On 16 September 2026, Russia’s Ministry of Foreign Affairs (МИД России), the federal authority responsible for the country’s foreign policy, explained the general approach to migration policy: the country remains open to foreign nationals arriving to work and study, but the legality of their stay and employment is linked to security objectives. For employers, this is not a notice of new deadlines or obligations, but a signal to review existing HR processes.
What follows specifically from the MFA’s position
The published clarification does not name any new mandatory rules, their effective dates, transitional periods or special sanctions. Therefore, an employer does not need to restructure processes around a non-existent new requirement. However, the statement establishes the direction of state policy: clear procedures for lawful stay, digital services, transparency in employment relationships and a reduction in informal employment.
The practical meaning of this position is that lawful employment is becoming not only a matter of an individual document, but also of the quality of the entire hiring process. It is important that information about the employee, their actual work, HR documents and the employer’s mandatory actions do not contradict one another. It is precisely these inconsistencies that create a risk of claims during an inspection.
Why ongoing HR controls matter more than a one-off check
When hiring foreign workers, it is not enough to verify their documents only on the day they start work. Employers should maintain a single register containing each employee’s citizenship, legal basis for stay, document details and validity periods. Such a register makes it possible to view the workforce records as a whole rather than search for information in individual personnel files at the time of an inspection.
Controls should cover more than deadlines. The employment contract, position, place of work and actual duties should be compared with the migration documents. If an employee actually performs work that differs from the recorded information, formally completed documents do not eliminate the risk. The MFA statement does not describe a specific procedure for this comparison, so the company should establish one within the applicable requirements.
How to reduce dependence on “grey” schemes and intermediaries
The MFA directly links transparent procedures with reducing the risk of workers being drawn into “grey” schemes operated by unscrupulous employers. For businesses, this means the need to eliminate unofficial payments, sham contracts and allowing employees to start work before the required procedures are completed. Such decisions may seem fast, but they deprive the employer of control and do not reflect the actual employment situation.
Using a contractor to recruit personnel does not eliminate the need for the employer’s own controls. The agreement with the intermediary should specify its responsibilities for checking documents and supporting the employment formalities, but the result should be verified independently. A sample audit of the contractor helps establish what information it provides, how it confirms that the information is current and whether the personnel supplied meet the applicable employment-formalisation requirements.
Digitalisation as part of a manageable process
The MFA points to the development of digital services and the simplification of administrative procedures. The statement does not list specific services or establish a mandatory method for using them. It should therefore not be interpreted as introducing new technical requirements. At the same time, employers should reasonably appoint a person responsible for monitoring available digital tools and using them under the existing procedure.
A digital approach is primarily useful for internal discipline: it helps record deadlines, confirmations that mandatory notifications have been sent and the status of documents. It does not replace a substantive review, but it reduces the risk of a task being left without an owner. It is advisable to review the current HR records without waiting for specific changes, based on the validity periods of each employee’s documents.
What to check
- Create a single register of foreign workers containing citizenship, the legal basis for stay and document validity periods.
- Check that the required grounds and documents are in place before allowing each employee to start work.
- Compare the contract, position, place of work and actual duties with the recorded information.
- Check mandatory notifications and retain confirmation that they were sent.
- Eliminate unofficial payments, sham contracts and informal access to work.
- Appoint a person responsible for monitoring deadlines and available digital services.
- Conduct sample checks of contractors supplying foreign personnel.