The Ministry of Internal Affairs (МВД), Russia’s interior ministry, reported that on 10 August 2026, a service for autonomously making decisions to declare a work patent (патент), a Russian work authorization for foreign nationals, invalid due to a foreign national’s non-payment of advance Personal Income Tax (НДФЛ) will begin operating. Employers are not explicitly named as the intended recipients of the announcement; however, the information is important for companies that transfer this payment on behalf of foreign nationals working for them or oversee this process.
What changes from 10 August 2026
According to the Ministry of Internal Affairs (МВД), from 10 August 2026, a service is expected to begin operating that will autonomously make decisions to declare work patents invalid. The stated ground is the foreign national’s failure to make an advance Personal Income Tax (НДФЛ) payment. This is a stated change in the decision-making procedure, not a new rule concerning the payment itself.
For a company’s HR and payroll functions, it is significant that the control point is linked to the fact of payment. The Ministry of Internal Affairs (МВД) reminds employers that advance Personal Income Tax (НДФЛ) under a work patent is paid monthly. At the same time, the published material does not provide a specific date for the next monthly payment, so it cannot be determined from this announcement.
Who is affected by the Ministry of Internal Affairs announcement
The announcement directly concerns foreign nationals working under a work patent, as well as persons who transfer advance Personal Income Tax (НДФЛ) on their behalf. A company may be part of this chain if it pays the tax for an employee or helps arrange the payment through an authorized person.
The Ministry of Internal Affairs (МВД) does not describe separate employer obligations in the announcement and does not explain the consequences for a company if a work patent is declared invalid. Therefore, an internal review should not be replaced with conclusions that are not contained in the source. The employer’s practical task is to understand who pays, how the payment recipient is identified, and where supporting documents are kept.
Payment by a third party: what information is required
The Ministry of Internal Affairs (МВД) separately explained the procedure for cases where advance Personal Income Tax (НДФЛ) is transferred by a third party. The payment comment must state the foreign national’s surname, first name and patronymic, date of birth, and Taxpayer Identification Number (ИНН). This information helps link the payment to the specific work patent holder.
For a company, this means it is necessary to check not only that a payment order or receipt exists, but also the content of the comment when payment is made by a third party. The Ministry of Internal Affairs material does not describe an omission or inaccuracy in the comment as an independent ground for a decision, so its consequences cannot be asserted in advance. However, the Ministry of Internal Affairs requirement for completing the comment should be included in the operating procedure.
How to establish internal controls without unnecessary assumptions
It is useful to divide the process into several clear stages: identify the payer, check the official Ministry of Internal Affairs (МВД) instructions before payment, verify the identifying information in the comment, and retain the confirmation. This approach does not change the payer’s status or create new obligations, but it helps ensure that the information required to verify the payment is not lost.
Controls can be maintained for each employee working under a work patent: who transferred the advance Personal Income Tax (НДФЛ), for which period confirmation is available, and where the original receipt is stored. Unverified deadlines should not be recorded in such a register: the Ministry of Internal Affairs (МВД) stated only that the payment is monthly, without specifying the calendar date by which it must be made.
If a decision declaring a work patent invalid appears
The Ministry of Internal Affairs (МВД) specifies the procedure for a foreign national who disagrees with the decision: they may apply to the Ministry of Internal Affairs unit that issued the work patent and present the original payment receipts. Consequently, an electronic reference to payment held by the company may be insufficient for the method of application specified by the Ministry of Internal Affairs: it is the original receipts that matter.
It is advisable for the employer to understand in advance who holds these documents and how they can be located promptly. At the same time, the announcement does not state that the company may challenge the decision instead of the foreign national, and it does not establish a deadline for such an application. These issues should not be inferred but, if necessary, clarified through the official instructions or with the unit that issued the work patent.
What to check
- Check whether the company has employees working under work patents and who actually transfers advance Personal Income Tax (НДФЛ) on their behalf.
- Review the official Ministry of Internal Affairs (МВД) instructions on paying for a work patent before making the payment.
- If payment is made by a third party, include the foreign national’s full name, date of birth, and Taxpayer Identification Number (ИНН) in the comment.
- Arrange for the storage of original payment receipts.
- Note that the Ministry of Internal Affairs (МВД) did not specify a particular date for the monthly payment in its announcement.