“Amina” and foreign employees: what employers should consider in HR processes

A foreign employee independently enters their residential address in the “Amina” app

Moscow Migration Center (ММЦ Москвы), the city agency responsible for migration services, explained the procedure for recording users of the “Amina” app («Амина»). The foreign national him- or herself enters the residential address and also transmits geolocation data. The participation of the property owner is not предусмотрена in this procedure: the owner does not need to confirm the information through a Multifunctional Public Services Center (МФЦ, a government service office) or the Unified Public Services Portal (ЕПГУ, Russia’s online public-services portal). For the employer, the clarification is important primarily as a guide for providing the employee with accurate advice and organizing internal processes.

Moscow Migration Center clarification: who enters the residence information

According to the Moscow Migration Center, the user of the “Amina” app independently enters the residential address and transmits geolocation data. This means that the action under the described procedure is performed by the foreign national him- or herself, not by the owner of the apartment or other housing where the person lives.

If the place of residence changes, the app user must also enter the new address. The publication does not establish the period within which this must be done. Therefore, the employer should not give the employee a specific update deadline unless it is confirmed by official rules applicable to the employee’s situation.

Why the property owner should not be included in HR communications

The Moscow Migration Center separately stated that the property owner does not confirm the information entered into “Amina” and does not participate in this procedure. Consequently, guidance for foreign employees should not include a requirement to obtain confirmation of the address from the property owner specifically for registration through the app.

The Center also reported that the owner does not need to apply for this registration at a Multifunctional Public Services Center or through the Unified Public Services Portal; any application will be refused. For HR and personnel departments, this is a practical signal not to create an unnecessary chain of approvals with the property owner and not to send the owner to obtain a service that is not provided to them.

The limits of the employer’s responsibility

The original clarification does not set out separate employer obligations concerning work with “Amina.” It does not require the company to verify the entered address, obtain geolocation data, confirm the information, or submit it on the employee’s behalf. The source also does not describe the consequences if the user fails to enter or update the data.

This does not eliminate the need for careful HR communications. The employer may tell the employee the substance of the official clarification and suggest that the employee independently check whether the app applies to them. However, internal instructions should not turn informational support into unconfirmed obligations for the company or the property owner.

How to organize the work process without unnecessary steps

It is useful to separate employment-related matters from the user’s actions in the app within the HR process. If an employee reports moving, the HR specialist may remind them that the user him- or herself enters the new address in “Amina.” At the same time, there are no grounds to require the property owner to visit a Multifunctional Public Services Center, submit an application through the Unified Public Services Portal, or confirm the information in the app.

Before applying this algorithm to a particular employee, it is necessary to check the current official rules and establish whether the employee is among the users of “Amina.” The Moscow Migration Center’s notice does not contain a list of all foreign-national categories to which the app applies, so no conclusion may be drawn solely from citizenship, position, or the fact of employment.

What is known about the expansion of the app’s use

The Moscow Migration Center announced that from 1 September 2026 the app will become mandatory for new categories of foreign nationals. However, the published notice does not specify these categories. For the employer, this means the need to monitor official documents in advance rather than compile a list of employees based on assumptions.

The clarification has the status of an explanation of the procedure, not a description of a new rule that has entered into force for all foreign nationals. Internal monitoring should be based on confirmed sources: verify the employee’s category and the applicable requirements, and only then explain the sequence of independent actions in the app.

What to check

  • Check the official documents to determine whether the particular foreign employee is a user of the “Amina” app («Амина»).
  • Check the current rules before incorporating the clarification into the company’s HR processes.
  • Do not send the property owner to a Multifunctional Public Services Center or the Unified Public Services Portal to confirm the “Amina” user’s address.
  • Explain to the employee that they enter their residential address and geolocation data into the app independently.
  • When the place of residence changes, remind the employee to check and enter the new address; the Moscow Migration Center’s notice does not specify an update deadline.
  • Check the official materials to determine which new categories of foreign nationals must use the app from 1 September 2026.

Sources

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