Comprehensive Changes in the Migration Sphere: New Requirements and Regulation

Dear Colleagues,

In recent years, the migration sphere undergoes a series of large-scale changes.

To help you navigate the planned innovations, we have prepared a consolidated overview of amendments to Russian migration legislation that come into force in 2026-2027.

The reforms cover digitalisation of registration, increased financial burden on foreign nationals, stricter requirements for labour migrants and their families, new rules for holders of temporary residence permits (TRP) and residence permits, as well as a fundamental change in conditions for highly qualified specialists (HQS).

Special attention is paid to procedural aspects, including new notification forms and consent to the processing of personal data.

1. Digitalisation of Migration Registration

1.1. Digital Profile of a Foreign National

As of 30 June 2026, the state information resource “Digital Profile of a Foreign National” has been established (Government Decree No. 735 of 12 June 2026).

A unified electronic database receives information from various government agencies: identity documents, migration registration data, employment and education records, medical insurance, real estate and vehicle ownership, as well as administrative offence records and entry bans.

A system of trust levels for the digital profile identifier is provided: “simplified”, “verified” and “enhanced” (requiring fingerprint registration).

1.2. The "Amina" Application for Foreigners from Visa-Free Countries

Starting September 1, 2025, as part of an experimental program in Moscow and the Moscow Region, the "Amina" application has been introduced.

This is an official state mobile application for remote migration registration (see also here).

Through the app, a foreign national submits a notice of their place of stay, and the application automatically transmits the smartphone's geolocation data to the Ministry of Internal Affairs.

Mandatory registration in the "Amina" app applies to foreigners from visa-free countries who have arrived in Russia for the purpose of employment.

In essence, this is a digital equivalent of paper-based registration: the system verifies whether the individual is actually present at the declared address.

The experiment commenced on September 1, 2025, in Moscow and the Moscow Region and will remain in effect until September 2029 (pursuant to Federal Law No. 121-FZ).

Furthermore, starting September 1, 2026, "Amina" will also become mandatory for visa-free foreigners staying in the capital region for more than 90 days for non-work purposes (such as study, guest visits, or extended trips to visit relatives).

1.3. New Pre-Entry Notification for Visa-Free Country Nationals

As part of an experiment that started on 1 July 2026 (extended until 31 December 2027), the mobile application “Gosuslugi RuID” has been created for foreign nationals entering Russia in a visafree manner. The application may also be used for submitting an entry application.

It is recommended to submit the application no later than 72 hours before crossing the border, providing passport data, purpose and duration of the trip, region of visit, as well as uploading biometric data and a photo. After processing, the system generates a QR code that can be presented at border control. The code is valid for 90 days.

Children under 6 are exempt from submitting the application; for children aged 6 to 18, parents or legal representatives who have a valid entry application may submit it on their behalf.

Currently, failure to submit the application does not formally constitute grounds for refusal of entry. At the same time, foreign nationals who fill in the entry application using the “RuID” application will enjoy a number of advantages. In particular, users of the said mobile application will be able to check in advance for any entry restrictions imposed by the Russian Ministry of Internal Affairs.

1.4. Automatic Information Exchange between Government Agencies from 2027

From 1 October 2026 (for data transmission) and from 1 January 2027 (for full operation), automatic and regular exchange of information between state bodies is being introduced:

• Federal Tax Service → Ministry of Internal Affairs: information on foreigners’ income (based on insurance contribution data) for 3, 6, 9 and 12 months, as well as income of selfemployed persons, and data on tax registration.
• Ministry of Internal Affairs → Federal Tax Service: information on a foreign national’s migration registration (when a temporary residence permit/residence permit is issued).
• Social Fund of Russia → Ministry of Internal Affairs: information on the employment history of foreign nationals (total length of employment, periods of work).

Previously, data exchange between the Federal Tax Service and the Ministry of Internal Affairs was not automatic or regular, but was carried out on a “requestresponse” basis. The new regime will allow for prompt detection of violations and decisions on cancellation of authorisation documents.

2. New Rules for Patents, temporary residence permits (TRP) and Residence Permits

2.1. New Condition of Stay: Income Level

From 1 January 2027, a law comes into force obliging labour migrants to support themselves and their family members living in Russia and dependent on them at a level not lower than the regional subsistence minimum established in the relevant constituent entity of the Russian Federation.

The relevant amendments are set out in Federal Law No. 241-FZ of 26 July 2026 “On Amendments to Federal Law ‘On the Legal Status of Foreign Nationals in the Russian Federation’”.

The minimum income is calculated using the formula:

Regional subsistence minimum × number of persons (employee + dependent family members).

At the same time, the required minimum income may not exceed the average monthly nominal accrued salary for the full range of organisations in the constituent entity for the most recent calendar year.

Foreign nationals holding temporary residence status in Russia are required to independently submit to the Ministry of Internal Affairs information on their income (income certificate, copy of tax declaration or documents confirming tax payment).

The absence of confirmed income or its amount below the regional subsistence minimum may serve as grounds for the authorised body to decide on the cancellation of a patent, work permit, or revocation of a TRP or residence permit.

2.2. Advance Payment of Personal Income Tax (for Work with Individuals for Personal Needs)

From 1 January 2027, foreign nationals carrying out labour activities with individuals for personal, domestic and other similar needs not related to entrepreneurial activity are required to pay a fixed advance payment of personal income tax.

The payment amount is RUB 1,700/month (for work under a patent with legal entities, individual entrepreneurs and selfemployed persons – RUB 1,200/month, subject to indexation by a deflator coefficient and regional coefficient).

If a foreign national has children under 18 years of age, as well as other dependent relatives, the amount of his/her advance payment increases by 50% for each such dependent. For example, with a base payment of RUB 1,700 and one child, the amount payable will be RUB 1,700 + 850 = RUB 2,550.

This provision is set out in the new version of Article 227.1 of the Tax Code, introduced by Federal Law No. 242-FZ of 26 July 2026.

Upon reaching the age of 18, children of labour migrants are required either to independently obtain a patent and pay it in full, or to leave the Russian Federation within 30 days. The temporary stay period of minor children may not exceed the validity period of the patent or work permit of their parent.

3. Substantial Increase in Requirements for Highly Qualified Specialists (HQS)

On 26 July 2026, Federal Law No. 241-FZ (previously Bill No. 1158407-8) was officially adopted (signed by the President of the Russian Federation), significantly changing the rules for attracting highly qualified specialists.

3.1. Previous Regulation (in force at the time of publication)

• Required minimum income level – RUB 750,000 per quarter (average RUB 250,000 per month).
• The employer is obliged to submit quarterly notifications to the Ministry of Internal Affairs confirming compliance with the income level requirements for the HQS employee.
• Work permit is issued for a period of up to 3 years.
• Since 2024, HQS have the right to obtain an indefinite residence permit (subject to conditions: work in HQS status for at least 2 years, residence in the Russian Federation for at least 2 years).

3.2. What Changes from 2027

1. Income Level Requirements

From 1 March 2027, new thresholds come into force:

• RUB 717,000 per month – basic minimum threshold for the majority of HQS.
• RUB 358,500 per month – reduced threshold for certain categories (research scientists and lecturers, employees of residents of special economic zones, accredited IT companies, participants in the Skolkovo, Sirius and innovative scientific and technological centres projects).

2. Annual Indexation

The salary amount for HQS is subject to annual indexation based on the growth rate of the average monthly accrued salary of employees of organisations for the previous year. The indexation coefficient is determined by the Ministry of Labour of Russia.

3. Transitional Provisions

Specialists who obtained HQS status before 1 March 2027 are entitled to change their migration regime (e.g. obtain a “regular” work permit under quota) in a simplified procedure without leaving the Russian Federation.

Important:

The new law does not contain changes regarding the possibility of aggregating salary amounts from different employers. Therefore, as before, if a foreign employee works for several employers as an HQS, the requirement to pay a salary of RUB 717,000 will from 1 March 2027 apply to each employer. At the same time, the cost of rental accommodation, voluntary medical insurance or education fees cannot be directly included in the minimum salary threshold for HQS if they are structured as a social package.

It is important to consider that the new salary threshold applies from 1 March 2027, so the minimum salary must be at least RUB 717,000 from March (i.e. from the third month of the first quarter of 2027 – January, February, March). For January and February 2027, the old requirements apply.

3.3. What to Do if the New Requirements Are Not Met

If the company is unable to provide remuneration in accordance with the new requirements and decides to terminate the employment contract, it is important to take into account the specifics of the dismissal procedure for HQS. One of the following options must be chosen:

• Dismissal upon expiry of the work permit: the employment contract is subject to termination one month after the occurrence of circumstances related to the expiry of the authorisation documents. The employee must be suspended from work for 1 month.
• Dismissal by agreement of the parties by signing a corresponding agreement between the employer and the employee.
• Staff reduction subject to all mandatory procedures, including 2month notice, offer of vacancies, preferential right to remain at work, payment of severance pay, prohibition on dismissal of certain categories.

In any case, the employing company will be obliged to notify the migration authorities of the termination of the employment contract with the HQS employee.

It is important to bear in mind that the regulation does not provide options for deviation from the target remuneration amount. An HQS may take leave without pay, but the total salary of the HQS for the quarter must in any case not be less than the relevant threshold so that the employee does not lose the status of a highly qualified specialist.

If further employment of the employee is envisaged, but no longer as an HQS, alternative options for the employment of the foreign specialist will need to be considered. Alternative registration options for the employee (without HQS status) are discussed in Section 4 below.

4. Special Categories and Alternative Statuses

4.1. Temporary residence permit (TRP) “for Values”

By Decree of the Government of the Russian Federation No. 2560-r of 17 September 2024, a list of 47 states was approved (USA, UK, Germany, France, Japan, etc.), whose citizens may obtain a TRP outside the quota and without confirming knowledge of Russian, history and fundamentals of legislation. They may also be issued single-entry private visas for 3 months.

4.2. “Talent Visa”

From 15 April 2026 (Presidential Decree No. 883 of 2 December 2025), a mechanism has been launched for foreign nationals “of interest to the Russian Federation”: scientists, soughtafter specialists with at least 5 years of experience, entrepreneurs, investors, students of top100 universities, athletes, and creative industry professionals.

The procedure consists of several stages:

• Application to a nonprofit organisation – operator (Agency for Strategic Initiatives).
• If a positive recommendation is given, the application is sent to the Ministry of Internal Affairs for interdepartmental coordination.
• Consideration by the working group of the Commission on Citizenship under the President of the Russian Federation (the entire process may take from 95 to 125 days).

Successful candidates obtain a TRP without quota and without examinations, and subsequently a residence permit, with simplified employment for them and their family members.

4.3. Residence Permit by List of Professions (without TRP)

By Order of the Ministry of Labour of Russia No. 172n of 3 April 2025, a list of 29 professions was approved that are entitled to obtain a residence permit without prior obtaining a temporary residence permit.

The list includes, for example, such positions as big data analyst, software engineer, design engineer, process engineer, electronics engineer, etc. Conditions for obtaining a residence permit in a simplified procedure are: continuous work in the profession in the Russian Federation for at least 1 year, confirmation of payment of insurance premiums for that period, and confirmation of qualifications. The application review period is 4 months.

4.4. Registration under Quota (Work Permit)

Registration under quota is the most understandable and familiar scheme for legalising labour relations with foreigners.

The main advantage of this option is the absence of a requirement to maintain a high salary level, which is particularly relevant in light of the new salary thresholds for HQS.

However, this method has significant disadvantages: lengthy bureaucratic processes related to obtaining and distributing quotas, the impossibility of registering family members within the same status, and a higher tax burden on the employer.

4.5. Registration outside Quota by List of Professions

This is a faster process compared to quotabased hiring, but this option is only possible for a closed list of positions.

At the same time, migration authorities strictly match the job title in the employment contract, staffing table and the Ministry of Labour list. If a foreigner is appointed to the position of “General Director” (according to the Unified State Register of Legal Entities and the company’s charter), it will not be possible to submit documents for the position of “Enterprise Manager” – these are different qualification codes.

At the same time, there is no requirement to maintain a high salary level.

However, the list of professions giving the right to such registration is narrow and limited.

As with the quota, it is impossible to register family members who have the right to work in the Russian Federation without obtaining their own authorisation documents; a higher tax burden on the employer remains, and it is also required to pass a test on Russian language knowledge and undergo an annual medical examination.

4.6. Temporary Residence Permit (TRP)

This is one of the most flexible options, as it allows registration not only of the employee himself. An important advantage is the absence of a tie to a specific employer: a TRP holder may freely change jobs within the region of issue.

In addition, after one year of residence on the basis of a TRP, a foreigner acquires the right to apply for an indefinite residence permit.

Among the specific features are the tie to the region of issuance, the annual obligation to submit a notification of confirmation of residence, and the requirement to pass a test on Russian language, history and fundamentals of legislation (except for cases of obtaining a TRP “for values” and under the “Talent Visa”, where such requirement does not apply).

4.7. Residence Permit

A residence permit provides the broadest scope of rights among all migration statuses, allowing a foreign national to permanently reside and work in Russia without the need to obtain additional permits.

The choice of the optimal registration option depends on the specific situation, including the qualification of the foreign specialist, the presence of family members, the intended period of stay in Russia and the financial capabilities of the employer.

5. Other Changes

5.1. New Notification Forms

From 1 September 2026, new forms come into force (Order of the Ministry of Internal Affairs of Russia No. 290 of 12 May 2026), including:

• petition for the engagement of an HQS;
• notification of employment by an organisation providing employment services;
• notification of salary payment to an HQS (a field for TIN has been added, information on profession has been excluded);
• notifications on conclusion and termination of an employment contract (now indicating the term of the contract).

5.2. Consent to Processing of Personal Data

From 1 September 2026, consents to the processing of personal data of the foreign national must be attached to notifications. Unlike the current procedure, where the consent is included in the notification forms themselves, now a separate document will be required.

The recommended form of consent is contained in Order of the Ministry of Internal Affairs No. 290. It is expected that at the beginning of application of the new regulation, the Ministry of Internal Affairs will expect to receive consent in the format of the recommended sample; however, final practice will develop after the requirement takes effect.

Practical issues of filing notifications:

In the notification of salary payment to HQS, a field for the specialist’s TIN has been added and information on the profession has been excluded.

When submitting a paper notification, the consent must be attached as a separate document.

When submitting through the State Services portal, it is not yet known whether there will be an option to “attach a document” for uploading consent. It is expected that this technical capability will be introduced after the order takes effect.

In the notification of conclusion of an employment contract, it is now necessary to specify its term.

It should be recalled that fines for violations in the migration sphere are extremely high.

For noncompliance with the procedure or form of notification of hiring/dismissal of a foreign national, the fine may reach RUB 50,000 for officials and range from RUB 400,000 to RUB 800,000 (or suspension of activities for up to 90 days) for legal entities.

For violations when filing a notification of salary payment to HQS, the fine may reach RUB 70,000 for officials and range from RUB 400,000 to RUB 1,000,000 for legal entities.

Fines are applied for each notification filed with violations, so special attention should be paid to the correct completion of forms and compliance with deadlines.

5.3. Increase in State Duties

From 26 July 2026, new amounts of state duties for legally significant actions in the migration sphere come into force. The relevant amendments were set out in Federal Law No. 190-FZ of 26 June 2026.

Recommendations for Employers

• Conduct an analysis of the situation with HQS from the standpoint of workforce and financial planning, assessing the possibility of increasing salaries to the new thresholds from 1 March 2027.
• Draw up an action plan for each HQS employee, taking into account individual conditions.
• Assess the possibility of switching to alternative registration options for foreign employees (quota, TRP, residence permit, list of professions, etc.).
• Take into account the change in notification forms from 1 September 2026 and the mandatory attachment of a separate consent to the processing of personal data.

We will be happy to answer your questions and help you navigate the regulation as it applies to your individual situation.