A statement by Dmitry Medvedev in an interview with Vedomosti («Ведомости») confirms the direction of migration policy: biometric checks on migrants’ entry and movement are planned across the entire territory of Russia. For businesses, this is a reason to assess the quality of their existing HR and migration processes—not a reason to change hiring rules immediately.
Biometric plans do not amount to a new company requirement
The material presented does not indicate that a legal act has been adopted that has already introduced a nationwide system, set its launch date, or established employers’ obligations. The types of biometric data, the procedure for using them, the implementation stages, and the mechanism for employers to verify the information have also not been disclosed.
HR departments need to distinguish confirmed information from assumptions. For now, the statement cannot be treated as an effective legal requirement; employers should not request new documents from candidates or employees or change internal procedures with reference to the future system.
Which processes may be affected by expanded checks
The changes could potentially affect employers that hire foreign workers, especially in cases of mass recruitment. The most sensitive processes will be those in which a person’s information passes through several departments: recruitment, onboarding, migration registration, HR administration, and document-expiry monitoring.
If discrepancies in the data or expired documents are discovered when the new mechanism is implemented, this could complicate inspections, employee onboarding, and confirmation that workers are legally present and employed. The statement does not name any specific penalties: these can be established only by future regulations.
What to check in the current migration compliance system
The employer’s practical task is not to collect biometric data independently, but to organize the records already available. It is useful to reconcile passports, migration cards, visas or patents, work permits, and their expiry dates. The register should make it possible to quickly see the employee’s grounds for stay, registered address, position, citizenship, and the expiry date of each document.
The process for migration registration and submitting mandatory notifications should also be assessed separately. Migration registration is the mandatory recording of a foreign national’s place of stay in Russia. The review is not intended to comply with biometric requirements that have not yet been established, but to eliminate inconsistencies in information already in use. This approach reduces the risk that HR staff will have to search for documents during an inspection or onboarding process.
How to establish internal controls without unnecessary requirements
Companies should appoint a person responsible for monitoring official publications by the Ministry of Internal Affairs of Russia (МВД России), the federal law-enforcement agency responsible for migration administration, the Government, regional authorities, and new regulations. These are the sources where the system’s start date, its application procedure, the possible obligations of participants, and liability should appear.
Until an established procedure is introduced, companies should not add a biometric-data requirement to their internal policies or request such data from foreign employees. Instead, they can prepare their HR departments for possible requests for documents and data reconciliation, designate the owners of the register, and establish rules for updating records.
What to check
- Reconcile passports, migration cards, visas or patents, work permits, and their expiry dates.
- Check that migration registration is up to date for each foreign employee.
- Make sure that mandatory notifications were submitted on time.
- Update the register with full name, citizenship, grounds for stay, registered address, position, and document expiry dates.
- Appoint an employee to monitor official regulations and announcements from the Ministry of Internal Affairs.
- Do not introduce your own biometric-data collection or request new documents without an established legal procedure.
- Prepare the HR department for possible reconciliation of documents and information.