Dmitry Medvedev announced plans to introduce a migrant tracking system in Russia. Based on the available excerpt of the announcement, it is impossible to determine how the mechanism will work, what data it will use or who will be required to provide it. For an employer, this is not a reason to change procedures immediately, but it is an opportunity to assess the quality of the migration and HR controls already in place.
What is known about the initiative—and what is not yet known
The published material refers to the planned introduction of a system for tracking foreign nationals. However, it does not disclose the technologies, registration procedures, data categories, rules for accessing the system or the participants involved. It also does not specify liability for violating future requirements or the date from which the mechanism could become mandatory.
It is important for a company to distinguish a political announcement from a rule currently in force. The announcement itself does not create a new employer obligation, require connection to any system or establish a format for submitting information. Until an official regulatory act is issued, the current requirements of migration legislation remain in effect.
Which departments could be affected
Potential changes concern more than just the migration compliance specialist. Work with foreign employees usually involves HR, legal and security departments, line managers and employees who handle documentation. This is relevant to employers and customers ordering work or services who engage visa-free workers, visa-required specialists, highly qualified specialists (ВКС) and other categories of foreign nationals.
The manager’s practical task is to understand in advance where information about foreign workers is stored and who is responsible for keeping it up to date. If passport details, documents confirming the right to stay, grounds for working and employment relationship data are kept in separate spreadsheets or by different people, it will be more difficult for the company to quickly assess its readiness for officially approved changes.
Why the data should be checked now
Preparation does not mean introducing new rules independently. A sensible step is to reconcile the documents and information already available: passports, migration cards (documents recording a foreign national’s entry and stay details), migration registration (the mandatory registration of a foreign national’s place of stay in Russia), work patents or work permits, and employment contracts. A voluntary health insurance policy (ДМС) should be checked if it is required for a particular category of foreign worker.
It is also useful to verify separately that there is evidence of submitting mandatory notifications to Russia’s Ministry of Internal Affairs (МВД России), the federal authority responsible for migration administration, about the conclusion and termination of employment contracts. This check helps identify discrepancies in current records rather than anticipated requirements of a future system. If documents and HR information are kept in order, adapting to official rules will usually require less organizational effort.
How to establish controls without unnecessary action
Companies should maintain an up-to-date register of foreign workers and appoint someone responsible for maintaining it. The register should make it possible to track the validity periods of available documents and changes in an employee’s information. Reminders help ensure that such changes are not overlooked and reduce dependence on the memory of individual employees or managers.
At the same time, employers should not request additional data from employees or introduce technical solutions solely because of the announcement. Until requirements are approved, neither the necessary data categories, nor the method of submitting them, nor the procedure for updating them is known. Excessive data collection is not a confirmed measure for preparing for the future mechanism.
Which documents and explanations to monitor
The content of future obligations may be defined by a draft law, government resolution or departmental procedure. These are the documents that should show whether employers will be required to submit or update information, which categories of foreign nationals the system will cover and how interaction with it will be organized.
It is advisable to assign monitoring to a specific employee or department. Useful sources include official publications of Russia’s Ministry of Internal Affairs (МВД России), the Government of Russia (Правительство Российской Федерации) and materials relating to draft laws. The available excerpt does not specify either the system’s launch date or a transition period, so no specific deadline for employers can be given.
What to check
- Prepare or update a register of all foreign workers.
- Appoint someone responsible for maintaining the register and monitoring official publications.
- Check the validity periods of passports, migration registration, work patents or work permits.
- Check voluntary health insurance policies (ДМС), if they are required for the relevant category of workers.
- Check employment contracts and evidence of submitting mandatory notifications to Russia’s Ministry of Internal Affairs (МВД России) about the conclusion and termination of contracts.
- Set reminders for document expiry and changes to an employee’s information.
- Do not introduce additional data collection or technical solutions until official requirements are approved.