IMPACT – MEDIUM

What is the change? Russia has passed a bill to simplify the application procedure for Permanent Residence Permits (PRP) and to clarify the process for obtaining the Temporary Residence Permit (TRP).

  • Effective date: Nov. 1.
  • Visas/permits affected: TRPs and PRPs.
  • Who is affected: Foreign nationals applying for residence permits.

Pending changes:

  • Eased eligibility. Eligible foreign nationals will now be able to apply directly for the PRP without first applying for a TRP. Foreign nationals will be eligible for a PRP with unlimited validity if they:
    • were born in the RSFSR and were USSR citizens;
    • have a parent or guardian who is a foreign citizen and has a PRP in Russia;
    • are under 18 and have obtained a PRP together with their parent, adoptive parent or guardian;
    • have a parent, adoptive parent or guardian, son or daughter – who is a Russian citizen and who permanently lives in Russia;
    • are native speakers of the Russian language (this will be determined under a specially designed procedure, to be announced);
    • were deported from the territory of Crimea ASSR;
    • have highly qualified specialist status;
    • are considered qualified specialists and have worked for no less than six months in a position included on the list issued by the Ministry of Internal Affairs;
    • have graduated with honors from a Russian university under a full-time accredited education program.

The following foreign citizens can apply directly for a PRP with a three-year validity:

    • HQS employees and their family members.
    • Qualified specialists who have worked in Russia for six months in a position that is included in the list of qualified worker job positions, and who have the right to apply for Russian citizenship following a simplified procedure. The Ministry of Internal Affairs will confirm the full list of documents that must be filed.
  • Renewals. The bill stipulates that the PRP must be renewed if and when holders turn 14, 20 or 45, or if they change their first or last name.
  • Counting rules. Foreign nationals who have spent more than six months total in one calendar year outside of Russia will have their PRP or TRP application rejected or an already-issued PRP or TRP annulled. Exceptions may be made in emergency circumstances (i.e., serious illness) or in cases where the TRP or PRP holder is spending time abroad owing to work.
  • Notification. PRP holders must submit notification to a local Ministry of Internal Affairs office on a yearly basis. Notification must be submitted in person.
  • Cancellations. The bill clarifies the procedure for canceling a PRP or TRP. Additionally, the authorities have proposed that the PRP will be automatically canceled if holders fail to report their presence in Russia for more than two consecutive years.
  • Shortened application review. The bill shortens the review period for the TRP to four months.

Analysis & Comments: The changes will simplify the process for obtaining a PRP for eligible nationals and further clarify processing of TRPs. While the bill has been passed, it will not come into effect until Nov. 1.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

Russian officials have announced the countries whose nationals will be eligible for e-visas when traveling to St. Petersburg and the Leningrad region beginning Oct. 1. Nationals of the following countries will be able to apply for single-entry e-visas for business, tourism or humanitarian visits.

Austria Finland Japan North Korea Saudi Arabia
Andorra France Kuwait North Macedonia Serbia
Bahrain Germany Latvia Norway Singapore
Belgium Greece Lithuania Oman Slovakia
Bulgaria Hungary Liechtenstein Philippines Slovenia
China (including Taiwan) Iceland Luxemburg Poland Spain
Croatia India Malaysia Portugal Sweden
Cyprus Indonesia Malta Qatar Switzerland
Czech Republic Iran Mexico Romania Turkey
Denmark Ireland Monaco San Marino Vatican
Estonia Italy The Netherlands    

Additional information: E-visas for those traveling to St. Petersburg and the Leningrad region will be valid for 30 calendar days with an eight-day limit on a visitor’s duration of stay. No fees will be assessed for e-visa issuance. The St. Petersburg-Leningrad program will be launched ahead of a nationwide e-visa program expected to take effect Jan. 1 and following the implementation of the Kaliningrad e-visa program earlier this year.

Analysis & Comments: The e-visa program will ease business, tourist and humanitarian travel for eligible foreign nationals visiting St. Petersburg and the Leningrad region. More information on the nationwide e-visa program is expected in the coming weeks and months.

Source: Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

Reports on the salaries paid to highly qualified specialists during the third quarter of 2019 (July through September) must be submitted in October. The reports, which employers must complete to show that they have met minimum salary payment levels, are required quarterly.

  • Key Dates: Oct. 1-31.
  • Visas/permits affected: HQS work permits.
  • Who is affected: Companies that employ highly qualified specialists.
  • Business impact: Companies and individual company officials may face fines if they fail to submit the reports on time.
  • Next steps: Salary reports may be submitted in person or mailed to the Ministry of Internal Affairs.

Analysis & Comments: Companies should ensure that they submit their quarterly reports on time and that the salaries comply with wage thresholds for HQS workers.

Source: Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Russia now requires all foreign nationals to be immunized against measles when working in the country.

What does the change mean? Companies should ensure that all current foreign workers are immunized by Dec. 31, and that all new hires are immunized thereafter.

  • Effective date: Immediate and ongoing. The employer deadline for all current employees to hold an immunization record is Dec. 31.
  • Visas/permits impacted: A number of visas and permits, including work visas and work permits, patents, and temporary and permanent residence permits.
  • Who is impacted: Foreign nationals working in Russia and their employers.
  • Business impact: Companies employing foreign workers who are not immunized against measles are subject to fines and penalties.

Additional information: Foreign nationals who have had the measles before or suffer from a measles immunization allergy will not be required to obtain the immunization. Immunization records must be issued in Russia. If the immunization record was issued abroad, it may be possible to have it verified with an authorized clinic in Russia.

Analysis & Comments: To be compliant with the new law, companies should ensure that all foreign nationals have confirmation of immunization against measles before Dec. 31.

Source: Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? Russia will soon begin issuing e-visas to eligible foreign nationals traveling to St. Petersburg and the Leningrad region.

What does the change mean? Beginning Oct. 1, eligible foreign nationals will be able to apply for single-entry e-visas for business, tourism or humanitarian visits. The visas will be valid for 30 calendar days with an eight-day limit on a visitor’s duration of stay. No fees will be assessed for e-visa issuance. Authorities have not yet established which nationalities will be eligible for e-visas, but the list of countries will likely be similar to the list of 53 countries for an e-visa program launched earlier this year in Kaliningrad.

  • Implementation time frame: Oct. 1.
  • Visas/permits affected: E-visas for business, tourism or humanitarian visits.  
  • Who is affected: Eligible foreign nationals traveling to St. Petersburg and the Leningrad region.
  • Business impact: The change will save business travelers the time it takes to obtain a visa.
  • Next steps: Between now and Oct. 1, Russian authorities will establish which nationalities are eligible for the e-visas and which points of entry will be included in the program.

Additional information: The St. Petersburg-Leningrad program will be launched ahead of a nationwide e-visa program expected to take effect Jan. 1 and following the implementation of the Kaliningrad e-visa program. The is available to nationals of 53 countries, including most EU countries but not the United Kingdom or the United States.

Analysis & Comments: The e-visa program will ease business, tourist and humanitarian travel for eligible foreign nationals visiting St. Petersburg and the Leningrad region. Authorities have not yet said which nationals will be eligible, and Deloitte will provide more information as it becomes available.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more. Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services. This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change? The Ministry of Interior’s immigration department is more strictly scrutinizing and penalizing companies employing foreign nationals through third-party staffing agencies.

What does the change mean? Companies outsourcing employees through third-party staffing agencies are at risk of violating the rules for employing foreign nationals. While some companies resort to the services of staffing agencies, employment of foreign nationals without a direct (local) employment contract and applicable permission documents is subject to fines and penalties.

  • Resolution issue date: Immediate and ongoing.
  • Who is affected: All foreign nationals, including Commonwealth of Independent States (CIS) nationals.
  • What to watch: Companies that breach rules for employment of foreign nationals, specifically employers hiring foreign nationals without the appropriate permission documents, may be fined up to 1 million Russian rubles and/or face suspension of activities for up to 90 days.

Background: On June 25, the Ministry of Interior’s immigration department for the Northeastern District of Moscow issued a resolution against a company providing food delivery services, penalizing it for a breach of rules for employment of foreign nationals. While some companies in Russia employ foreigners through staffing agencies and, thus, have no permission documents in place for the foreign employees, this can result in fines and penalties.

Analysis & Comments: Companies should avoid employing foreign nationals through third-party staffing agencies and instead hire them directly to avoid penalties. Additionally, companies should note that the authorities may see using the services of staffing agencies as a way to avoid immigration and employment responsibilities and obligations.

Source: Deloitte. Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also ref­­­erred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.  Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services. For legal, regulatory and other reasons, not all member firms provide legal services.

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the “Deloitte network”) is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication. © 2019. For information, contact Deloitte Touche Tohmatsu Limited.

IMPACT – MEDIUM

What is the change?  Russia has proposed a bill to simplify the application procedure for permanent residence permits (PRPs) and to clarify the processes for obtaining temporary residence permits (TRPs).

  • Effective date: To be determined. The bill has not been passed yet.
  • Visas/permits affected:  Temporary and permanent residence permits.
  • Who is affected: Foreign nationals applying for residence permits.
  • What’s next: The bill, which has been labeled a high priority, is expected to be reviewed by the State Duma by the end of July, or October at the latest.

Proposed changes:

  • Eased eligibility. Eligible foreign nationals would be able to apply directly for the PRP without first applying for a TRP. The following individuals would be eligible for an unlimited validity PRP:
    • Foreign nationals who were born in the Russian Federation and who were USSR citizens in the past.
    • Foreign nationals who were born in Russia, have not reached the age of 18 and whose parent, stepparent, or caretaker are foreign citizens and who permanently live in Russia.
    • Foreign nationals who have a parent, son or daughter who is a Russian citizen and who permanently live in Russia.
    • Foreign nationals who are native speakers of the Russian language (eligibility to be determined under a specially designed procedure, to be announced).
    • Foreign citizens who were deported from the territory of Crimea Autonomous Soviet Socialist Republic.
    • Individuals who live in Russia and whose Russian citizenship has been annulled.
    • Individuals who live in Russia and who were denied Russian citizenship, with the exception of those who were denied Russian citizenship because they committed a crime.

The following individuals may apply directly for a PRP with a three-year validity:

    • Foreign citizens – Highly qualified specialists and their family members.
    • Foreign citizens (highly qualified specialists) who have worked in Russia for six months who have the right to apply for the Russian citizenship following a simplified procedure. The full list of documents that have to be filed will be confirmed by the Ministry of Internal Affairs.
  • Renewals. The proposed bill establishes that the PRP will need to be renewed if and when the foreign national turns 14, 20 or 45 years of age or if the foreign nationals change their first name or surname.
  • Counting rules. Foreign nationals who have spent more than six months in one calendar year outside of Russia will have their PRP or TRP application rejected or an already issued PRP or TRP annulled. Exceptions may be made in emergency circumstances (such as serious illness) or in cases where the TRP or PRP holder is spending time abroad due to work.
  • Notification. PRP holders must submit notification to a local Ministry of Internal Affairs office on a yearly basis. Notification must be submitted at an in-person appearance.
  • Cancellations. The proposed bill clarifies the procedure for cancelling a PRP or TRP  Additionally, the authorities have proposed that the PRP will be automatically cancelled if the foreign national fails to report their presence in Russia for more than two years in a row.
  • Shortened application review. The bill has proposed a four-month review period for the TRP.

Analysis & Comments:  The proposed changes would simplify the process for obtaining a PRP for eligible nationals and would further clarify processing of TRPs.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

What is the change? The Moscow Immigration Office has announced new rules when applying for letters of invitation at the migration office located at 42 Pokrovka St. in Moscow.

What does the change mean? The state fee collected for original letters of invitation, or LOIs, must now be paid from the bank account of the inviting company. Previously, the fee could be paid by individuals and confirmed by payment receipt.

  • Effective date: Immediate and ongoing.
  • Visas/permits affected: LOIs.
  • Who is affected: Inviting companies submitting LOI applications.

Additional information: An original payment order certified with a round bank seal and a bank representative signature must be attached to the application. The application must include the full name of the foreign national in the “purpose of payment” section.

Analysis & Comments: Companies should ensure that the state fee for LOIs is paid directly to the Moscow Immigration Office in order to complete the application. The payment receipt must be validated by a bank seal.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

 

IMPACT – HIGH

What is the update? A series of regulations that specify procedures for inviting parties to enforce that foreign nationals comply with the terms of their visa have been submitted to the government for review. Migration authorities have verbally confirmed that companies may refer to the draft guidelines to prepare draft documents until the official recommendations are announced.

Proposed changes:

  • New arrivals. The inviting company or organization must notify the foreign national, upon entry, of the activities that are allowed under their visa type, the allowed period of stay, and the penalties if they violate the terms of the visa. It is presumed that the inviting parties will have to communicate this information via email, telephone or personal meeting.
  • Visa expiration reporting. The inviting company must send a visa expiration reminder to the foreign employee or business visa holder at least 10 calendar days prior to the visa expiration date. The reminder must inform the foreign national of the expiry date, and may be sent as a registered letter by one of the following methods: the Russian post (with a receipt notification) ,an email (the company must have a receipt indicating that the mail was sent and received by the individual) or in-person meeting (the inviting company must obtain a signature from the individual)
  • Immigration violation reporting. The inviting company must submit a notification regarding any regime violation to the Ministry of Internal Affairs within five days from the date when it was informed of the respective violations.

Background: In January, Article 16 of the federal law “on the status of foreign citizens in Russia” imposed new regulations on employers and individuals who invite foreign nationals to Russia to make sure that the foreign nationals comply with the terms of their visa and their purpose for being in the country. While the law took effect Jan. 16, guidelines setting out the specific regulations had not yet been issued. The proposed regulations would specify the measures to be followed by inviting parties sponsoring visas to foreign nationals.

Analysis & CommentsCompanies should be aware of the new obligations and review their procedures. In particular, the inviting company should obtain written acknowledgment from foreign nationals when they arrive in Russia that they are required to comply with the stated purpose of entry and leave before their visa expires. They should also notify visa holders at least 10 days prior to their visa expiry.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.

IMPACT – MEDIUM

Reports on the salaries paid to highly qualified specialists during the first quarter of 2019 (January through March) must be submitted in April. The reports, which employers must complete to show that they have met minimum salary payment levels, are required quarterly.

  • Key dates: April 1-30.
  • Visas/permits affected: HQS work permits.
  • Who is affected: Companies that employ highly qualified specialists.
  • Business impact: Companies and individual company officials may face fines if they fail to submit the reports on time.
  • Next steps: Salary reports may be submitted in person or mailed to the Ministry of Internal Affairs.

Analysis & Comments: Companies should ensure that they submit their quarterly reports on time and that the salaries comply with wage thresholds for HQS workers.

Source: Deloitte LLP. Deloitte LLP is a limited liability partnership registered in England and Wales with registered number OC303675 and its registered office at 1 New Street Square, London EC4A 3HQ, United Kingdom.