A foreign employee’s departure from Russia affects not only their work schedule but also the validity of their migration registration. The Moscow Migration Center (Миграционный центр Москвы), the authority that issued the clarification, reported that crossing the border ends the previous registration. Therefore, a new migration registration (the mandatory registration of a foreign national’s place of stay in Russia) must be arranged after the employee returns. This clarification also applies to foreign nationals working under a valid patent (a Russian work permit for certain visa-free foreign nationals) that was paid for in advance.
An Employee’s Departure Is a Reason to Update the HR Check
For an employer, the key event is not whether the employee had previously completed migration registration, but the fact that they left Russia. According to the Moscow Migration Center, the previous migration registration ends after the border is crossed. This means that information that was valid before the trip cannot automatically be considered valid after the employee returns.
It is useful to include the question of whether an employee has left Russia in regular HR checks for foreign employees. This is especially important if the trip was short: the length of the absence does not change the principle stated by the center that the previous registration ends when the border is crossed. The original message does not specify how an employer should obtain confirmation of the departure, so the specific verification method should be determined based on official information and the company’s internal process.
A Patent Does Not Replace New Migration Registration
A valid patent does not eliminate the need to register again for migration purposes after returning to Russia. The Migration Center specifically emphasized this in relation to a patent that had been paid for in advance. In HR practice, this means that checking the patent and checking migration registration are two separate control tasks.
If an employee presents a valid patent, that alone is not enough to conclude that their migration registration remains valid after a trip. Employers should keep information about the patent separate from information about migration registration after the most recent entry in the employee’s records. This approach helps prevent one status from being mistaken for the other and makes it possible to identify in time that the employee has returned to Russia.
What to Check After an Employee Returns
The first practical step is to ask the foreign employee whether they left Russia. If they did, it is necessary to check whether new migration registration was completed after their return. This check also applies to employees whose patents remain valid and were paid for before the trip.
Do not rely only on information collected before the departure. The center’s clarification specifically concerns the termination of the previous registration and the need to complete new registration after the return. The original material does not identify the documents that should be requested or the party responsible for completing the registration. Therefore, the list of documents and the allocation of responsibilities cannot be inferred from this clarification.
How to Set Up Internal Controls Without Unnecessary Assumptions
An employer can designate a return from abroad as a separate control point in the HR process. After an employee reports their return, the employer should check whether new migration registration has been completed and then record the result of the check according to the company’s established procedure. This does not change the registration rules, but it helps ensure that the situation is not overlooked among other HR events.
It is important not to supplement the clarification with unverified deadlines, requirements, or consequences. The Moscow Migration Center’s message does not specify the deadline for completing the new registration. The original material also does not describe what happens if new migration registration has not been completed. For decisions that depend on deadlines and procedures, it is necessary to consult the center’s official information.
Where to Clarify the Registration Procedure
The Moscow Migration Center’s message names the “Amina” app («Амина») for completing the registration. This can be taken into account when informing a returning employee and preparing an internal instruction. At the same time, the original material does not explain the sequence of actions in the app or the data or documents required for registration.
The clarification does not announce any new rules. It explains the existing approach: leaving Russia ends the previous migration registration, while a new entry requires new registration. Therefore, employers should use the center’s official publication as a starting point and clarify the details directly through current official information.
What to Check
- Ask whether the foreign employee left Russia.
- If the employee did leave, do not consider the previous migration registration valid after their return.
- Check whether new migration registration was completed after the new entry.
- Check the registration separately even if the employee’s patent remains valid and was paid for in advance.
- Note that the message from the Moscow Migration Center names the “Amina” app («Амина») for completing the registration.
- Verify the details of the registration procedure against the official information of the Moscow Migration Center: the original message does not provide deadlines or a list of documents.