IMPACT – MEDIUM

What is the change? The Ministry of Internal Affairs will soon change the requirements for Association of European Businesses members applying for work permits or letters of invitation at the ministry’s central migration office in Moscow.

What does the change mean? Beginning Saturday, AEB members applying for highly qualified specialist work permits or letters of invitation based on their AEB membership must be on an official AEB list. Documents filed at the central migration office that are based on AEB membership will only be accepted from companies registered in Moscow or the Moscow region. Companies registered in other parts of Russia will be required to submit documents to the relevant regional migration office. Companies registered in Moscow or the Moscow area should contact AEB immediately to make sure they are on the official list.

  • Implementation time frame: AEB is expected to submit its finalized list for the migration office Saturday, but companies only have until Thursday to submit information (company name and tax identification number) to the AEB.
  • Visas/permits affected: HQS work permits, letters of invitation.
  • Who is affected:Companies applying for HQS work permits or letters of invitation based on AEB membership at the central migration office in Moscow.
  • Business impact:The changes may create some administrative hurdles and will limit the number of companies that can apply for HQS work permits or letters of invitation based on AEB membership.
  • Next steps: Affected AEB member companies should contact AEB immediately.

Background: The AEB represents the a number of European companies that conduct business in Russia. AEB membership can, in certain instances, ease the processes of obtaining work permits or letters of invitation. In particular, AEB members have, up to this point, been allowed to apply for work permits and letters of invitation at the central migration office, regardless of where they were registered. This option is usually more convenient, but is now only available to AEB companies registered in Moscow or the Moscow region. The central migration office in Moscow is moving to tighten up these processes by imposing the requirements listed above. No official comment has been offered, but the changes may have been undertaken in part to decrease the workload of the central migration office.

BAL Analysis: Affected AEB member companies should contact the AEB immediately to ensure that they are able to continue requesting HQS work permits and letters of invitation based on their AEB membership. Those who have to pursue other routes may wish to contact their BAL professional to discuss other options.

This alert has been provided by the BAL Global Practice group and our network provider located in the Russian Federation. For additional information, please contact your BAL attorney.

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