IMPACT – MEDIUM

What is the change? New rules allow foreign nationals to complete registration by providing the address of their host party, provided that there is a “legal connection” between them that will continue for the duration of the foreign national’s stay in Russia. “Legal connection,” in this context, is understood to imply that the foreign national will be participating in activities with the host party in a way that requires a presence at the host party’s address.

What does the change mean? Foreign nationals may now complete registration processes by providing (1) their actual residence, (2) the address of their employer or (3) the address of their host party where a “legal connection” will continue for the duration of their stay.

  • Implementation time frame: Immediate and ongoing.
  • Who is affected: Foreign nationals completing registration upon arriving in Russia.

Background: The new rules were implemented following a decision by Russia’s Constitutional Court in July. In it, the court recognized legal ambiguity as to whether foreign nationals could use the address of their host organizations when completing registration. The Federal Legislature took steps to remedy the uncertainty by developing the rules descibed above. It is possible that additional changes to registration processes will be made under the court’s ruling, and BAL will alert clients if they are made.

BAL Analysis: Organizations hosting foreign nationals on business, humanitarian trips or for other purposes may wish to advise them of the registration options available to them. Foreign nationals should only register using the address of their host party if they will have continued contact with the organization throughout their stay in Russia.