Deputy Prime Minister Marat Khusnullin stated the need to bring order to the organization of migrant labor at construction sites. The material presented does not specify new mandatory requirements, their effective dates, or special deadlines. However, construction employers, general contractors, and staffing intermediaries should assess how controllable the engagement of foreign personnel is at each site.
A signal for the construction supply chain, not a new rule
The statement concerns developers, technical customers, general contractors, contractors, subcontractors, and companies that provide personnel for construction work. In practice, a foreign worker may be present at a site through one project participant, while the actual management of the work and authorization to enter the site are handled by another. Therefore, control cannot be limited to the HR department of a single organization.
The call itself does not introduce new sanctions or change migration procedures. The material also contains no information on specific future measures or deadlines. Nevertheless, the absence of a clear control system increases the risk that existing violations will be identified during inspections, while the consequences are determined by the specific violation. Possible consequences mentioned include administrative fines, suspension of operations in cases provided by law, claims against the customer or general contractor, and disruption of work due to workers being denied access to the site.
Start with a map of actual employers
The first management action is to establish who exactly engages each foreign worker, who formalized the relationship with them, and who is responsible for their presence at the construction site. It is useful to carry out such verification not only for in-house personnel, but also for workers of contractors, subcontractors, and staffing intermediaries. This makes it possible to identify areas where documents and responsibility remain outside the general contractor’s field of view.
Contracts between construction supply chain participants should distinguish responsibilities for providing workers’ documents and liability for violations. The purpose of such a provision is not to shift formal liability without verification, but to ensure that up-to-date information is obtained before a person is allowed onto the site. If a personnel provider cannot confirm the grounds on which a particular person may work, this risk becomes visible before they enter the site, rather than during an inspection or work stoppage.
Link migration documents to authorization to work
Authorization to enter the site should be structured as a controlled process: before work begins, the passport, migration card (миграционная карта), registration, and document granting the right to work are checked. Particular attention should be paid to whether the patent or work permit corresponds to the region where the work is performed and to the actual job function. The formal existence of a document without such verification does not solve the control task at a specific site.
An access log helps record who is present at the site and on what grounds. It is needed not as a standalone formality, but as a link between HR verification, the contracting arrangement, and production control. Workers with expired or unverified documents should not be allowed to work. This reduces the likelihood that a problem will be discovered only after a shift has begun or during an external inspection.
Turn control from a one-time review into an ongoing process
A one-time audit is useful as a starting point, but documents, contracts, and notifications have key control dates. Therefore, the employer needs a register of foreign workers containing information on documents, employment relationships, and responsible persons. The validity periods of migration registration (миграционный учёт), notifications to the Ministry of Internal Affairs (МВД), Russia’s federal police and migration authority, and document renewals should be monitored separately under the general procedure: no new deadlines have been established in the statement.
The practical resilience of the process is also determined by occupational health and safety briefings. It is important to conduct them in a language understood by workers and to record their completion. Appointing a person responsible for migration registration and maintaining a calendar of key control dates help avoid separating HR, migration, and production processes. For construction, this means fewer grounds for denying workers access and more predictable management of resources at the site.
What to check
- Verify each foreign worker’s passport, migration card, registration, and document confirming the right to work.
- Check that the patent or work permit is valid in the region where the work is performed and corresponds to the actual job function.
- Check compliance with the applicable deadlines for mandatory notifications to the Ministry of Internal Affairs (МВД) on the conclusion and termination of employment contracts.
- Set out in contracts with contractors the obligation to provide workers’ documents and liability for violations.
- Maintain an access log for the site and do not allow workers with expired or unverified documents to work.
- Conduct occupational health and safety briefings in a language understood by workers and record their completion.
- Appoint a person responsible for migration registration and a calendar of key control dates for documents, notifications, and contracts.