The clarification from the Moscow Migration Center (Миграционный центр Москвы), the body that issued the clarification, concerns foreign nationals and stateless persons temporarily staying in Russia who have a “green card,” including foreign workers without a temporary residence permit (разрешение на временное проживание, РВП) or a residence permit (вид на жительство, ВНЖ). A repeat medical examination is connected with the expiry of the medical documents: they are valid for 12 months. A brief departure from Russia is not itself identified in the clarification as grounds for repeating the procedure.
Why the HR department needs to track the date of the medical documents
In the HR process, it is not enough to know that an employee has a “green card.” A specific date for the medical documents is important for monitoring a repeat medical examination. The clarification links the need for a repeat procedure for a foreign national temporarily staying in Russia specifically to the expiry of those documents.
The medical documents remain valid for 12 months. Therefore, it is useful for an employer to record this date in an accounting system or working register of documents for foreign personnel. This approach helps avoid confusing the validity of medical documents with other HR events, such as an employee’s short-term trip outside Russia.
Who the repeat procedure applies to
According to the center’s clarification, a repeat medical examination is required if 12 months have passed since the “green card” was issued and no temporary residence permit (разрешение на временное проживание, РВП) or residence permit (вид на жительство, ВНЖ) has been obtained. This concerns foreign nationals and stateless persons temporarily staying in Russia, including company employees.
When checking status, it is important not to make assumptions. The source material does not describe how an employer should confirm that an employee has a temporary residence permit or residence permit, or what additional steps should be taken depending on the result. In practice, it is important first to clarify the employee’s status and then compare it with the date of the medical documents.
How to incorporate the check into HR controls
An employer may use a consistent internal check: establish the date on which the medical documents were issued, determine whether the 12-month period has ended, and clarify whether the employee has obtained a temporary residence permit or residence permit. This enables the HR specialist to work with verifiable information rather than relying only on the hiring date or the employee’s verbal explanations.
If the validity period of the medical documents has ended, the foreign national must undergo a repeat medical examination. The source does not establish any additional employer obligations, a notification form, document-retention procedures, or rules for interaction with government agencies. They should not be inferred from the center’s reminder alone.
What the 30-day period means
After the 12-month period ends, 30 days are provided for the repeat medical examination. For an employer, this means that it is necessary to monitor not only the documents’ one-year validity period but also the moment it ends: the specified period for the procedure is counted from that point.
The exact date for a specific employee is not provided in the material. It should be determined from the employee’s medical documents. The clarification also does not specify how to calculate 30 days in a disputed situation, so, where necessary, the procedure should be checked against official documents.
What should not be inferred from the clarification
The Moscow Migration Center (Миграционный центр Москвы) did not announce the introduction of new rules. This is a reminder about the existing validity period for medical documents and the need for a repeat medical examination after it ends under the stated conditions. Therefore, companies should not interpret the publication as a separate new basis for revising the entire HR process.
The source material does not identify the consequences of missing the deadline, fines, the liability of the employer or employee, or the list of documents required for the repeat procedure. This information requires separate verification against official sources. The one confirmed practical conclusion for an employer is to check the exact date of the foreign employee’s medical documents in a timely manner.
What to check
- Confirm the date on which the foreign employee’s medical documents were issued.
- Check whether their 12-month validity period has ended.
- Clarify whether the employee has a temporary residence permit (разрешение на временное проживание, РВП) or residence permit (вид на жительство, ВНЖ).
- If the period has ended and no temporary residence permit or residence permit has been obtained, take into account the need for a repeat medical examination.
- Count 30 days from the end of the medical documents’ validity period.
- If anything is unclear, check the procedure against official documents.