The State Duma (Госдума), the lower house of Russia’s parliament, reported that a federal law (федеральный закон) introduces criminal liability for violating a number of requirements when entering into contracts for the provision of telecommunications services with foreign citizens and stateless persons. This report is relevant for companies that may be involved in arranging mobile service for foreign employees. However, the material provided does not specify the particular violations, the persons liable, or the penalties. Therefore, no conclusions about risks for an employer can be drawn from the publication alone.
What Exactly the State Duma Reported
According to the State Duma, criminal liability is provided for certain violations of legal requirements when entering into telecommunications service contracts with foreign citizens and stateless persons. The wording concerns specifically the execution of telecommunications service contracts, rather than all aspects of a foreign national’s use of mobile communications.
The source material does not disclose the elements of the offense. It also does not specify which acts or omissions may be deemed punishable. The penalties are not named either. Consequently, it cannot be asserted that criminal liability automatically applies to the employer, HR specialist, telecommunications operator, or the foreign citizen themselves.
Why the Report Requires a Review of Processes, but Not Hasty Conclusions
In some organizations, mobile service may be arranged in connection with the employment of a foreign worker: for example, where the company participates in organizational matters or supports the employee. The existence of such a process in itself does not mean that the company is subject to the new liability. This must be determined by the official text of the law.
The employer’s practical task is not to create rules based on a brief report. Until the law has been reviewed, new obligations should not be imposed on employees, procedures for registering phone numbers should not be changed, and internal prohibitions should not be announced as legal requirements. First, it is necessary to establish which requirements have been introduced, to whom they are addressed, and from what date they apply.
What Information Must Be Confirmed from the Primary Source
The publication states that the law is to enter into force “tomorrow” after the State Duma’s report. The calendar date is absent from the material provided. Therefore, for HR and compliance purposes, it is important to find the officially published federal law, verify its details, and independently establish its effective date.
The full elements of the offense, the persons subject to liability, and the penalties should also be checked against the primary source. These three elements determine whether the change affects a particular company and which processes require adjustment. Without them, neither the legal risk nor the scope of necessary internal actions can be reliably assessed.
Related Changes: Phone Number Limit and IMEI Database
The material separately states that from 2025, a migrant may register no more than 10 mobile phone numbers in their own name. This is a separate fact that should be considered when discussing the arrangement of mobile service for foreign employees. At the same time, the information provided does not explain the procedure for verifying the number of phone numbers and does not establish an employer’s obligation to carry out such verification.
In addition, telecommunications operators and government authorities will populate a database of IMEI codes for mobile devices. The material does not disclose the procedure for populating the database, the consequences for users, or companies’ obligations. An employer should not infer additional requirements for device records or employee documents from this report: such conclusions are possible only after reviewing the regulatory provisions.
What to Check
- Find the officially published text of the federal law reported by the State Duma.
- Check the law’s details and its exact effective date.
- Determine from the text of the law which actions when entering into telecommunications service contracts constitute a violation.
- Clarify who is named as a person subject to criminal liability.
- Check the penalties provided for by law.
- Compare the requirements of the law with the company’s processes if it participates in arranging mobile service for foreign employees.