Checking foreign workers’ income: what employers know from the Ministry of Internal Affairs announcement

A foreign worker and HR documents on an HR specialist’s desk

Russia’s Ministry of Internal Affairs (МВД России) reported that federal laws (федеральные законы) drafted jointly with Russia’s Ministry of Finance (Минфин России) have been signed. The changes are linked to combating sham employment, monitoring tax obligations, and checking foreign nationals’ income. The publication does not disclose any new obligations for companies; therefore, HR decisions should be made only after reviewing the official texts of the laws and explanatory guidance.

What exactly the Ministry of Internal Affairs reported about the new laws

The President of Russia signed federal laws developed by the Ministry of Finance of Russia (Минфин России) jointly with the Ministry of Internal Affairs of Russia (МВД России). According to the agency, their purpose is to combat the sham hiring of foreign nationals and strengthen oversight of their compliance with tax obligations. This description indicates the direction of regulation but does not replace the provisions of the laws themselves.

The confirmed change concerns monitoring a foreign worker’s income. Regional divisions of the Ministry of Internal Affairs will be able to determine whether a foreign national has income and assess its amount. At the same time, the original announcement does not contain the laws’ reference details, a complete list of affected persons, or special rules for individual grounds for employment or stay.

Why an employer should not automatically change its HR process

The Ministry of Internal Affairs publication does not identify any standalone employer obligations. It does not establish what information a company must collect, submit, retain, or verify in connection with a foreign employee’s income. Therefore, it is not justified to introduce a new internal document package or require additional evidence from employees based solely on this announcement.

The source also does not describe the employer’s involvement in the Ministry of Internal Affairs check. It is unclear whether the agency will use its own data, request information, or apply another mechanism. Until these matters are regulated in publicly available material, the appropriate management position is not to substitute legal requirements with assumptions and to document the uncertainty.

The link between an employee’s income and their stay

According to the Ministry of Internal Affairs, a foreign worker will have to support themselves and their family members taking into account the subsistence minimum in the relevant region. The regional connection is important: the agency expressly links the benchmark to the subsistence minimum of the constituent entity where the situation is assessed. However, the method for calculating the amount and the types of income taken into account are not explained in the announcement.

Following the check of the existence and amount of income, the Ministry of Internal Affairs will be able to consider shortening the permitted period of stay of a foreign national. This possible consequence applies to the foreign national. The source does not say that the shortening will occur automatically and does not disclose the procedure for such consideration, the grounds for the decision, or the employer’s role.

How to establish internal controls without unnecessary requirements

It is useful to divide monitoring into two tracks. The first is to review which foreign workers the company employs and what HR data is already maintained in the ordinary course. The second is to create a list of external issues for subsequent legal review: categories of foreign nationals, effective date, proof of income, and the Ministry of Internal Affairs procedure for deciding to shorten a period of stay.

This approach does not mean introducing a new obligation for personnel. Its purpose is to ensure that HR and legal functions are ready for the introduction of official rules. For example, an HR specialist may flag employees for whom clarification will be required after the laws are published, but should not draw conclusions about their status in advance or request documents not required by confirmed rules.

What remains unknown and what to monitor next

The Ministry of Internal Affairs reports that the changes are planned to enter into force next year, but does not provide an exact calendar date. The reference details of the signed federal laws are also not disclosed. Until they are published, it is impossible to reliably determine the transitional period, whether the rules apply to a specific employee, or whether the timing of internal reviews needs to be adjusted.

The full list of affected categories of foreign nationals, the methodology for assessing income, methods of confirming it, and the procedure for shortening the period of stay have not been determined. The source also does not establish the consequences of employer inaction. For the company, the main practical action remains monitoring official texts and explanatory guidance, rather than creating unverified HR requirements.

What to check

  • Record that the laws have been signed, but their reference details are not provided in the Ministry of Internal Affairs announcement.
  • Do not change HR procedures based solely on the Ministry of Internal Affairs publication: no standalone employer obligations are identified.
  • Review the official texts of the laws when they become available to determine the affected categories of foreign nationals.
  • Separately clarify the effective date of the rules: the Ministry of Internal Affairs refers to next year but does not specify a calendar date.
  • Monitor explanatory guidance on the method of calculating and confirming a foreign worker’s income.
  • Do not draw conclusions about consequences for the company: the source does not establish employer liability or a monitoring procedure involving the employer.

Sources

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