What Businesses Want Changed in Organized Recruitment and How It Affects Hiring Plans

What businesses are proposing

The main concern is that the key rules of the mechanism are to be established by secondary legislation. For an employer, this means uncertainty, additional costs and difficulties with workforce planning: the rules will become known later than decisions on recruitment need to be made.

Four main requirements:

• establish the main parameters of the mechanism in the law itself, rather than in secondary legislation;
• abandon the single authorized bank;
• make inclusion in the register indefinite rather than time-limited;
• not extend the new regime to citizens of Eurasian Economic Union (Евразийский экономический союз, ЕАЭС) member states.

Businesses propose using the extra year to test information systems, prepare secondary legislation and train participants.

What this means for planning

No decision has been made: this is a proposal, not a change to the rules. The current draft regulations prepared by the Ministry of Internal Affairs (МВД) still provide for an experiment in 2027–2030, and employers should prepare for that timeline.

What to consider when planning for 2027:

• under the proposed system, a worker would come to a specific employer rather than look for work after entering the country — the staffing need would have to be declared in advance;
• the Ministry of Internal Affairs (МВД) would become the system operator, with powers transferred from the Ministry of Labour and Social Protection (Министерство труда и социальной защиты Российской Федерации, Минтруд); the Federal Security Service (Федеральная служба безопасности, ФСБ), the Federal Tax Service (Федеральная налоговая служба, ФНС), the Ministry of Labour and Social Protection (Минтруд) and the Ministry of Digital Development, Communications and Mass Media (Министерство цифрового развития, связи и массовых коммуникаций, Минцифры) would also be involved;
• registers of employers and workers are planned, meaning access to hiring would become subject to authorization;
• the information system and mobile application are planned to launch by December 1, 2026.

What to do now

Monitor the progress of the draft laws and do not redesign processes around rules that have not been approved. A practical step that does not depend on the outcome is to bring records on foreign workers into order: under a register-based model, this will become a condition for access to hiring.

FAQ

Will the pilot programme for the organised recruitment of foreign workers be postponed until 2028?

Not yet: business associations have only proposed postponing the start of the pilot programme from 1 January 2027 to 1 January 2028. No decision has been made, and the Ministry of Internal Affairs' (MVD of Russia) draft proposals provide for a pilot programme in 2027–2030.

The Ministry of Internal Affairs is the Russian government authority responsible, among other matters, for migration administration.

Why is business asking for the pilot programme to be delayed by a year?

The proposed one-year delay would be used to test information systems, prepare subordinate regulations, and train participants. Businesses also believe that the key rules of the mechanism should be set out in legislation rather than determined later by subordinate regulations.

Subordinate regulations are implementing rules issued by government authorities under a law.

What should employers prepare for in 2027?

Under the Ministry of Internal Affairs' draft proposals, employers would have to declare their staffing needs in advance because each worker would arrive for a specific employer. Registers of employers and workers are also envisaged, and eligibility to hire would become subject to authorisation.

A register is an official list used to determine whether an employer or worker is eligible to participate.

What should an employer do now?

Employers should not restructure their processes around rules that have not been approved, but they should monitor the progress of the draft bills. A practical step is to bring personnel records for foreign workers into order, as under the register-based model this would become a condition for eligibility to hire.

Personnel records are employer records documenting the employment and migration status of foreign workers.