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September changes to migration rules: are you aware of all of them?
01.09.2025
Our migration experts have put together a brief summary of the most important changes relating to foreign employees.
The changes are designed to improve migration service processes and reduce the burden on local internal affairs offices with regard to migration registration while enhancing mechanisms for monitoring the actual place of stay of foreign nationals using modern technologies. September will see the end of the migration amnesty which allows foreign nationals who arrived in Russia illegally and citizens of Ukraine to regularize their legal status without the need to leave Russia. There are also changes for foreign citizens working on the basis of a work license in the Moscow region, St Petersburg and the Leningrad Oblast. Migrations forms have been updated in line with changes in the law. Furthermore, state fees have been introduced for migration services that used to be free. All the above is covered in the sections below.
AN EXPERIMENT TO INTRODUCE A NEW MIGRATION REGISTRATION MECHANISM WILL COMMENCE IN MOSCOW AND THE MOSCOW OBLAST FROM 1 SEPTEMBER 2025 [1]
Initially, participants in the experiment will be citizens of Uzbekistan, Tajikistan, Kirgizia, Armenia, Kazakhstan, Georgia, Azerbaijan, Moldova and Ukraine who came to Russia to work and are based in Moscow or the Moscow Oblast.
For migration registration purposes, those foreign nationals must install a dedicated app called ‘Amina’ on their mobile phones. The app uses a geolocation function that enables internal affairs bodies to be kept remotely informed of the place that a foreign national regularly uses to sleep and spend their spare time as well as their working hours.
The app can be downloaded here.
The timeframe for migration registration under the new procedure is as follows:
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Foreign citizens who entered Russia on or after 1 September 2025 and are participating in the experiment must set up an account in the app and register when having their fingerprints and photograph taken at a migration center
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Foreign citizens who are in Russia legally, are participating in the experiment and have not undergone migration registration as of 1 September 2025 must register by 30 November 2025
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Foreigners and stateless persons who have undergone migration registration at a place of stay in Moscow or the Moscow Oblast as of 1 September 2025 must register in the system within 30 days of that migration registration
The absence of geolocation data from a foreign national’s device for more than 3 working days may result in the individual concerned being entered in the register of controlled persons.
Host parties (apartment owners) are not required to submit notifications of migration registration in relation to participants in the experiment.
It should be noted that the children of foreign citizens are not currently regarded as participants in the experiment, i.e., they must be registered in accordance with the normal procedure.
The registration rules for other categories of foreign nationals (such as foreign employees from non-visa-free countries who work on the basis of a standard work permit, highly qualified specialists and members of their families, and foreign nationals who arrived in Russia on the basis of a business visa or an ‘installation work’ visa) have not changed.
You can find more information about the experiment on the website of the Moscow Multifunctional Migration Center at the following link.
FROM 1 SEPTEMBER 2025 A FOREIGNER WILL BE ABLE TO WORK IN TWO REGIONS UNDER ONE WORK LICENSE ONCE THE REGIONS HAVE ENTERED INTO A SPECIAL AGREEMENT [2]
The change will affect Moscow / the Moscow Oblast and St Petersburg / the Leningrad Oblast. According to our information, relevant Agreements have not yet been signed between the regions.
Once the Agreements have been signed, employers will be obliged to notify the local migration bodies of each region of the conclusion of a contract with such a foreigner.
THE MIGRATION AMNESTY ENDS ON 10 SEPTEMBER [3]
Under the amnesty, in some cases foreign nationals who are in Russia illegally may apply to the migration offices of local internal affairs bodies to regularize their legal status.
Foreign nationals who have not legalized their status are obliged to leave Russia of their own accord. After 10 September 2025 such foreign nationals may face expulsion from Russia.
UKRAINIAN CITIZENS MUST OBTAIN A WORK LICENSE / OTHER DOCUMENT OR LEAVE RUSSIA BY 10 SEPTEMBER 2025 [4]
Ukrainian citizens with non-regularized status must apply to local internal affairs bodies to regularize it (i.e., obtain a work license, a temporary residence permit or a permanent residence permit or assume Russian citizenship). Citizens with non-regularized status must leave Russia by 10 September 2025, and employers will not be able to continue employing such citizens.
NEW STATE FEES ARE EFFECTIVE FROM 1 SEPTEMBER 2025 [5]
New state fees are to be charged for migration services that were previously provided free of charge:
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Initial migration registration at a place of temporary stay and extension thereof (with the exception of foreigners staying in Russia on a visa-free basis who are participating in the experiment to introduce a new migration registration mechanism)
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Extension of a work permit
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Issuance or re-registration of a work license
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Issuance of a duplicate work permit / license
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Amendment of a work permit / work license
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Issuance of duplicate permits to engage and use foreign workers
In addition, foreign nationals with a temporary residence permit or a permanent residence permit will see an increase in fees payable for the extension of registration at their place of residence.
More details about these changes can be found in our alert at the following link.
CHANGES TO MIGRATION FORMS IN SEPTEMBER 2025 [6]
From 1 September 2025 an updated form of the notification of the conclusion of an employment contract and/or a civil contract with foreign citizens comes into effect. Employers that violate the notification procedure by submitting an obsolete notification form will face a fine of up to 1 million rubles (for each notification). These changes are connected to the new rules for the issuance of a work license.
From 6 September 2025 an updated form of an employer’s application to engage a highly qualified specialist comes into effect. Changes include the entry of new information about the employer and the terms of the foreigner’s employment. An employer will have its application to employ a highly qualified specialist rejected if it uses the old application form.
In view of the large number of changes to migration rules, we recommend checking that you are using the latest versions of migration forms before submitting them or delegating the function of ensuring compliance with migration rules to qualified specialists.
Should you have any questions about compliance with migration law, please contact our migration team.
AUTHORS
Ekaterina Ukhova
B1 Partner
People Advisory Services (PAS) Leader. 25+ years of consulting experience focusing on complex employer and employee issues
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Maria Tkacheva
B1 Senior Manager
People Advisory Services, Tax, Law and Business Support
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Maria Moskaleva
B1 Assistant Manager
People Advisory Services, Tax, Law and Business Support
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Show references
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[1] Federal Law No. 121-FZ of 23.05.2025 “Concerning the Introduction of Amendments to Certain Legislative Acts of the Russian Federation and the Conduct of an Experiment to Introduce Additional Mechanisms for the Registration of Foreign Citizens"
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[2] Article 13.3-1 “Special Considerations Relating to the Conduct of Work Activities by Citizens Who Arrived in Russia Under a Procedure not Requiring the Receipt of a Visa on the Basis of a Work License in Certain Constituent Entities of Russia” of Federal Law No. 115-FZ of 25.07.2002, Federal Law No. 121-FZ of 23.05.2025.
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[3] Edict No. 1126 of the President of Russia of 30.12.2024 “Concerning Temporary Measures to Regularize the Legal Status of Certain Categories of Foreign Citizens and Stateless Persons in the Russian Federation in Connection with the Application of the Expulsion Regime”
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[4] Edict No. 159 of the President of Russia of 20.03.2025 "Concerning Special Considerations Relating to the Legal Status of Certain Categories of Foreign Citizens and Stateless Persons in the Russian Federation and the Amendment and Annulment of Certain Edicts of the President of the Russian Federation"
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[5] Article 333.28 of the Tax Code as worded from 01.09.2025, Federal Law No. 271-FZ of 31.07.2025
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