically mean the introduction of a new HR process: their obligations are not described in the published notice. However, companies employing foreign students should carry out a targeted review of employees’ documents and citizenship in advance.
Which employees may be affected by the change
The new method of migration registration through the “Amina” («Амина») app from 1 September 2026 is specified for students who are citizens of Tajikistan, Moldova, Georgia, Azerbaijan, Uzbekistan, Ukraine, Armenia, Kazakhstan and Kyrgyzstan. For the HR department, the first practical step is not to apply the notice indiscriminately to all foreign employees, but to verify the citizenship and status of the specific individual.
For citizens of all other countries, the Moscow Migration Center (Миграционный центр Москвы) states that the previous procedure under Federal Law No. 109-FZ “On Migration Registration” (Федеральный закон № 109-ФЗ «О миграционном учёте») remains in force. The clarification itself is addressed to students. It does not state whether the described procedure applies to other categories of foreign nationals, so HR decisions cannot be based on an expansive interpretation of the publication.
Why a new employer policy should not be introduced
The notice contains no separate requirements for employers. It does not establish new actions for HR staff, a company notification procedure, time limits for checking the app, or an obligation to monitor the receipt of a foreign national card. Therefore, prematurely adding such requirements to internal policies would create rules that are not confirmed by the source.
It is useful for an employer to maintain a neutral position: take into account the date of the change and the affected nationalities, but do not replace official rules with assumptions. If an employed student contacts the HR department with a question about registration, the applicable procedure should be checked against Federal Law No. 109-FZ “On Migration Registration” (Федеральный закон № 109-ФЗ «О миграционном учёте») and current official clarifications from the State Budgetary Institution “Migration Center” (ГБУ «Миграционный центр»).
How to set up monitoring without unnecessary requirements
Before 1 September 2026, an inventory of employed foreign students can be conducted: clarify their citizenship and review the expiry date of their current migration registration. This review will help identify the employees for whom the issue of the new procedure may become relevant, without drawing conclusions about the transition procedure in advance.
The publication does not specify transition rules for students who already have valid migration registration. It also does not name the deadlines for obtaining a foreign national card. Consequently, the expiry date of the current registration is important for internal monitoring, but it does not make it possible to determine independently when and how an employee must switch to the app.
Foreign national card: what is known and what is not
The State Budgetary Institution “Migration Center” (ГБУ «Миграционный центр») issues foreign national cards. A student can obtain one at a Center representative office after making an appointment in advance. This is the only specific information about the card contained in the clarification, and it should be communicated to the employee only to that extent.
The source does not establish that the card is mandatory for the operation of the “Amina” («Амина») app, does not describe the consequences of its absence, and does not specify an issuance deadline. A company should not require a student to provide the card as a mandatory HR document solely on the basis of this publication. If official clarifications are issued, the internal process can be reviewed.
What to check
- Clarify the citizenship of the employed foreign student and place them in one of the two groups specified in the clarification.
- Check the expiry date of the current migration registration in the employee’s HR documents.
- Record that the new date named in the clarification is 1 September 2026.
- Check the subsequent procedure against the current official clarification from the State Budgetary Institution “Migration Center” (ГБУ «Миграционный центр») and the provisions of Federal Law No. 109-FZ “On Migration Registration” (Федеральный закон № 109-ФЗ «О миграционном учёте»).
- Do not include obtaining a foreign national card among mandatory employee requirements without separate official confirmation.
- Do not change the employer’s internal obligations solely on the basis of this notice: they are not defined in it.