The Ministry of Internal Affairs (Министерство внутренних дел Российской Федерации, МВД; Russia’s federal agency responsible for migration matters) has prepared a draft of a new procedure for notifications concerning the employment of foreign nationals under a patent. The proposed model concerns a foreign national working for an organization, an individual entrepreneur (sole proprietor) or an individual, as well as the hiring party. For the employer, the key question is not whether the process will become simpler, but which specific actions will remain mandatory and when internal regulations may be changed.
What exactly the Ministry of Internal Affairs proposes to change
Under the draft, a foreign national will not be required to notify the Ministry of Internal Affairs of working under a patent for an organization or individual entrepreneur. This change concerns the notification submitted by the worker personally. It does not mean that all notifications to the Ministry of Internal Affairs connected with the foreign national’s employment will be cancelled.
For work under a patent for an individual, the notification by the foreign national is planned to remain. For this retained notification, the draft provides three submission methods: in person, by post or electronically. The presented material does not specify how these methods will align with the specific hiring party’s work processes.
Why HR must not confuse the two notifications
An organization and an individual entrepreneur retain an independent obligation to notify the Ministry of Internal Affairs of the conclusion and termination of an agreement with a foreign national. The draft does not expressly cancel these employer notifications. Therefore, reducing the worker’s actions must not result in the employer’s notification being removed from the HR process.
In practice, a risk arises when a company uses one general term — “patent notification” — for different procedures. In regulations, checklists and the allocation of tasks, it is useful to identify separately the action of the foreign worker and the action of the organization or individual entrepreneur. This approach helps prevent the proposed change to one obligation from being applied to another obligation that remains in force.
When the new procedure may apply
The draft specifies the proposed start date for the new procedure — 1 January 2027. However, the information presented does not confirm that the document has already been adopted as a regulatory act and entered into force. Therefore, the date cannot be considered finally established for changing HR procedures.
Until the document is officially adopted and enters into force, the employer should apply the current procedure. The employer should not stop checking or supporting notifications in advance based solely on the draft. The basis for revising the process should be the final version of the Ministry of Internal Affairs’ document as officially published.
How to prepare internal controls without premature changes
The employer should check the draft’s official status and determine which elements of the current procedure depend on the worker’s notification and which depend on the organization’s or individual entrepreneur’s independent notification. The purpose of this review is not to cancel actions in advance, but to prepare a clear process map for when the final act is issued.
After the final version is officially published, HR will need to compare it with the internal instructions. In particular, it is important to check whether templates, guidance notes and control points describe the foreign national’s obligation when working for an organization or individual entrepreneur as already applicable after the proposed date. The original material does not specify the details of the transitional procedure or any additional document requirements.
What is law here and what is a draft
The change itself is established by Federal Law No. 241-FZ dated 26 July 2026 (Федеральный закон от 26 июля 2026 года № 241-ФЗ), which amended the law “On the Legal Status of Foreign Citizens in the Russian Federation” (закон «О правовом положении иностранных граждан в Российской Федерации»). It enters into force on 1 January 2027 — this date is fixed by the law and is not under discussion.
The Ministry of Internal Affairs’ Order dated 14 August 2026 (приказ МВД от 14 августа 2026 года) approves the notification form and the procedure for submitting it. In other words, the details of completion may be debated, but not the date itself: the HR process must be planned from 1 January 2027.
What to check
- Check the official status of the Ministry of Internal Affairs’ draft.
- Do not treat the draft as a final adopted regulatory act.
- Distinguish in the regulations between the worker’s notification and the employer’s independent notification.
- Keep the current procedure in place until the new procedure enters into force.
- Before changing the process, locate the final version as officially published.
- Check that the organization’s or individual entrepreneur’s notifications of the conclusion and termination of the agreement remain within the control process.