Moscow Mayor Sergey Sobyanin (Мэр Москвы Сергей Собянин) presented the results of the city’s migration system and noted that the existing control mechanisms help improve safety. Migration control is the process of checking whether foreign nationals may lawfully stay and work. The available description contains no information about a new law, changed procedures, deadlines, payments, or sanctions. Therefore, an employer should not restructure its HR process solely on the basis of the statement, but should check how effectively the existing controls work in practice.
The Statement Does Not Mean New Obligations Have Been Introduced
The publication describes an assessment of existing migration control mechanisms. It does not indicate that Moscow employers have been given additional reporting requirements, a new procedure for hiring foreign nationals, or new document requirements. It also does not provide specific performance indicators for the system.
The practical takeaway for a company is to distinguish informational statements from regulatory changes. It is premature to amend internal policies, request unfamiliar documents from employees, or change the deadlines for HR actions until official acts and explanations with specific content have been published.
Pre-Employment Checks Remain a Key Process Point
For an employer, risk arises not only when employment documents are signed, but also when a person actually starts work. Before allowing a foreign national to work, it is necessary to ensure that they have valid documents required for lawful employment and that the work itself and the region comply with those documents.
It is useful to organize this check as a recurring process rather than a one-time hiring step. The HR department should track document control dates and record HR actions. This helps identify issues before an employee arrives at a site without proper authorization.
Particular Attention to Contractors and Work at Client Sites
Checks are needed not only for employees hired directly by the company. If foreign nationals work at a site through a contractor, staffing agency, or chain of subcontractors, it is important for the company to understand who has actually been allowed to perform the work and on what basis.
A useful management tool is to request from the contractor a register of foreign workers at the sites and confirmation of their lawful employment. This does not eliminate the need to assess the actual situation: the formal presence of a list does not guarantee that the people who arrived at the site are the individuals listed or that their documents are valid.
How to Allocate Responsibility for Checks Within the Company
The effectiveness of checks depends on clear responsibility. One employee or department should track documents and their expiration dates, while site managers should prevent people whose status has not been confirmed from performing work. It is important that HR information reaches those who decide whether a person may actually start a shift or work at a site.
It is also necessary to monitor HR events that require mandatory notifications and ensure that those notifications are submitted on time. The source material does not specify the deadlines for such actions, so the applicable rules for the specific situation should be followed rather than the date on which the statement was published.
Consequences of a Passive Approach
If documents are not checked and actual access to work is not reconciled with HR records, a violation may be discovered only after a person has arrived at a site. The consequences depend on the nature of the violation and the applicable rules; the material presented specifies neither the amounts of sanctions nor any special measures for employers.
In addition to possible orders from authorities and administrative liability, the company may face difficulties continuing the work and questions from the client. Regular reconciliation of documents and contractor registers is therefore not a reaction to the statement, but part of a manageable HR process.
What to Check
- Check that foreign workers have the valid documents required for lawful employment.
- Verify document validity periods and enter the control dates in the HR calendar.
- Make sure that the worker is allowed to perform work that corresponds to their documents and is located in the relevant region.
- Check HR events that require mandatory notifications and whether those notifications are submitted on time.
- Request from contractors registers of foreign workers at the sites and confirmation of lawful employment.
- Appoint a person responsible for monitoring official changes in Moscow and at the federal level.