As of 1 September 2025, Federal Law No. 121-FZ of 23 May 2025 has entered into force, launching a pilot program to implement new mechanisms for the migration registration of foreign nationals and stateless persons entering Russia under a visa-free regime. The pilot program will be conducted in Moscow and the Moscow Region and will remain in effect until 1 September 2029.

New Rules for Foreign Nationals

The law introduces several key innovations:

mandatory registration at the address of an authorized organization in Moscow and notification of the actual place of residence;

registration in a mobile application with geolocation functionality;

monitoring of the geolocation of subscriber devices.

If geolocation data is not updated for more than three consecutive days, a foreign national will automatically be removed from the migration register and included in the register of controlled persons, which may subsequently result in deportation.

Who Will Be Subject to the Pilot Program

The program will apply to foreign nationals who:

are employed under a work permit (patent);

are employed without a work permit pursuant to Russian legislation or international treaties (including nationals of EAEU member states);

entered for purposes other than employment but later changed the declared purpose of their stay.

The program will not apply to persons under the age of 18, nationals of the Republic of Belarus, diplomatic personnel and their family members, officials of international organizations and their family members.

Registration Deadlines

Foreign nationals present in Moscow and the Moscow Region as of 1 September 2025 who are not yet registered must complete registration with the authorized organization within 90 days.

Foreign nationals already registered must contact the authorized organization within 30 business days after the expiration of their current registration.

Any change of residence must be reported to the territorial office of the Ministry of Internal Affairs of Russia within three business days.

Implications for Employers

For employers, the pilot program changes the procedure for registering foreign employees for migration purposes. This obligation is now assigned to the foreign nationals themselves via the mobile application.

However, to mitigate the risk of claims by supervisory authorities, employers are advised to obtain written confirmation from foreign employees that they:

are aware of the pilot program;

have completed registration in the mobile application.

It is important to note that participation in the program is mandatory. Foreign nationals covered by the pilot program cannot opt out, refuse to install the application, or rely on the general rules for migration registration. Failure to comply will result in automatic removal from the migration register and inclusion in the register of controlled persons.

Sources: Federal Law No. 121-FZ of 23 May 2025