New rules* for the registration of foreign citizens at their place of stay in Russia come into force on 8 July 2018, which will make it almost impossible to register a foreign citizen at his employer’s address.

As a result of these new rules, foreigners can be registered at the address of the organisation where they carry out employment (or other activities not prohibited by Russian law) in the following cases only:

  • when they actually live at the address of the relevant organisation; or
  • when they live at a place of residence provided by an organisation, which does not have a permanent address (e.g. a makeshift barrack).

Hence, the majority of foreign employees, as well as other foreign citizens who, before the amendments came into effect, were registered at a work organisation’s address, must now be registered at the residence they are actually staying.

As most foreign employees and their families live in rented accommodation, their landlords will be responsible for registering them.

Recommendations

We recommend that businesses without delay inform their foreign employees and other foreign citizens, previously registered at their organisation’s address, that it will be impossible to register them through an employer in the future.

We also recommend that foreign citizens immediately alert their landlords that they need to register their tenants.

If the landlord lives in another city or for some reason cannot personally undertake registration formalities, it is possible that migration authorities will accept registration applications based on a notarised power of attorney signed by the landlord.

The legislation, however, does not directly provide that foreign citizens may be registered on the basis of a power of attorney, and the position of migration authorities on this issue varies from office to office. For this reason, before obtaining a power of attorney from a landlord, it is advisable to first clarify with the local office of the migration body in the city or town where you are living whether registration applications submitted under a power of attorney will be accepted.

Foreigners officially employed as highly qualified specialists and their family members are, as before, exempt from the obligation to register during 90 calendar days from their arrival to Russia except when special registration rules are in force, such as those applicable until 25 July 2018 inclusive in the host cities of the FIFA World Cup – Russia (on which we previously reported).

* In Russian