What is the change? Beginning Jan. 1, Russia will overhaul its work permit regime for companies employing nationals of the Commonwealth of Independent States. 

What does the change mean? Standard work permits will be replaced by “work patents” governing CIS nationals’ stays and employment in Russia. Employers will not have to sponsor a CIS national’s initial work patent application and they will not be subject to quotas.

  • Implementation timeframe: Jan. 1, 2015.
  • Visas/permits affected: Work patents.
  • Who is affected: Companies employing CIS nationals.
  • Business impact: While some provisions ease rules for businesses employing CIS nationals, others will have a negative impact on employers who hire a large number of CIS nationals.
  • Next steps: Companies employing CIS nationals, particularly those relying on a majority-CIS workforce, should consult their BAL attorney to strategize for the new regime in the coming year.

Background: Under the new system that takes effect Jan. 1, CIS nationals will no longer be required to apply for standard work permits. Instead, upon entering Russia they must declare that their purpose is to work. They will then have to observe strict deadlines for work patent applications (30 days) and finding a job (60 days). Violation of the deadlines will result in fines or cancellation of the work patent.

Work patents will be valid for a maximum of 12 months and may be extended only once. Work permits give CIS nationals the right to work in only one particular region of Russia, but they can work for any employer within the region, do not need an employer to sponsor the initial work patent and can change jobs without having to obtain a new work patent. CIS nationals must undergo medical testing, pass Russian language and history tests, provide fingerprints, purchase insurance from designated providers and appear in person to submit the application and pick up the work patent.

The new system also transfers significant powers over work patents to regional governors, who can decide that work patents must denote job positions, ban work patents for certain job categories or dismiss all work patent holders in certain job categories. 

BAL Analysis: The work patent regime will have a significant impact for companies employing large numbers of CIS nationals and may eventually incentivize employers to replace those workers with Highly Qualified Specialist permits since some criteria for HQS work permits have been eased.

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.

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