Category: Migration issues
Legislative and Enforcement Practice Digest: September 2026
Dear Colleagues,
Updating the information previously provided, we present a fresh overview of recent legislative developments and enforcement practice covering September 2026, as well as changes expected in the coming months.
1. Payments
1.1. New restrictions on taking cash rubles abroad
On 29 September 2026, the President of the Russian Federation signed Decree No. 706, amending Decree No. 193 of 25 March 2026 on the special procedure for taking Russian cash currency abroad. The decree entered into force on the date of signature (see also media reports 1, 2).
Key changes:
- For individuals, the limit on taking cash rubles to EAEU member states has been reduced from the equivalent of USD 100,000 to RUB 1 million; any excess is subject to seizure. Larger amounts may still be taken out only through international airports designated by the Russian Government, with bank documents confirming withdrawal of the funds from an account;
- The restrictions have been extended to Azerbaijan, Tajikistan and Uzbekistan;
- For legal entities and individual entrepreneurs, the ban in force since 1 April 2026 on taking cash rubles to these countries remains in place regardless of the amount; a violation entails seizure of the entire amount. Exceptions apply to international transport where both the point of departure and destination are outside Russia, subject to supporting documents, and to transfers based on notification by the Russian Ministry of Foreign Affairs to support diplomatic missions and consular posts.
The Russian Government, in agreement with the Bank of Russia, has been instructed to approve a procedure for recording cash rubles taken abroad within three months.
The following previously introduced restrictions also remain in force:
- Since 2 March 2022, taking foreign cash currency exceeding the equivalent of USD 10,000 out of Russia has been prohibited;
- The Bank of Russia has extended restrictions on foreign cash withdrawals until 9 March 2027: individuals may withdraw no more than USD 10,000, or the equivalent in euros, from foreign-currency accounts opened before 9 March 2022; residents may receive cash US dollars, euros, pounds sterling and yen only for business travel expenses within the prescribed limits; non-residents may not receive cash in these currencies.
1.2. Non-resident transfers: restrictions retained
The Bank of Russia has retained for six months from 1 October 2026 the ban on transfers abroad from accounts held with Russian brokers and trust managers by non-resident individuals and legal entities from unfriendly states. Funds of foreign investors recorded in type “In” accounts remain exempt.
As a reminder, the Bank of Russia’s general restrictions on cross-border transfers by non-residents from unfriendly countries are currently in place through 7 December 2026 inclusive.
Individuals resident in unfriendly countries who are officially employed in Russia may transfer funds abroad up to the amount of their salary. The ban on transferring funds abroad remains in place for legal entities from unfriendly states; it does not apply to foreign companies controlled by Russian persons.
No decision has yet been taken on the arrangements to apply after 7 December.
1.3. New channels: cryptocurrency settlements in foreign trade
As previously reported, Federal Law No. 282-FZ “On Digital Currencies and Digital Rights” entered into force on 1 September 2026, allowing digital currency to be used for settlements under foreign trade contracts (see our previous overview and our 2024 article on the legalization of cryptocurrencies).
On the same day, according to media reports, Sberbank launched a cross-border cryptocurrency settlement service for corporate clients engaged in foreign trade. Public sources indicate an average transaction cost of 0.3%, no minimum payment amount, transfers between crypto wallets completed within minutes, and automatic generation of documents for currency control purposes (see report).
Legislation on the taxation of cryptocurrency transactions is still being developed. Before using the new channel, we recommend agreeing with your bank on the supporting documents required and reviewing the accounting and tax treatment of such settlements.
1.4. Bank of Russia plans for cross-border settlements
On 11 September 2026, the Bank of Russia published the draft Guidelines for the Development of the Financial Market for 2027–2029.
For foreign trade settlements, the regulator plans to develop alternative settlement mechanisms and payment channels, reduce business costs and gradually lift restrictions on capital movements as the economy adapts.
In addition, according to media reports, the Bank of Russia plans to increase the limit on transfers between legal entities through the Faster Payments System. The timing and specific parameters have not yet been determined; we will monitor developments.
1.5. Digital ruble: the first stage of mass implementation has begun
From 1 September 2026, systemically important banks and banks significant in the payment services market must enable clients to transact in digital rubles. Merchants with revenue exceeding RUB 120 million in the previous year that are serviced by such banks must accept digital ruble payments (see Bank of Russia information). Further stages are scheduled for 1 September 2027 and 1 September 2028.
2. Banking news
2.1. Tax registration through a bank for foreign organizations
From 1 September 2026, under Federal Law No. 416-FZ of 17 November 2025, a foreign organization opening an account with a Russian bank is registered with the tax authority on the basis of the bank’s application. Within five days of receiving that application, the tax authority registers the organization and sends the bank an extract from the Unified State Register of Taxpayers. The foreign company no longer needs to apply to the tax authority itself.
For more on opening and servicing accounts for foreign companies, their Russian subsidiaries and representative offices, see our overview.
See also our overview of the legal forms through which foreign businesses can operate in Russia.
2.2. More banks subject to sanctions
On 23 July 2026, the Council of the EU adopted the 21st sanctions package. In the financial sector:
- The transaction ban was extended to a further 33 Russian credit and financial institutions;
- A bank in Kyrgyzstan connected to the Financial Messaging System (SPFS), as well as three other banks in third countries facilitating sanctions circumvention, became subject to the ban;
- Transactions were prohibited with 14 cryptocurrency platforms registered in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan and Belarus;
- Courts and competent authorities in EU member states were granted the right to refuse recognition and enforcement of judgments arising from claims brought before Russian courts.
On 6 August 2026, the United Kingdom added six Russian banks to its sanctions list: Ozon Bank, Roseximbank, Center-invest Bank, Realist Bank, Stavr Bank and Teleport Bank.
On 18 September 2026, H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, was signed into law in the United States, expanding the statutory basis for sanctions, tariff measures and prohibitions concerning Russia. The practical consequences will depend on the US administration’s implementation decisions. We will monitor developments.
Before making cross-border payments, we recommend checking the current status not only of the payer’s and recipient’s banks but also of correspondent banks.
3. Supply chains
3.1. SPOT: security payments on supplies from Belarus from 1 November
As previously reported (see our previous overview), the System for Confirmation of Expected Goods (SPOT) has operated since 1 June 2026, and security payments have been mandatory for supplies from Armenia, Kazakhstan and Kyrgyzstan since 1 July.
The exemption from security payments for supplies from Belarus entering via the Russia–Belarus border applies through 31 October 2026 inclusive; no information on an extension was available when this overview was prepared.
Accordingly, from 1 November 2026, obtaining a QR code for goods imported from Belarus by road will require a security payment equal to the import VAT and excise duties.
According to information from the Ministry of Finance and the Federal Customs Service, additional budget receipts generated by the system had reached RUB 33.8 billion by 10 September 2026, against an annual target of RUB 50 billion.
The business community’s proposal to replace the security payment with a bank guarantee is to be considered in the autumn. Businesses also propose reducing the revenue threshold for exempting compliant taxpayers from RUB 30 billion to RUB 5–10 billion.
Final decisions on adjustments to the system have not yet been taken.
3.2. Customs monitoring: pilot extended until 2029
Russian Government Resolution No. 1188 of 18 September 2026 extends the customs monitoring pilot until 31 March 2029, previously 31 March 2027. Eligibility has also been expanded: Russian declarants not classified as high-risk may join. Applications will be accepted until 30 September 2028. The resolution enters into force on 19 October 2026.
As a reminder, participants provide customs authorities with remote access to data in their accounting systems and, where risks are identified, have an opportunity to rectify violations themselves before customs control measures are applied.
3.3. Electronic transport documents: no penalties before March 2027
From 1 September 2026, under Federal Law No. 140-FZ, carriers, freight forwarders, consignors and consignees are required to issue transport documents electronically through the State Information System for Electronic Transport Documents (GIS EPD). The requirement covers road, rail and air consignment notes, transport orders and freight forwarding documents.
Paper documents remain available, in particular:
- For military and special cargo transport;
- For transactions with foreign counterparties;
- For transport for individuals’ personal needs;
- For border-area operations and in territories with special status.
According to information from the Ministry of Transport, an adaptation period applies until 1 March 2027: penalties for using paper documents instead of electronic ones will not be imposed. Please note that the ministry announced this adaptation period, but no regulatory act on the matter had been published when this overview was prepared.
3.4. New obligations for manufacturers and importers
A technology levy introduced by amendments to the Federal Law “On Industrial Policy in the Russian Federation” will apply from 1 December 2026. Manufacturers and importers of radio-electronic products will pay the levy.
The Ministry of Industry and Trade has prepared a draft order setting rates, including RUB 746 per laptop and RUB 373 per smartphone; rates are lower for products included in the relevant directory and higher for those not included (see also media coverage). The rates remain at the draft stage.
In addition, from 1 October 2026, manufacturers begin applying identification markings to household and sanitary-hygiene products, including paper towels, toilet paper, toothbrushes and diapers. Registration in the Chestny ZNAK system has been mandatory since 1 September 2026 (Russian Government Resolution No. 656 of 30 May 2026).
4. Other developments
4.1. Taxation
4.1.1. Under discussion: 35% tax on dividends paid into type “C” accounts?
On 24 September 2026, the Russian Government approved the budget package for 2027–2029; the bills are scheduled to be submitted to the State Duma by 1 October. The proposed tax measures are intended to take effect from 2027 (see media reports 1, 2). They include:
- An increase from 15% to 35% in the corporate income tax rate on dividends paid into type “C” accounts to non-residents from unfriendly states;
- Taxation of individuals’ passive income, including dividends, deposit interest, securities transactions and property sales, at progressive rates of 13–22%; income from deposits of up to RUB 1 million would not be taxed;
- VAT at 22% on cross-border e-commerce, with electronic platforms acting as tax agents, and a customs fee of RUB 100 per parcel valued at up to EUR 200;
- Corporate income tax at 15% on passive income of mutual investment funds;
- A tax on additional income arising from increases in world prices for companies extracting solid minerals, at 30%, or 20% for gold producers.
The higher dividend tax rate would affect foreign groups receiving dividends from Russian subsidiaries. As a reminder, the double taxation treaty between Russia and Germany will also be suspended from 1 January 2027 (see our overview and Telegram post).
We recommend taking the proposed changes into account when planning the timing of profit distributions. The parameters may change as the bills are considered; we will monitor developments.
4.1.2. Official: new rules on tax penalties
From 1 September 2026, amendments to Articles 112 and 114 of the Russian Tax Code introduced by Federal Law No. 425-FZ of 28 November 2025 apply: where mitigating circumstances exist, a penalty is reduced by a factor of at least two but no more than ten; previously, there was no upper limit on the reduction (the amendments were introduced by Article 1 of Federal Law No. 425-FZ; see the current version of Article 114 of the Tax Code).
As a reminder, Bill No. 1215257-8 on easing liability for late submission of returns, which we previously reported, has been enacted as Federal Law No. 201-FZ of 26 June 2026:
- The penalty under Article 119(1) of the Tax Code does not apply if a late tax return or calculation shows no tax payable;
- Individuals are not fined for failing to submit a 3-NDFL return upon the sale or gift of real estate;
- Taxpayers may submit evidence of mitigating circumstances together with the late return.
4.1.3. Consideration of tax audit materials by videoconference
From 1 September 2026, Federal Law No. 425-FZ (Article 1; see the current versions of Article 101 and Article 101.4 of the Tax Code) amended Article 101(2) and Article 101.4(7) of the Tax Code to permit participation by videoconference in the consideration of tax audit materials and reports on tax offenses identified outside an audit.
The procedure for such participation was approved by Federal Tax Service Order No. ED-1-2/567@ of 11 August 2026, published on 31 August 2026 and entering into force one month after publication:
- Participants connect from the tax office at the organization’s location or the individual’s place of residence, provided the tax authorities have the technical capability;
- A request to participate by videoconference must be sent to the tax authority considering the materials;
- The tax authority must notify the applicant of the possibility of videoconference participation at least three working days before the hearing;
- In the event of technical failures, consideration is postponed or conducted in person; videoconferencing is not used where the materials contain state secrets.
At the same time, Federal Tax Service Order No. ED-1-2/568@ of 11 August 2026 approved the format and procedure for submitting written objections and supporting documents electronically.
4.1.4. Tax monitoring: new rules for reorganizations
Amendments to the tax monitoring procedure introduced by the same Law No. 425-FZ took effect on 1 September 2026 (Article 1; see the current version of Article 105.26 and the subsequent articles of Section V.2 of the Tax Code):
- Legal successors of reorganized participants may continue tax monitoring without meeting the monetary thresholds if they update the previously submitted documents within one month; the monitoring period is not interrupted by the reorganization;
- The grounds for early termination of monitoring have been expanded, including non-compliance with requirements for information exchange, information systems and internal control systems, and repeated violations of information access procedures.
As a reminder, our previous overview covered the government-approved bill on mandatory tax monitoring for special economic zone residents (see also our Telegram post). The general tax monitoring procedure is described in our overview.
4.1.5. Accounting: amendments to PBU 18/02
Russian Ministry of Finance Order No. 121n of 20 August 2026 amended PBU 18/02 “Accounting for Corporate Income Tax.” The amendments concern accounting for deferred tax assets and liabilities when corporate income tax rates change, and the recognition of income tax relating to transactions included in the period’s comprehensive financial result.
The order entered into force on 29 September 2026. We recommend assessing its impact on the 2026 annual financial statements in advance.
4.2. Corporate law and transactions with unfriendly persons
4.2.1. Temporary management in the event of security violations
Presidential Decree No. 604 of 24 August 2026 “On Measures to Ensure the Security of Critical Infrastructure Facilities of the Russian Federation” empowers the Russian Government, acting on instructions from the President, to introduce temporary management of business entities’ property where critical infrastructure security requirements are violated. The facilities concerned include fuel and energy, industry, communications, transport and logistics, municipal infrastructure and life-support facilities.
Grounds may include, in particular:
- Failure to take security measures, or delays in taking them;
- Ineffective organization of measures to counter unmanned aerial vehicles;
- Delays in restoring a facility’s operation.
Rosimushchestvo is appointed temporary manager unless the Government designates another person. The temporary manager may not dispose of the property. Unlike Decree No. 302, the new mechanism is not limited to assets of persons from unfriendly states.
4.2.2. Bill on creditor protection during reorganization
The Russian Government has submitted Bill No. 1342008-8 to the State Duma to amend Article 60 of the Civil Code. It proposes that a court should reject a creditor’s demand for early performance due to the debtor’s reorganization if the debtor demonstrates that there is no material threat to performance of the obligation.
If adopted, the amendments could facilitate intragroup reorganizations. The bill is under consideration.
As a reminder, the Russian Ministry of Finance previously clarified when corporate procedures in companies involving persons from unfriendly states do not require Government Commission approval (see our overview).
4.3. Migration
As previously reported, a range of migration law changes takes effect in 2026–2027. The principal changes and our recommendations for employers are set out in our full overview and Telegram posts on digital registration, new personal income tax payments and requirements for highly qualified specialists.
4.3.1. Medical examinations: a uniform 30-day deadline
From 1 September 2026, Federal Law No. 162-FZ of 10 June 2026 (Article 1, amending Article 5 and Articles 6, 6.1, 13 and 13.3 of Federal Law No. 115-FZ “On the Legal Status of Foreign Citizens in the Russian Federation”) establishes a uniform deadline for foreign nationals to undergo medical examinations: 30 calendar days from entry into Russia.
It applies to foreign nationals arriving for more than 90 days or for employment, and when obtaining a work permit, work patent or temporary residence permit. Repeat examinations are conducted annually.
Federal Law No. 163-FZ of 10 June 2026 (Article 1, introducing Article 18.11.1 of the Code of Administrative Offenses) introduced administrative liability for violations of the examination procedure: a fine of RUB 25,000–50,000, with possible administrative expulsion.
4.4. Employment relations
The Russian Government approved the working calendar for 2027 by Resolution No. 1187 of 17 September 2026. Days off are moved from 2 January to 5 November, from 3 January to 31 December, and from 20 February to 22 February. There are 247 working days in 2027; standard working time for a 40-hour week is 1,972 hours.
As a reminder, amendments to the Labor Code took effect on 1 September 2026 under Federal Law No. 144-FZ of 25 May 2026:
- The annual overtime limit may be increased from 120 to 240 hours if a collective agreement or sectoral agreement so provides;
- Overtime exceeding 120 hours is paid at no less than double the regular rate;
- The employee threshold for small businesses permitted to enter into fixed-term employment contracts by mutual agreement has been raised from 35 to 70.
4.5. Personal data: new criteria for “adequate” countries
Federal Law No. 265-FZ of 26 July 2026 was published and entered into force on 3 August 2026, changing the procedure for recognizing foreign states as ensuring adequate protection of personal data subjects’ rights. Participation in Council of Europe Convention No. 108 alone is no longer sufficient: a country’s rules must comply with the Convention and ensure personal data confidentiality and security.
Roskomnadzor approves the list of such states; an updated list had not been approved when this overview was prepared.
A country’s status affects cross-border data transfer procedures, including the use of a parent company’s information systems, cloud services and CRM systems.
We will monitor developments.
4.6. Upcoming deadlines
For planning purposes, we summarize adopted and expected changes taking effect in the coming months:
- 1 October 2026: commencement of marking household and sanitary-hygiene products (section 3.4); the procedure for considering tax audit materials by videoconference takes effect (section 4.1.3);
- 19 October 2026: the resolution extending and expanding customs monitoring takes effect (section 3.2);
- 23 October 2026: Bank of Russia Board meeting on the key rate, currently 14%;
- 1 November 2026: SPOT security payments for supplies from Belarus (section 3.1);
- 1 December 2026: collection of the technology levy begins (section 3.4);
- 7 December 2026: expiry of the current Bank of Russia restrictions on non-resident cross-border transfers (section 1.2);
- 1 January 2027: abolition of separate corporate income tax returns for certain separate subdivisions; suspension of the double taxation treaty with Germany; fixed advance personal income tax payments for foreign workers; an increase in the minimum wage to RUB 28,935, subject to enactment; budget-package tax measures, subject to enactment;
- 1 March 2027: new salary requirements for highly qualified specialists, RUB 717,000 per month (see our overview); end of the adaptation period for electronic transport documents (section 3.3);
- 9 March 2027: expiry of the current restrictions on foreign cash withdrawals (section 1.1);
- 1 September 2027: second stage of digital ruble implementation (section 1.5).
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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.
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Digest of Changes in Legislation and Law Enforcement Practice: July – August 2026
Dear colleagues,
We present a fresh overview of the latest changes in legislation and law enforcement practice covering July – August 2026.
1. Payment Situation
1.1. Bank Deposits of Non-Residents from Unfriendly Countries: Special Procedure and Exceptions
Presidential Decree No. 95 of 05.03.2022 establishes a special permitting procedure for fulfilling obligations to foreign creditors from unfriendly countries if the amount of obligations exceeds 10 million rubles per month (or the equivalent in foreign currency). This procedure involves either obtaining permission from the Government Commission, or crediting funds to special accounts of type “C”.
By the Decree of the President of the Russian Federation dated 01.06.2026 No. 377, the list of obligations subject to Decree No. 95 was expanded. From June 1, 2026, a special procedure was also applied to the obligations of banks to return deposits (deposits) and pay interest on them in favor of foreign creditors from unfriendly countries.
On July 14, 2026, the Bank of Russia published official explanations that clarified the application of Decree No. 377 to bank deposits:
- The threshold of 10 million rubles is applied individually to each depositor (and not in the aggregate for the bank). If the obligations to a specific depositor in a calendar month do not exceed 10 million rubles, the special procedure is not applied.
- If the threshold is exceeded, the obligations are fulfilled by crediting funds to the C-type account; the use of such funds is possible only in authorized areas or on the basis of a special permission of the Government Commission.
- The rules apply exclusively to bank deposit contracts and do not affect bank account or correspondent account contracts.
- In case of early or urgent return of the deposit, as well as when paying interest, a special procedure is applied. At the same time, before the maturity of the obligation, the bank is not obliged to change the status of the deposit (convert it into an account of type "C").
- The decree does not apply to foreign citizens who have a residence permit in the Russian Federation, as well as to Russian companies whose members include persons from unfriendly countries.
Decree of the President of the Russian Federation dated 04.08.2026 No. 550 in Decree No. 95 made additional changes that significantly narrow the scope of the special order in relation to bank deposits. According to the new version, the rules of Decree No. 95 do not apply to obligations on bank deposits (deposits):
- deposited by individuals who are foreign creditors from unfriendly countries;
- introduced by branches, permanent missions and other separate or independent structural subdivisions of organizations – foreign creditors, provided that the place of registration of such subdivisions is the Russian Federation.
In addition, Decree No. 550 grants these individuals, as well as branches, representative offices and subdivisions the right to receive funds in rubles that were credited by credit institutions to accounts of type “C” in the period from June 1, 2026 until the date of entry into force of this Decree (ie until August 4, 2026). Decree No. 550 entered into force on the date of its official publication.
Thus, at present, a special procedure under Decree No. 95 is reserved for bank deposits of non-resident legal entities from unfriendly countries (except for their branches and representative offices registered in the Russian Federation), but does not apply to deposits of non-resident individuals and deposits of Russian subdivisions of foreign organizations. Previously blocked in accounts of type “C” ruble funds of these categories of depositors are subject to issuance.
1.2. Reminder from the Federal Customs Service on the Rules for Exporting Cash Currency
The FCS of Russia reminded that from March 2, 2022, there is a temporary ban on the export of cash foreign currency from Russia in the equivalent of more than $ 10,000. At the same time, the ban does not apply to exported cash in Russian rubles (subject to the rules of customs declaration).
In accordance with the Decree of the President of the Russian Federation dated 25.03.2026 No. 193, the procedure for exporting cash to the EAEU countries has been limited since this year. Now, when exporting cash in the amount of more than $10,000, a written declaration will also be required, and if the amount exceeds $100,000, confirmation of the origin of the funds is required. Filing a declaration does not entail payment of fees.
The explanations of the FCS also describe in detail the procedure for declaring and provide a list of airports that allow the export of cash currency in accordance with the current procedure.
2. Supply Situation
2.1. Clarifications from the Federal Tax Service on the Operation of the SPOT System
In the letter, the Federal Tax Service answered frequent questions of the Eurasian Economic Commission and foreign trade participants about the procedure for the functioning of the national system for confirming the expectation of goods (SPOT), launched from June 1, 2026. Key clarifications:
- Technical support: a round-the-clock support service for the applicant’s service and a Federal Customs Service hotline are organized.
- Security payment is not required for certain categories of goods: return packaging, goods for testing and research, for participation in exhibitions, under lease / leasing agreements, as well as for goods sold to individuals through electronic trading platforms (ETP). For them, a Document on the upcoming delivery (DPPP) is issued without payment.
- The QR code has no expiration date, the route is not specified in the DPPP, the vehicle can be replaced before crossing the border without creating a new DPPP.
- When transiting goods through the territory of the Russian Federation to third countries, registration of DOP and QR code is not required.
- The carrier must have a visualized reference to the QR code and present it at the request of the regulatory authorities.
Recall that the adaptation period (without making security advances) for Armenia, Kazakhstan and Kyrgyzstan operated until June 30, 2026, for Belarus continues to operate until October 31, 2026.
See also in the media.
3. Other Changes
3.1. Taxes
3.1.1. Official: Postponement of the Reduction of the VAT Exemption Threshold under the Simplified Tax System
On July 4, 2026, the President of the Russian Federation signed Federal Law No. 228-FZ, which postpones the reduction of the annual revenue threshold for VAT exemption for business on the simplified taxation system (simplified tax system). As we informed earlier, from January 1, 2026, the threshold was reduced to 20 million rubles, and it was planned to gradually reduce it to 15 million in 2027 and to 10 million in 2028. Now the threshold of 20 million rubles will remain until 2029.
Further reduction of the threshold has been postponed: to 15 million rubles from 2030, to 10 million rubles from 2031.
3.1.2. Discussion: Exclusion of Trade from the Simplified Tax System?
The Ministry of Finance of Russia requested the position of business associations on the issue of excluding wholesale and retail trade from the list of activities for which simplified tax system can be applied (see media 1, 2). The reason was the appeals of the regions about “tax migration” – registration of sellers working through marketplaces in subjects with reduced simplified tax system rates without real activity there.
According to expert estimates, falling budget revenues from such schemes can reach 75 billion rubles in 2026. The business opposes the complete exclusion, offering to focus on suppressing fictitious registration.
A final decision has not yet been made.
3.1.3. Expansion of the Scope of Controlled Transactions: New Low-Tax Jurisdictions
From January 1, 2026, the updated provisions of subitem 3 paragraph 1 of Article 105.14 of the Tax Code of the Russian Federation came into force (introduced by Federal Law No. 425-FZ of 28.11.2025). Now the transaction is recognized as controlled (without interdependence of the parties), if the total turnover with the counterparty exceeds 120 million rubles. per year and the counterparty is registered in a jurisdiction with a profit tax rate of 15% or lower.
This significantly expands the perimeter of control: transactions with independent counterparties from the UAE, Kuwait, Qatar and other Middle East countries fall under it.
There is no official list of such jurisdictions, taxpayers will have to determine rates independently, requesting information from counterparties. Errors in qualifying threaten transfer pricing fines.
It is important to take into account that according to open sources (see media 1, 2), the tax service has intensified inspections of the TP, paying attention not only to intra-group, but also to foreign trade transactions with independent persons from 91 jurisdictions included in the offshore list of the Ministry of Finance, as well as with products from the special list of the Ministry of Industry and Trade (oil, metals, fertilizers, jewelry).
Recall that fines for violations have increased significantly since 2024: for failure to provide notice of controlled transactions – up to 100,000 rubles, for failure to provide documentation for TP – up to 1 million rubles. The Federal Customs Service seeks to resolve most issues at the analytical stage before the on-site inspection.
Our previous detailed reviews on transfer pricing are available via links 1, 2.
3.1.5. VAT in Case of Changes in Tax Rates under Long-Term Contracts
04.08.2026 was adopted Federal law of 04.08.2026 No 293-FZ. The key principle of VAT application: when tax rates change, VAT is not automatically transferred to the buyer. If the buyer cannot accept the tax for deduction, and the parties have not changed the price of the contract, the amount of VAT is calculated based on the value of the contract, invoices are not issued.
3.1.6. Tax Monitoring: Will It Become Mandatory for SEZ Residents?
The government commission approved a bill obliging large and medium-sized residents of special economic zones (SEZs) to switch to tax monitoring within 2 years from the date of conclusion of the agreement (see media 1, 2). For refusal may be provided for termination of the agreement.
See our earlier review on tax monitoring.
3.1.7. Updated Register of Double Taxation Treaties
In July, the Russian Ministry of Finance has traditionally updated the register of agreements on the avoidance of double taxation. As we informed earlier, information on suspension/denunciation has been added to the register.
From January 1, 2027, the Agreement between Russia and Germany of May 29, 1996 (and the Protocol thereto) is fully suspended. Germany notified Russia of this on June 26, 2026. This means the elimination of foreign tax credits, the risk of double taxation and the inability to claim reduced rates at source on dividends, interest and royalties. It should be noted that the German Federal Ministry of Finance uses the term “suspension” rather than “denunciation”, which means temporary non-application.
See more details in our review.
It is also worth mentioning that Spain included the Russian Federation in its national list of “non-cooperative tax jurisdictions” – in terms of the presence in the Russian Federation of special tax regimes for companies with registration in certain administrative regions. The decision comes into force on December 28, 2026. This does not lead to the abolition of the double taxation treaties between Spain and the Russian Federation, but means stricter tax controls, increased verification of the origin of funds and greater attention to transactions related to Russian companies by the Spanish tax and banking authorities. Recall that Russia was included in the “black list” of the EU from January 29, 2026.
3.2. Corporate Law and Transactions with Unfriendly Persons
3.2.1. Reverse Buyback of Assets under Options
04.08. In 2026, the Federal Law No. 319-FZ dated 04.08.2026 was officially adopted, introducing grounds for the judicial termination of the right of foreign investors from unfriendly states to repurchase Russian assets sold after 22.02.2022. For judicial refusal, confirmation of simultaneous fulfillment of the following conditions is required:
- Investor behavior: public support of unfriendly actions, discrediting the Russian Armed Forces, financing of terrorism, a statement on the termination of activities in the Russian Federation, etc.
- Financial parameters: the repurchase price deviates from the market by 25% or more, or the acquirer has made a significant investment in the asset.
The claim can be filed by the acquirer (it is not necessary to wait for the exercise of the option) or the profile FOIV (with the permission of the board). The case will be heard by the Moscow Region Arbitration Court. The investor has the right to demand compensation within a year, while the court can reduce it or refuse it completely.
See more details in our review.
3.2.2. Relaxations for Corporate Procedures
On July 10, 2026, the Ministry of Finance published official explanations from 01.07.2026, which specified the cases when the permission of the Government Commission for transactions with unfriendly persons is not required (under Decree No. 618):
- Amendments to the charter of an LLC related to the formation, definition of competence or termination of powers of management bodies (for example, the creation of a Board of Directors).
- Repayment of the treasury share (change in the size of the participant’s share as a result of repayment of the share owned by the LLC itself, and a decrease in the authorized capital).
See more details in our review.
3.2.3. Review of the Supreme Court of the Russian Federation No. 8/2026: Transactions with Unfriendly Counterparties
On June 22, 2026, the Thematic Review of the Supreme Court of the Russian Federation No. 8/2026 was published, which significantly changes the approach to risk assessment.
Among the key conclusions of the review, the following should be noted:
- Splitting payments (for tranches up to 10 million rubles to circumvent Decree No. 95) is recognized as an abuse of the right (Article 10, 168 of the Civil Code of the Russian Federation) and entails nullity. In the text of the review, the splitting of payments is mentioned in the context of settlements under credit agreements. However, we cannot exclude the risk that the position will be extended to royalties, dividends or other settlements.
- Real estate transactions involving a person under the control of an unfriendly person (participation of more than 50%) are void without the permission of the Executive Committee, even if carried out between the Russian seller and the buyer.
- Assignment of the right of claim (cession) to a friendly person, made in order to bypass accounts of type "C" or "O" is void.
- Settlement agreements that provide for the payment of money not directly to an unfriendly person, but to his representative in circumvention of the permitting procedure, cannot be approved by the court and are void.
- Limitation of liability of banks: the bank is not liable for losses of the client if the transfer was blocked by the intermediary bank in an unfriendly country due to sanctions imposed later, provided that the sender bank is in good faith.
See more details in our review. We also recommend reviewing the full text of the document.
3.2.4. Draft Law on Limiting Subsidiary Liability
The State Duma introduced a bill aimed at a more balanced regulation of the use of subsidiary liability of managers / controlling persons.
Among other things, it is proposed to:
- Apply liability only for intentional actions clearly aimed at causing harm to creditors (management errors and business risk are excluded).
- The possibility of writing off subsidiary liability under a number of conditions (completion of the repeated bankruptcy procedure of a citizen, expiration of 10 years from the date of adoption of the judicial act, good faith behavior).
The bill is under consideration.
In this context, we also recall that in November 2025, the Supreme Court approved a review of the prosecution of controlling persons for the debts of abandoned companies (excluded from the USRLE).
Key findings:
- Controlling persons may be brought to subsidiary liability in case of exclusion of the company from the USRLE, if as a result of their behavior, settlements with creditors of the specified company became impossible;
- The creditor is not obliged to prove the bad faith of the controlling persons, the burden of proof lies on them;
- A lawsuit can be filed even without trying to prevent the company from being excluded from the USRUL;
- The limitation period begins from the moment when the creditor became aware of the exclusion of the company and the controlling person;
- The mere fact of having the status of a sole participant or director does not constitute a basis for liability; it is necessary to prove the real influence and causality.
3.3. Regulation of Cryptocurrencies
11.08.2026 was published almost 300-page Federal law “On digital currencies and digital rights” No. 282-FZ (signed 04.08.2026), establishing the rules for the circulation of cryptocurrencies in Russia. The main provisions come into force from September 1, 2026, the transition period will last until July 1, 2027.
The law introduces 5 categories of regulated organizations (exchanges, brokers, management companies, depositories, exchangers). After July 1, 2027, transactions with cryptocurrency will be possible only through regulated organizations, banks are obliged to refuse other operations. Payment for goods and services with cryptocurrency within the country is prohibited, but it is allowed to use for operations within the framework of foreign trade.
In parallel, laws on the taxation of cryptocurrencies and on liability for illegal transactions are being developed.
See our article on cryptocurrencies in Russian Business Guide magazine here.
3.4. Migration Sphere
A detailed description of the changes is available in our full review.
Below is a brief summary of the main changes:
3.4.1. Digitalization of Registration
- Since June 30, 2026, the Digital Profile of a Foreign Citizen (Decree No. 735) has been formed. It is a single electronic database of documents, employment, education, insurance, offenses and restrictions on entry.
- From July 1, 2026, as part of the experiment (until December 31, 2027), a mobile application “Public Services RuID” was launched to submit an application for entry to the Russian Federation for citizens of visa-free countries (recommended 72 hours before entry). The QR code is valid for 90 days.
- From 01.09.2025 as part of the experiment in Moscow and the Moscow region, the application "Amina" – the official state application for remote migration registration – was put into operation (see also the application information page). With its help, the foreigner submits a notification of the place of stay, and the application automatically transmits to the Ministry of Internal Affairs data on the geolocation of the smartphone. Mandatory registration in the application "Amina" is subject to foreigners from visa-free countries who came to Russia to work.
The experiment started on September 1, 2025 in Moscow and the Moscow region and will last until September 2029 (based on Federal Law No. 121-FZ).
At the same time, from 01.09.2026, Amina will also become mandatory for visa-free foreigners who are in the capital region for more than 90 days for non-working purposes (study, guest visit, long trip to relatives).
- From October 1, 2026 (data transfer) and from January 1, 2027 (full work), an automatic exchange of information between the Federal Tax Service, the Ministry of Internal Affairs and the SFR is introduced.
3.4.2. New Rules on the Subsistence Minimum and Taxes
From 01.01.2027, Federal Law No. 241-FZ and Federal Law No. 242-FZ of 26.07.2026 come into force, which
- Obliges migrant workers to support themselves and their dependents at a level not lower than the regional subsistence minimum. Lack of confirmed income is the basis for revocation of a patent, TRP or residence permit.
- introduces the obligation to pay a new fixed advance payment on personal income tax when working for individuals: 1700 rubles / month, 1200 rubles / month. – under a patent from legal entities, with an increasing coefficient of 50% for each dependent.
3.4.3. Significant Increase in Requirements for Highly Qualified Specialists
26.07. In 2026, Federal Law No. 241-FZ was officially adopted, which increases the basic income requirement for foreign highly qualified specialists by almost 3 times.
The basic minimum wage threshold for maintaining the status of the HQS is increased from 750,000 rubles / quarter (250,000 rubles / month) to 717,000 rubles / month. The new requirements come into force from 01.03. 2027. The reduced threshold (358 500 rubles / month) can be applied for narrow categories (scientific workers, teachers, SEZ residents, accredited IT companies, Skolkovo participants and innovation centers).
In addition, a requirement for annual indexation of the amount of remuneration of the HQS is introduced.
3.4.4. Other Changes
It is important to take into account that from September 1, 2026, new forms of notifications come into force (Order of the Ministry of Internal Affairs of Russia from 12.05.2026 No. 290). At the same time, the notifications will now require a separate consent to the processing of personal data. State duties for legally significant actions in the migration sphere are also significantly increased.
We recommend employers to analyze the situation with HQS, assess the possibility of raising wages to new thresholds and consider alternative options for registration (quota, TRP, residence permit, list of professions).
We have prepared a consolidated overview of the main migration changes and recommendations; the text is available here.
3.5. Identification of Domain Administrators through ESIA
Federal Law No. 569-FZ of December 29, 2025 from September 1, 2026 introduces mandatory identification of domain name administrators in the Russian national domain zones .ru, .rf and .su through the Unified Identification and Authentication System (ESIA) – the portal "Gosuslugi". The requirement applies to all administrators, including foreign nationals and companies. For individuals, a confirmed account on the Gosuslugi is required; for legal entities, registration of the company in the ESIA and the connection of an authorized employee are required.
Without passing the identification, the administrator loses the ability to extend the domain, make changes to the settings or transfer rights. At the same time, the domain will continue to work until the end of the registration period, but after its expiration, it will go to the waiting status, and then it will be released.
We recommend an inventory of all domains in the .ru, .rf and .su zones, check the administrator’s data and, if necessary, urgently update them or change the registrar (if the current one is not integrated with the ESIA).
See also more details in our review.
3.6. Tax Secrecy on Gosuslugi
Since August 1, 2026, the tax secrecy regime has been extended to documents and information from the personal account of the taxpayer on the Gosuslugi portal. Also abolished the obligation of the Federal Tax Service to massively send paper tax notices: now they are sent in electronic form through public services (by default), paper remain only for those who are not registered on the portal.
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Online seminar 13.12.2024: Doing Business in Russia – Practical Experience in New Circumstances
PROGRAM
Detailed reviews and Q&A session with experienced experts on the following topics
1. Doing business in Russia
Legal, tax, HR and migration issues. Basics.
2. Overview on bank transaction with Russia
SWIFT, currency exchange and other.
3. Practical experience of foreign companies in Russia
FAQ in the regular business processes.
Changes in payments to highly qualified specialists (HQS) from 01.03.2024
On 10.07.2023, the Federal Law No. 316-FZ “On Amendments to the Federal Law “On the Legal Status of Foreign Citizens in the Russian Federation” (hereinafter referred to as Federal Law No. 316-FZ), about which we informed earlier, was signed and published.
We remind you that, starting from 01.03.2024, the provision of the specified Federal Law No. 316-FZ comes into force, which changes the wage (remuneration) rate for highly qualified specialists (hereinafter referred to as HQS).
In particular, starting from 01.03.2024, the wages (remuneration) of an HQS must be at least 750 000 RUB per quarter. Previously, the minimum wage (remuneration) for an HQS in general was 167 000 RUB per month.
Taking into account the above, in the first quarter of 2024, the total wages (remuneration) of an HQS must be in conformity with the amount specified in the legislation, that is, at least 750 000 RUB per quarter.
Please note that the above position corresponds to the position of the Directorate of External Labour Migration of the Main Directorate for Migration Issues of the Ministry of Internal Affairs of the Russian Federation stated by the department when contacted in writing.
In case of violation of the established amount of payments, the company shall be deprived of the right to attract foreign citizens to work in the Russian Federation as HQS for two years (subclause 1 of clause 26 and clause 26.1 of the art. 13.2 of the Federal Law No. 115-FZ dated 25.07.2002 “On the Legal Status of Foreign Citizens in the Russian Federation”, hereinafter referred to as Federal Law No. 115-FZ).
We remind you that in accordance with the clause 13 of the article 13.2 of the Federal Law No. 115-FZ, employers and customers of work (services) are obliged to notify the federal executive body in the field of internal affairs or its authorized territorial body for the fulfilment of obligations to pay wages (remuneration) to the HQS on a quarterly basis, no later than the last working day of the month following the reporting quarter.
Failure to notify or violation of the established procedure and (or) form of notification by the employer or customer of work (services) involving highly qualified specialists entails administrative liability established by the part 5 of the article 18.15 of the Code of Administrative Offenses of the Russian Federation, namely:
- imposition of an administrative fine on officials in the amount of 35 000 – 70 000 RUB; for legal entities – from 400 000 to 1 million RUB.
We will be happy to answer your questions!
Contacts:
Maria Matrossowa
Yulia Belokon
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New in migration legislation: changes for highly qualified specialists
On July 10, 2023, Federal Law No. 316-FZ was adopted, introducing a number of significant changes regarding the legal status of foreign citizens in the Russian Federation (hereinafter referred to as “Law No. 316-FZ”).
This law entered into force on July 10, 2023, but provides for separate, later deadlines for the entry into force of a number of provisions (more details below).
According to the new rules, family members of highly qualified specialists (hereinafter referred to as “HQS”) will be required to undergo a medical examination again within 30 calendar days from the date of the decision to extend the validity of the HQS work permit or from the date of entry into the Russian Federation (if they were outside the Russian Federation on the day of such a decision). Previously, family members of HQS were required to undergo a medical examination annually.
In addition, after 180 days from the official publication of Law No. 316-FZ, the following changes will come into force:
The obligation to obtain a work permit within 30 calendar days from the date of the decision to issue (extend) it is introduced.
In the presence of documented valid reasons and a written application from the employer, a work permit may be obtained at a later date, but not exceeding 30 calendar days. After the expiration of the established period, a work permit is not issued, and the decision to issue (extend) it is canceled.
In the event of early termination of an employment or civil law contract, the HQS, as before, has the right to search for another employer or customer of work within 30 working days.
If a new contract has not been concluded upon expiration of this period, the HQS and his family members will be required to leave the Russian Federation within 30 calendar days, and their visas and residence permits (if any) will be considered cancelled.
Before the said changes come into force, HQS and their family members will be given 30 working days to leave.
A HQS who has worked in this capacity in the Russian Federation for at least two years and his family members who have a residence permit will be issued an indefinite residence permit if the following conditions are met:
The HQS and family members reside in the Russian Federation with a residence permit;
during the period of the HQS’s employment, the employer calculated, withheld and transferred taxes to the budget system of the Russian Federation.
It is envisaged to issue a work permit for highly qualified specialists to carry out labor activities in two or more constituent entities of the Russian Federation if the following conditions are met:
work in other constituent entities is provided for by the provisions of an employment or civil law contract for the performance of work (provision of services);
a foreign citizen carries out labor activities in separate divisions of an organization, branches or representative offices of a legal entity or with related parties located in these constituent entities.
A ban on the employer to attract foreign highly qualified specialists to labor activities in the Russian Federation for two years in the event of failure to provide the tax authorities with information on the amounts of personal income tax calculated and withheld by the tax agent in relation to highly qualified specialists after 6 months, as well as if the information provided turned out to be fake or counterfeit.
In addition, from 01.03.2024, the level of wages (remuneration) of highly qualified specialists will increase to 750 thousand rubles per quarter. Before the changes were introduced, the threshold was 2 million rubles/year.
At the same time, Law No. 316-FZ does not cancel the previous reduced wages required to attract highly qualified specialists who are medical, teaching staff, participants in the implementation of the Skolkovo project, and employees of resident companies of special economic zones.
We are closely monitoring the development of the situation and innovations in legislation and will be happy to answer any questions you may have!
Your contacts on this topic:
Maria Matrosova
Yulia Belokon
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Dactyloscopy, photography and mandatory medical examinations for foreign citizens
We would like to remind you that starting fr om December 29, 2021 (with the Federal Law № 274-FZ fr om 01.07.2021 coming into force) the new migration legal requirements, which require foreign citizens to undergo dactylography and photographing as well as a mandatory medical examination. This requirement concerns:
• those arriving in Russia for the purpose of carrying out labor activities and
• foreign citizens arriving to the Russian Federation for other purposes for a period exceeding 90 calendar days.
For your convenience, we have compiled for you the addresses of clinics/stations in Moscow wh ere you can apply to get the necessary procedures.
Dactyloscopy and photography
Duration of procedures:
Within 30 calendar days from the date of entry into the Russian Federation or when applying for a patent or a work permit.
Where you can get it done:
1. At the Multifunctional Migration Center in Sakharovo on the day of the receipt of the work permit.
Address: Moscow, Troitskiy AO, Voronovskoe settlement, Varshavskoe highway, 64th km, bld. 1/47.
Opening hours: from Monday to Sunday from 08.00 to 20.00.
!! Here you can also undergo necessary medical examinations.
2. In the State Budgetary Institution “Migration Center” only for foreign citizens who came to Russia to perform labor activities.
Opening hours: from Monday to Friday from 09.00 to 18.00
!! Here you can also submit documents about the medical examination.
What documents are required:
To undergo dactyloscopy and photography, a foreign citizen must present the following documents:
• passport and a notarized translation of the passport;
• certificate of absence of disease caused by human immunodeficiency virus (HIV infection);
• documents confirming medical examination.
Period of validity:
Dactyloscopic registration and photographing are taken once; the documents are valid indefinitely. In case of loss of documents confirming the passing of fingerprinting and photographing, duplicates of these documents can be obtained.
Medical examinations
Time requirements for medical examinations:
• for foreign citizens arriving in Russia for labor purposes – within 30 calendar days from the date of entry into the Russian Federation. At the same time the foreign citizen is obliged to present these documents to migration authorities within thirty days from the date of entry;
• for other foreign citizens – within 90 calendar days from the date of entry into the Russian Federation.
What documents are required:
• passport and notarized translation of the passport;
• migration card;
• registration at the place of residence.
Where you can get it done (in Moscow):
1. CENTRAL DEPARTMENT FOR SPECIALIZED MEDICAL CARE
Address: Leninsky Prospekt, 17, room 56.
Phone: 8 499 558-58-28, 8 495-952-34-22.
Opening hours: from 09.30 to 13.00 on working days according to the order of the person in the line.
Range of necessary medical examinations: except fluorography.
2. Kutuzovsky clinic
Address: 41 Kutuzovsky Prospekt.
Phone: 8 499-249-25-55, 8 499 558 58 28.
Opening hours: working days from 09.00 to 15.00.
Range of necessary medical examinations: except fluorography.
3. Clinic named after V.G. Korolenko
Address: 3, Kosinskaya str.
Phone: 8 495-770 -09-83.
Opening hours: working days from 09.00 to 15.00.
Range of necessary medical examinations: There is no information about the possibility of fluorography.
4. Proletarsky clinic
Address: 22 Melnikova St.
Phone: 8 495-674-36-24, 8-499-558-58-28.
Opening hours: working days from 09.00 to 15.00.
Range of necessary medical examinations: except for phthisiatrician.
5. Ostankinsky clinic
Address: 103, Prospekt Mira St.
Phone: 8-495-682-30-91, 8-495-682-30-80.
Opening hours: working days from 09.00 to 15.00.
Range of necessary medical examinations: There is no information about the possibility of fluorography.
6. Sakharovo Multifunctional Migration Center – Branch “Multifunctional Medical Center of Labor Migration”
Address: Moscow, Troitskiy AO, Voronovskoe settlement, Varshavskoe highway, 64th km, bld. 1/47.
Opening hours: from Monday to Sunday from 08.00 to 20.00.
Full range of necessary medical examinations, including fluorography: yes.
7. State Budgetary Institution “Moscow City Scientific and Practical Center for Fighting Tuberculosis of the Department of Health of the City of Moscow”.
Address: 18, Dokukin St.
Phone: 8-499-187-78-72, 8-499-187-90-77.
Opening hours: 8.00-20.00, Saturday from 9.00-16.00.
Full range of necessary medical examinations, including fluorography: Yes.
Please note that the approximate time to take the tests takes 3 hours. Term of preparation of the medical report after examination and tests takes up to 7 working days.
Wh ere to submit the results of the medical examinatio
The results of the medical examination must be submitted in person to the migration authorities, considering the deadlines established by law.
You can submit the results of the medical examination:
1. At the Multifunctional Migration Center in Sakharovo on the day of the receipt of the work permit.
Address: Moscow, Troitskiy AO, Voronovskoe settlement, Varshavskoe highway, 64th km, bld. 1/47.
Opening hours: from Monday to Sunday from 08.00 to 20.00.
2. In the State Budgetary Institution “Migration Center” only for foreign citizens who came to Russia to perform labor activities.
Opening hours: from Monday to Friday from 09.00 to 18.00
!! Here you can also undergo dactyloscopy and photography.
First-hand comment from our foreign colleague.
I came to Russia at the beginning of January and, therefore, had to undergo a medical examination and fingerprinting.
I had a medical check-up in the medical center at 18 Dokukin St., because you can take all the analyses there and there is no need to go to other institutions. The line (without an appointment, the principle of a live line) was already quite long at 10 o’clock in the morning, so it is advisable to come early. The staff is friendly and helpful, but if you do not speak Russian, it is worth bringing an interpreter.
I ended up spending 4 hours in the clinic, including 3 hours in line, the tests themselves were done within an hour.
I received the results in 7 working days in the same building.
For fingerprinting I decided to go to the migration center in Sakharovo. I arrived by public transportation at 8 am and was directed to Gate 1 (for work permit holders). It took me 1.5 hours to get a voucher, then another 2 hours before I could get fingerprinted and photographed. It takes 4-6 business days to get confirmation that all the documents have been submitted.
Including the drive there and back, the whole procedure took me 10 hours. The staff is friendly and diligent, but the process on site is very unclear.
Summary of the procedure
Let’s summarize the order and steps of the above procedures:
1. Have your tests done at one (or several, in case one of the specialists/examination options is not available at the chosen center) of the medical centers listed above.
2. Receive test results from the appropriate medical center after 7 business days.
3. Get fingerprinted and photographed.
4. After all the procedures you will get a fingerprint card with. The information will be sent for registration to the information center of the Main Directorate of the Ministry of Internal Affairs in Moscow.
Please note that the information in the overview is relevant as of the date of this posting. The procedure is being clarified, and information may change. We recommend you to clarify the information before you visit a clinic or an authority.
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Changes in Migration Legislation
We would like to pay your attention to the fact that the changes specified in the Federal Law No. 274-FZ of July 01, 2021 “On the introduction of amendments to the Federal Law “On the legal status of foreign citizens in the Russian Federation” and the Federal law “On state fingerprint registration in the Russian Federation” shall become effective from December 29, 2021.
According to the Federal Law No. 274-FZ of July 01, 2021 foreign citizens who have arrived in the Russian Federation for working purposes (including highly qualified specialists) shall be subject to mandatory medical examination for substance abuse, infectious diseases that constitute a danger to the public, as well as HIV infection, to state fingerprint registration and photography within 30 calendar days from the date of arrival in the Russian Federation or from the date of receipt of work permission documents.
Besides, foreign citizens who have arrived in the Russian Federation for purposes other than work for a period exceeding 90 calendar days shall be subject to the abovementioned mandatory medical examination, mandatory state fingerprint registration and photography within 90 calendar days from the date of arrival in the Russian Federation.
State fingerprint registration and photography of foreign citizens will need to be completed once.
The medical examination must be repeated multiple times depending on period of validity of medical certificates. It is necessary to mention that in accordance with the clause 20 of the Ministry of Healthcare of the Russian Federation Order No. 1079нof November 19, 2021 that enters into force from March 01, 2022, medical certificates issued to foreign citizens will be in force within 3 months from their issuance. The Law specifies the procedure for repeated medical examination and submission deadline of its results to the territorial authority of the Ministry of Internal Affairs of the Russian Federation within 30 calendar days from the date of expiry of medical certificates. The results of the medical examination are to be submitted by a foreign employee in person or through the Russian unified portal of state and municipal services (Gosuslugi).
If a foreign citizen fails to comply with the above-mentioned mandatory procedures, the period of his residence is reduced and he will be obliged to leave the territory of the Russian Federation.
Contacts:
Maria Matrossowa
Project leader swilar OOO Project Manager of SWILAR LLC
maria.matrossowa@swilar.ru + 7 499 978 37 87 (ext. 308)Tatiana Ushakova
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Recent changes in the list of restrictions for employers of Moscow
Decree № 5-UM of the Mayor of Moscow suspends from January 27, 2021 the obligation of Moscow employers to transfer at least 30% of employees to remote work.
Decree № 5-UM of the Mayor of Moscow dd. January 27, 2021 (hereinafter – the Decree) suspends from January 27, 2021 the obligation of Moscow employers to transfer at least 30% of employees to remote work. Nevertheless, employers are advised to keep in force the measures taken on transferring employees to remote working mode.
Please note that the requirement for Moscow employers to transfer all employees over the age of 65 to remote work, as well as citizens with diseases, the list of which is determined by the Department of Health of Moscow, except for citizens whose presence in the workplace is critical, remains in force.
Also, the requirement to submit data on changes in the number of employees transferred to remote mode in electronic form using a personal account on the official website of the Mayor and Government of Moscow in accordance with clause 2.4.3. of the Decree remains in force.
Contacts:
Maria Matrossowa
Tatiana Ushakova
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Changes in the algorithm for payment of benefits for temporary disability, maternity and childhood
The Ministry of Labor and Social Protection of the Russian Federation has prepared a draft of amendments to Federal Law № 125-FZ dd. 24.07.1998 and Federal Law № 255-FZ dd. 29.12.2006, which will come into force from January 1, 2021 in terms of payment of benefits for temporary disability, maternity and childhood.
“Direct payments” is a project implemented by the Social Insurance Fund of the Russian Federation since 2011. During this time, 77 regions of the Russian Federation have already joined it. The remaining 8 largest regions (Moscow, St. Petersburg, Krasnodar and Perm, Moscow, Sverdlovsk and Chelyabinsk regions, the Khanty-Mansi Autonomous District) will move to direct payments from January 1, 2021.
Thus, the system of “direct payments” will be effective throughout the Russian Federation from January 2021.
The point of the amendments is that from 1 January 2021 all benefits (with few exceptions) will be paid directly to employees by the Social Insurance Fund (FSS).
Besides, employers will transfer insurance payments to FSS (including contributions for accidents at work and occupational diseases) in full, i.e. without reducing the amount of benefits paid to employees.
Direct payments of employee benefits from the Social Insurance Fund, which are considered in the draft, include:
- temporary disability allowance (including in the case of an accident at work and (or) occupational disease);
- maternity allowance;
- one-time allowance for women who have registered at medical institutions in the early stages of pregnancy;
- one-time allowances upon the birth of a child;
- monthly child care allowance;
- payment of leave (in excess of the annual paid leave) to an insured person who was injured at work.
Temporary disability benefits for the first 3 days of an employee’s illness will be assigned and paid, as before, only by the employer.
With subsequent reimbursement from the Social Insurance Fund, the employer will assign, and pay to working citizens the following types of benefits (the mechanism remains the same):
- payment of 4 additional days off to care for children with disabilities;
- funeral allowance;
- payment of temporary disability benefits from inter-budgetary transfers (to persons exposed to radiation).
The mechanism of direct payments is as follows:
1. The employee must submit to the employer:
-
a certificate of the amount of earnings (if he/she worked for other (other) employers during the calculation period);
-
confirming documents (certificate of disability for work, certificate of registration at a medical institution in the early stages of pregnancy, certificate of birth of a child, etc.);
-
application, wh ere details for the transfer of the allowance are specified.
Please be awared, that allowance will be paid by FSS only to the card of payment system MIR.
Important! The term for submission of the sick leave and other documents confirming the occurrence of an insured event is 6 months after the sick leave is closed.
2.The employer within 5 calendar days sends a package of documents to the FSS.
3. The FSS within 10 calendar days checks the documents provided by the employer and makes a decision on the assignment or refusal to pay the allowance.
4. If the decision is positive, the allowance is transferred to the employee’s current account or sent by mail.
5. If the documents are insufficient or incorrect, the FSS sends a notification to the employer. Within 5 calendar days the insured is obliged to replace them, or provide the missing documents.
The way of sending data to the FSS depends on the average number of employees:
- 25 people and more – the documents, including the register of information, are sent to the FSS digitaly;
- 24 people and less – the documents, including the inventory, can be sent to the FSS both digitaly and on paper.
The amount and methodology of benefit calculation remain the same.
Monthly child care allowance awarded in 2019-2020 and continuing into 2021 are paid as follows:
-
The employer pays the December 2020 allowance to the employee in the regular order;
-
To process an allowance payment from 2021 directly from the FSS:
· the employee must submit to the employer an application for the allowance directly from the regional branch of the FSS in the standard form and the necessary documents;
· the employer within 5 calendar days is obliged to transfer the data (inventory, application and documents from the employee or register) to the FSS.
The monthly child care allowance will be transferred from the 1st to the 15th of the month following the month for which the allowance is paid. The allowance for care of the child till 1,5 years at transition to direct payments from FSS, is not subject to recalculation, the sum of the allowance appointed till 01.01.2021, does not change.
We will be happy to answer your questions!
Contacts:
Natalia Safiulina
Ekaterina Babenko
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