What is the change? Russia has removed quota restrictions on Ukrainian citizens who have fled because of the conflict there.

What does the change mean? Companies may employ Ukrainian nationals in foreign quota positions without approval, but they must still obtain work permits.

  • Implementation timeframe: Immediate.
  • Visas/permits affected: Work permits for quota positions.
  • Who is affected: Companies employing Ukrainian nationals in quota positions.
  • Next steps: Work permits for qualifying Ukrainian nationals must be filed by the end of the year.

Background: The Russian government issued a decree on Sept. 2 amending its earlier quota restrictions on Ukrainian workers to allow Russian companies to employ Ukrainian citizens who left urgently. While “urgency” has not been defined, a Ukrainian national may need to prove he or she left because of the armed conflict. It is also unclear whether the removal of quotas applies only to Ukrainians from the conflict areas of Donetskaya and Luganskaya.

The Federal Migration Service (FMS) has indicated that these will be processed similar to other non-Highly Qualified Specialist applications. However, these applications will be screened by a senior FMS official before processing.

BAL Analysis: Employers should note the filing deadline for these cases. Authorities have not defined “urgency” or stated the documents needed to meet that standard. As further regulations are not expected, the rules will become clearer only as these special cases are adjudicated.

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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