From October 1, 2026, the procedure for notifying the Ministry of Internal Affairs of Russia (МВД — Russia’s federal agency responsible for migration matters) about foreign nationals working under a patent will depend on the employer’s status. If a foreign national works for a legal entity, the organization itself must submit notifications of contract conclusion and termination. This makes the notification process part of HR compliance: it is important not only to execute the contract but also to submit the information to the relevant territorial MVD office on time.
Who the change applies to and how responsibilities are allocated
The MVD notice concerns foreign nationals working on the basis of a patent, individuals who employ them, and employers that are legal entities. For the latter, a different approach applies than when a foreign national works for an individual: the notification obligation rests with the organization, not the worker.
When working for an individual, the foreign national must notify the relevant territorial MVD office himself or herself no later than two months after receiving the patent. A legal entity, by contrast, is required to submit notifications of contract conclusion and termination. The HR department must therefore first correctly identify the status of the party engaging the foreign national.
Which HR events require attention
A legal entity should structure its process around two events: concluding a contract with a foreign national working under a patent and terminating that contract. These actions should not be treated as isolated HR formalities: information about them must be submitted to the relevant territorial MVD office.
In practice, this means linking HR documentation with the notification workflow. The employee responsible for the contract must promptly pass the information to the person responsible for submitting the notification, and the organization must record the fact that it was submitted. The original notice does not provide the details of the regulatory document or the detailed procedure form, so these should be verified against the official source before the procedure is applied.
The three-day deadline: what is known and what needs clarification
For employers, the MVD specified a three-day deadline. However, the notice does not explain whether these are calendar or business days, or which specific event starts the clock. These rules should not be inferred independently: this uncertainty requires verification against the official regulatory document.
Pending clarification, the employer should determine in advance an internal procedure for transferring information between the HR function and the employee who submits notifications. This reduces the risk of a situation in which the contract has already been signed or terminated, but the responsible person learns about it too late to meet the three-day deadline specified by the MVD.
The risk of dismissal and the importance of internal controls
The MVD separately points to the consequences of late notification of dismissal: a fine of up to 800 thousand rubles or suspension of operations for up to 90 days. The notice refers specifically to a late dismissal notification; this conclusion should not be extended to other cases without official clarification.
For the employer, this is a reason to check how the contract termination date is recorded, who receives this information, and who is responsible for submitting it. A control stage confirming the notification status and the fact of submission is useful. This approach helps manage the process rather than discover a problem after the HR event has been completed.
How to organize submission without unnecessary gaps
The MVD reports that employers may submit notifications through the Public Services portal (Госуслуги — Russia’s government e-services portal). This channel can be taken into account when planning the process; however, the notice provided does not describe the technical steps, account requirements, information to be attached, or proof of submission.
The organization should appoint a person responsible for notifications, designate a backup employee, and divide responsibilities between the HR department and the person who submits the information. It is also important not to confuse the rules for legal entities with the procedure for a foreign national working for an individual: different persons act as the notifying party in these situations.
What to check
- Verify that the engaging party is a legal entity and that the worker is employed on the basis of a patent.
- Include notifications of contract conclusion and termination in the HR workflow.
- Appoint a responsible person and a backup employee to submit notifications.
- Take into account the three-day deadline specified by the MVD.
- Verify against the official regulatory document whether the deadline is measured in calendar or business days and which event starts the calculation.
- Check whether notifications can be submitted through the Public Services portal.
- Record the fact of notification submission as part of internal controls.