Sergey Sobyanin said that checks of migration flows at transport hubs cover 53% of such flows in Russia. The published statement does not establish any new obligations for businesses. However, companies that hire foreign nationals or organize their travel should assess whether their HR processes are ready for possible document checks when entering or leaving the country and when passing through major transport facilities.
What is known about the checks
According to the Mayor of Moscow, checks of migration flows at transport hubs have reached 53% coverage nationwide. This is an indicator relating to flows, not to the number of employers, workers, or individual types of documents. The statement does not specify which transport facilities are included in this coverage or which procedures are applied there.
The published excerpt also does not name any new rules, notification forms, fine amounts, or special deadlines for employers. Therefore, companies should not introduce additional requirements that are not contained in legislation or in the confirmed statement. The practical conclusion is different: the importance of the migration-status checks already in force is increasing.
Which hiring processes need to be reviewed
Companies whose foreign employees regularly enter or leave Russia or travel to regions through transport hubs are most sensitive to changes in the checks. The risk for an employer arises not from the fact of travel itself, but from the possible discovery of an expired, missing, or situation-inappropriate document.
Before arranging an employee’s start of work, the HR department should match the grounds on which the foreign national is entitled to work with the terms of the employment contract and the actual place of work. In particular, it should check the passport, migration card (миграционная карта), an entry document issued to a foreign national, where applicable; migration registration (миграционный учёт), the required registration of a foreign national’s place of stay; a patent (патент), a work authorization generally used by visa-free foreign nationals; or a work permit, as well as a visa if one is required in the specific case.
How to organize internal document checks
It is more reliable to check documents not only when hiring but throughout the entire employment period. For this purpose, the employer needs a clear register of expiry dates for the passport, migration registration, patent, work permit, and visa. Separately, the employer should track proof of patent payments for the current period when an employee works on the basis of a patent.
It is useful to appoint a person responsible for migration deadlines and for preparing a document package for a possible check. Their task is not to create new paperwork unnecessarily, but to identify expiring documents in a timely manner, request current confirmations, and pass the information to the HR department. The statement does not establish a specific format for such a register: the company chooses it independently.
What to arrange before employees travel
Before an employee enters or leaves Russia or travels through a major transport facility, the employer should remind them to check their documents and their expiry dates. The employee should carry the originals or documents in the form required by law. This reduces the likelihood that a problem with the document package will become known only during the trip.
Such a reminder is especially important if different departments organize travel within the company: the HR department, project manager, personnel department, or contractor. They should agree in advance on who checks the migration status before travel. The published material does not define the checking procedure or the deadlines for preliminary verification.
Consequences of errors for businesses
If a foreign employee is found to have missing or expired documents, possible consequences include refusal of entry, a shortened period of stay, administrative liability for the employee, and an employer inspection. If violations of employment and migration legislation are identified, the company may face fines, suspension of operations in cases provided for by law, and the need to terminate the employment relationship with an employee who has lost the right to work.
The statement does not contain sanction amounts and does not change the current deadlines for migration registration, mandatory notifications, or the extension of authorization documents. Therefore, the employer should follow the rules applicable to the specific employee rather than the announced percentage of coverage. The main management task is to prevent a trip from exposing an existing HR compliance gap.
What to check
- Check the validity periods of foreign workers’ passports, migration registration, patents, work permits, and visas.
- Check proof of patent payments for the current period for workers who hold patents.
- Match the employment contract with the foreign national’s grounds for working and their actual region of work.
- Make sure that mandatory notifications of the conclusion and termination of contracts have been submitted within the deadlines currently in force.
- Appoint a person responsible for monitoring migration deadlines and preparing documents.
- Before trips, remind workers to check their document package and its validity period.