IMPACT – MEDIUM

What is the change? Russian immigration authorities have rejected applications filed by employers for registration of foreign nationals—even in cases where the employer is the “host party” for foreign registration purposes.

What does the change mean? The pattern follows the implementation this month of new regulations for the registration of foreign nationals. Local immigration authorities have refused registration applications from employers in a number of offices, including the Presnensky office and others in Moscow. Some offices are accepting registration applications from employers, but implementation is inconsistent.

  • Implementation time frame: Ongoing.
  • Visas/permits affected: Registration of foreign nationals.    
  • Who is affected: Foreign nationals and host parties completing registration in Russia.
  • Impact on processing times: Registration procedures may be delayed in some cases even when employers are the appropriate entity to register their employees.

Background: The new rules took effect July 8 and changed the requirements of the “host party” responsible for completing registration.

Parties of Lease Agreement Party Responsible for Registration Address of Registration
Landlord and employer; i.e., employer rents accommodation for foreign national. Employer. Address of accommodation.
Landlord and foreign national; i.e., foreign national rents accommodation directly from landlord. Landlord. Address of accommodation.

Since the regulations took effect, implementation has been inconsistent from office to office. In some cases, authorities have rejected applications from employers even when employers are renting accommodations on behalf of foreign nationals and, therefore, are responsible for completing registration.

BAL Analysis: In recent days, local office have begun to accept more registration applications from employers, though enforcement is still inconsistent. Employers are encouraged to work closely with BAL to ensure they are completing registration procedures.

Intermark Relocation, BAL’s network partner in Russia, continues to work with authorities, asking that they provide written clarification about the new regulations. It is not clear, however, how long the current enforcement trends will continue.

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

Copyright © 2018 Berry Appleman & Leiden LLP. All rights reserved. Reprinting or digital redistribution to the public is permitted only with the express written permission of Berry Appleman & Leiden LLP. For inquiries please contact copyright@bal.com.