The Ministry of Labour of Russia (Минтруд России), the federal authority responsible for labour policy and regulation, proposes allowing the “MAX” messenger («МАКС») to be integrated into employers’ HR electronic document management information systems and commercial platforms. This is a proposal, not a requirement that has entered into force. For businesses, the key issue is not urgently changing the HR systems landscape, but conducting a prepared assessment of how an additional channel could fit into existing processes.
What the Ministry of Labour is proposing
The initiative provides for the possibility of using “MAX” for interaction between an employer and an employee within HR electronic document management (HR EDI; кадровый электронный документооборот). The messenger is viewed as an additional means of communication, not as a replacement for the HR EDI system currently in use. A company should not interpret the message as an instruction to move HR operations to a new service.
According to the material presented, the core HR EDI setup may remain in the employer’s information system, in an HR EDI provider’s solution or on the Work in Russia portal («Работа в России»). This structure is important for management planning: the subject of the assessment is a potential integration with the setup already in use, not the selection of a new mandatory channel.
Which HR processes could be affected by the potential integration
For an employer, an additional channel primarily affects the organisation of interaction with employees. Before making technical decisions, it is useful to document where the company currently conducts electronic HR document exchange, what employee actions are provided for under the existing procedure and which channels are already used for communication on HR matters.
The ability to verify the exchange requires particular attention. The material does not establish rules for identification, confirmation of receipt or signing documents through “MAX”. Therefore, when assessing a future integration, it cannot be assumed in advance that the messenger will resolve these tasks: the procedure will depend on regulatory and technical requirements that have not yet been presented.
How to organise internal controls without premature changes
In practical terms, it is reasonable to assess not implementation, but the readiness of the current HR EDI system. The HR function, IT and the person responsible for personal data protection can compare the existing exchange process with the possibility of adding another channel. This will make it possible to identify in advance questions concerning access, activity logging and employee support.
The date on which the changes will enter into force, the integration timeline and any obligation to connect “MAX” have not been specified. Accordingly, the material presented provides no grounds for urgently rewriting the local procedure for interaction or abandoning existing channels. Until applicable rules are introduced, the company continues to operate under the applicable HR EDI rules.
Considerations for companies employing foreign workers
Employers hiring foreign nationals should consider the integration not only as a technical function. Employees must understand how electronic HR document exchange works and what actions are expected of them. The material specifically recommends assessing language support and employees’ actual access to the services.
It is also necessary to verify the procedure for identifying employees and protecting personal data. Specific requirements for “MAX” have not yet been defined, so it cannot be stated which documents or settings will be required. At the preparation stage, the employer’s task is to preserve a clear and verifiable process, rather than create a parallel, untested route for HR documents.
What to include in the monitoring plan
It is useful to request information from the HR EDI provider about integration plans and the anticipated terms of use. If the company uses its own information system, an internal IT team can carry out a similar assessment. The result is needed for resource planning, not for immediately launching a new way of interacting.
The further progress of the initiative and the emergence of regulatory rules should be monitored. Only after that will it be possible to determine specifically the procedures for identification and for receiving and signing documents. Under the material presented, not connecting “MAX” does not entail the stated negative consequences: the channel is presented as an additional one.
What to check
- Record which HR EDI system the company uses: its own system, a vendor solution or the Work in Russia portal («Работа в России»).
- Maintain the existing channels and procedure for issuing HR documents until the new rules enter into force.
- Request information from the HR EDI provider about plans to integrate with “MAX” and the terms of use.
- Assess how the employee’s identity, receipt of documents and document signing will be verified in the potential setup.
- Check the approach to personal data protection when a potential new communication channel is used.
- For foreign workers, provide clear instructions that take the language of communication and access to the services into account.