New registration of foreign citizens for experimental purposes and other changes for foreign citizens from September 2025

From September 1, 2025, Federal Law No. 121-FZ of May 23, 2025, “On Amendments to Certain Legislative Acts of the Russian Federation and on Conducting an Experiment on the Introduction of Additional Mechanisms for Registering Foreign Citizens” (hereinafter referred to as Federal Law No. 121) introduces new provisions into migration legislation and amends Federal Law No. 115-FZ of July 25, 2002, “On the Legal Status of Foreign Citizens in the Russian Federation” (hereinafter referred to as Federal Law No. 115), Federal Law No. 109-FZ of July 18, 2006, “On Migration Registration of Foreign Citizens and Stateless Persons in the Russian Federation” (hereinafter referred to as the Law on Migration Registration), and other laws.

1. Experiments on the introduction of additional mechanisms for registering foreign citizens.

In order to achieve the objectives of migration registration (creating the necessary conditions for Russian citizens and foreign citizens [1] to exercise their rights and freedoms, as well as to fulfill their obligations; developing and implementing state policy in the field of migration, etc.), experiments may be conducted to introduce additional mechanisms for registering foreign citizens [2].

The procedure for organizing such experiments and the requirements for their conduct, including:

• the objectives, locations, and periods of their conduct,
• the specifics of the stay (residence) of foreigners in the Russian Federation at the locations where the experiments are conducted,
• the specifics of obtaining, including by means of automation (including data from mobile devices and geolocation), recording, processing, collecting, placing, transmitting, storing, using, and destroying information

– are determined in accordance with the Law on Migration Registration, other federal laws, and regulatory legal acts of the Government of the Russian Federation.

When executive authorities of the constituent entities of the Russian Federation are involved in experiments, their powers, procedures, requirements, and other specific features are also determined by the above-mentioned laws and regulatory legal acts in agreement with the highest officials of the constituent entities of the Russian Federation who are involved in such experiment [3].

The law on migration registration has been supplemented with certain provisions within the framework of the aforementioned experiments:

• The concept of “registration of a foreign citizen” is introduced – this is the recording of information about a foreign citizen by the migration registration authority at the address of an organization authorized by the city of Moscow (MMC “Sakharovo”) and the actual location of such a foreign citizen, including for the purpose of conducting experiments on the introduction of additional mechanisms for registering foreign citizens in the Russian Federation that are not provided for by the Law on Migration Registration [4];
• The concept of “actual location of a foreign citizen” is introduced — this is a residential premises/other premises, including temporary ones and those without address data, which a foreign citizen regularly uses for sleep and rest [5].
• The list of information about a foreign citizen recorded during migration registration is supplemented with information obtained in the course of experiments conducted in accordance with the Law on Migration Registration, other federal laws, and regulatory legal acts of the Government of the Russian Federation [6].

From September 1, 2025, to September 1, 2029, an experiment will be conducted to introduce additional mechanisms for registering foreign citizens residing in Russia in the territories of the Russian Federation’s constituent entities—the city of Moscow and the Moscow Region [7] (hereinafter referred to as the experiment).

• Objectives of the experiment:
• testing methods and means of recording and summarizing information about foreign citizens and their movements;
• determining the effectiveness of the additional mechanisms for registering foreigners staying in Russia provided for by the experiment;
• developing proposals for amendments to Russian legislation on the introduction of additional mechanisms for registering foreign citizens staying in the Russian Federation [8].
• Participants in the experiment:
• foreigners who have arrived in the Russian Federation for the purpose of performing work activities in a manner that does not require a visa, who are located in the constituent entity of the Russian Federation where the experiment is being conducted (Moscow and Moscow Oblast), and who have the right to perform work activities in the Russian Federation on the basis of a patent;
• Foreigners who have arrived in the Russian Federation for the purpose of performing work activities in a manner that does not require a visa, who are located in the constituent entity of the Russian Federation where the experiment is being conducted (Moscow and Moscow Oblast), and who have the right to perform work activities in the Russian Federation without a work permit or patent in accordance with federal law or international treaties of the Russian Federation. For example, citizens of EAEU countries; scientific workers; those who have a temporary residence permit/residence permit, etc. [9] Exception: citizens of the Republic of Belarus;
• Foreigners who arrived in the Russian Federation for purposes not related to employment, in accordance with the procedure that does not require a visa, and who are located in the constituent entity of the Russian Federation where the experiment is being conducted (Moscow and Moscow Oblast), when changing the purpose of their visit to the Russian Federation. Exceptions: citizens of the Republic of Belarus;
• foreigners who arrived in the Russian Federation in a manner that does not require a visa, temporarily residing in the constituent entity of the Russian Federation where the experiment is being conducted (Moscow and Moscow Oblast), for purposes not related to employment, for a period of more than 90 calendar days. For this category, the provisions of the laws on the experiment and the requirements for its implementation will apply from September 1, 2026.

Exceptions:

• foreign citizens under the age of 18;
• citizens of the Republic of Belarus;
• heads, employees, and staff of diplomatic missions and consulates of foreign states in the Russian Federation, as well as members of their families;
• officials of international organizations (their representative offices) that have concluded agreements with the Government of the Russian Federation on the conditions of stay in the territory of the Russian Federation, and members of their families, as well as officials of other international organizations;
• holders of diplomatic and service passports (including special, official, and other passports recognized as such in the Russian Federation) and other valid documents certifying their identity and recognized as such in the Russian Federation, provided they contain a diplomatic or service visa, as well as members of their families [10].

Thus, at present, the experiment does not apply to foreign citizens who require visas.

• Government agencies authorized to conduct the experiment:

The Ministry of Internal Affairs of Russia, the highest executive bodies of the constituent entities of the Russian Federation – the city of Moscow and the Moscow Region (the Government of Moscow, the Government of the Moscow Region). The participant in the experiment is an organization authorized by the city of Moscow – the Sakharovo International Center.

As the coordinator of the experiment, the Russian Ministry of Internal Affairs is responsible for:

• providing methodological support and coordinating the activities of the aforementioned government agencies and the Sakharovo International Media Center related to the experiment;
• conducting a comprehensive assessment of the results of the experiment together with government agencies, submitting an annual report to the Government of the Russian Federation no later than October 15 of the year following the reporting year, and no later than three months from the date of completion of the experiment [11].

Foreigners participating in the experiment are not subject to the rules and procedures for migration registration in relation to:

• registration of foreign citizens at their place of residence [12];
• registration of foreign citizens at their place of stay [13].

Exception:

Recording information about foreigners participating in the experiment in the territories of the Russian Federation participating in the experiment (in Moscow and the Moscow Region),

a hotel or other organization providing hotel services, in a sanatorium, recreation center,

– carried out by the administration of the relevant organization/institution upon the arrival and departure of these foreign citizens in accordance with the procedure for registering foreign citizens at their place of stay [14].

However, instead of the standard registration procedures described above, foreigners participating in the experiment who are staying in Moscow or the Moscow Region will be subject to “foreign citizen registration.”

As mentioned above, information about the foreigner will be recorded at the address of the organization authorized by the city of Moscow (MMC “Sakharovo”) and information about their actual location. However, such registration does not entail the provision of accommodation (residence) for foreign citizens participating in the experiment by the organization authorized by the city of Moscow (MMC “Sakharovo”) [15].

Information about the above registration will be entered into the GIS MU foreign citizens.

• Who conducts such registration: the territorial body of the Ministry of Internal Affairs of Russia located in the constituent entity of the Russian Federation where the experiment is being conducted (Moscow and Moscow Oblast).

An organization authorized by the city of Moscow (MMC Sakharovo) assists the Ministry of Internal Affairs in registering participants in the experiment on the basis of an agreement concluded between the Ministry of Internal Affairs of Russia and senior officials of the constituent entities of the Russian Federation – the city of Moscow and the Moscow Region. This agreement establishes the procedure for assistance, the means and methods of recording and summarizing information about foreign citizens participating in the experiment and about the movements of such citizens, including the use of a specialized mobile application, as well as the specifics of recording, processing, collecting, storing, transfer, storage, use, and destruction of information, including information containing the biometric personal data of such foreigners, including in information systems and/or through the use of automation tools [16].

• Mandatory actions for foreigners participating in the experiment:

When contacting the organization authorized by the city of Moscow (MMC “Sakharovo”) regarding the receipt of public services in the field of migration, fingerprinting, and photography, participants in the experiment must:

1) Register in a specialized mobile application. It can be downloaded via a link on the Sakharovo MMC website (https://mc.mos.ru/) and a QR code on Sakharovo MMC banners. If a foreigner does not have confirmation of registration in the specialized mobile application, an organization authorized by the city of Moscow (Sakharovo MMC) will ensure the registration of such a foreign citizen in this application.

2) give their consent to the processing of their personal data in accordance with Russian legislation, including through the use of automation tools (including mobile device and geolocation data);

3) send a message to the territorial body of the Ministry of Internal Affairs of Russia about their actual location using the above-mentioned specialized mobile application. The content of the message is determined by the Ministry of Internal Affairs of Russia in agreement with the highest officials of the constituent entities of the Russian Federation – the city of Moscow and the Moscow region.

4) in the event of a change in their actual location, they are required to inform the territorial body of the Ministry of Internal Affairs of Russia within three working days by sending a corresponding message via the mobile application.

Exceptions:

staying at a hotel or other organization providing hotel services, at a sanatorium, rest home, a boarding house, a children’s health camp, a tourist base, a campsite, a medical organization providing inpatient medical care, a social service organization providing inpatient social services, including to persons without a fixed place of residence, or in an institution serving a criminal or administrative sentence [17].

5) Foreign citizens who, as of September 1, 2025, are registered at their place of residence in accordance with the Law on Migration Registration in the constituent entities of the Russian Federation where the experiment is being conducted (Moscow and Moscow Oblast) are required to contact the organization authorized by the city of Moscow (MMC “Sakharovo”) to register at the address of the organization authorized by the city of Moscow (MMC “Sakharovo”) and report their actual location within 30 working days from the date of expiration of their registration at their place of residence and if there are legal grounds for their stay in the Russian Federation [18].

6) Foreign citizens legally residing in the territories of the Russian Federation participating in the experiment (Moscow and Moscow Oblast) as of September 1, 2025, and not registered with the migration authorities in accordance with the Law on Migration Registration, are required to apply to the organization authorized by the city of Moscow (MMC “Sakharovo”) for the purpose of registering at the address of such organization within 90 days from September 1, 2025, i.e., by November 29, 2025 [19].

The above-mentioned registration of foreign citizens participating in the experiment at the address of the organization authorized by the city of Moscow (MMC “Sakharovo”) is carried out for the duration of the experiment.

• Cases of removal from the register of participants in the experiment at the address of the organization authorized by the city of Moscow (MMC “Sakharovo”):

1) lack of information on the geolocation of a foreign citizen’s subscriber device for more than 3 working days from the date of the last geolocation monitoring;

2) registration of a foreign citizen for migration purposes in accordance with the procedure provided for by the Law on Migration Registration (registration at the place of residence or registration at the place of stay) in a constituent entity of the Russian Federation where the experiment is not being conducted;

3) departure of a foreign citizen from the Russian Federation;

4) death of a foreign citizen in the Russian Federation or entry into force of a court decision recognizing a foreign citizen who was in the Russian Federation as missing or declaring him or her dead [20].

The procedure for the territorial body of the Ministry of Internal Affairs of Russia to decide on removal from the above-mentioned register is established by the Ministry of Internal Affairs of Russia in agreement with the highest officials of the constituent entities of the Russian Federation – the city of Moscow and the Moscow Region [21]. Currently, it has not been established.

Foreign citizens who have left for constituent entities of the Russian Federation where the experiment is not being conducted are subject to migration registration at their place of residence or temporary stay in accordance with the standard procedure established by the Law on Migration Registration. [22].

2. Additional grounds for including foreign citizens in the Register of Controlled Persons (RCP):

In addition to the grounds established by Federal Law No. 115 for including foreign citizens in the RCP when conducting experiments in accordance with federal law on the introduction of additional mechanisms for registering foreign citizens staying in the Russian Federation, other grounds for inclusion in the RCP may be provided for[23].

In particular, inclusion in the RCL is envisaged for participants in the experiment:

• if deregistration occurs at the address of an organization authorized by the city of Moscow (MMC “Sakharovo”) on the basis of the absence of information about the geolocation of a foreign citizen’s subscriber device for more than 3 working days from the date of the last geolocation monitoring,

and

• if such a foreign citizen has no legal grounds for staying in Russia [24].

Information about a foreigner participating in the experiment is excluded from the RCP:

• if such a foreign citizen is registered at the address of an organization authorized by the city of Moscow (MMC “Sakharovo”); or
• if information about his registration with the migration authorities is received by the GIS MU [25].

3. Clarifications regarding the personal data of foreign citizens

From September 1, 2025, the processing of biometric personal data may be carried out without the consent of the data subject (among other things) also in cases provided for by the legislation of the Russian Federation on the legal status of foreign citizens in the Russian Federation, on migration registration of foreign citizens and stateless persons in the Russian Federation [26].

The police have the right to process data on citizens necessary for the performance of their duties, with the subsequent entry of the information obtained into databases on citizens, while from September 1, 2025 (among other things) information about foreign citizens and stateless persons who have reported their actual location shall be entered into such databases [27].

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[1] The term “foreigner”/“foreign citizen” here and throughout the text refers to foreign citizens and stateless persons.

[2] Part 5 of Article 4 of the Law on Migration Registration

[3] Parts 6–7 of Article 4 of the Law on Migration Registration

[4] Clause 12 of Part 1 of Article 2 of the Law on Migration Registration

[5] Clause 13, Part 1, Article 2 of the Law on Migration Registration

[6] Clause 18, Part 1, Article 9 of the Law on Migration Registration

[7] Part 1, Article 5 of Federal Law No. 121

[8] Part 2, Article 5 of Federal Law No. 121

[9] Clause 4, Article 13 of Federal Law No. 115

[10] Part 3, Article 5 of Federal Law No. 121

[11] Parts 4–5, Article 5 of Federal Law No. 121

[12] Chapter 3 of the Law on Migration Registration

[13] Chapter 4 of the Law on Migration Registration

[14] Chapter 4 of the Law on Migration Registration; Parts 7–8 of Article 5 of Federal Law No. 121;

[15] Parts 9 and 12 of Article 5 of Federal Law No. 121; Clause 12, Part 1 of Article 2 of the Law on Migration Registration

[16] Parts 10–11 of Article 5 of Federal Law No. 121

[17] Parts 13–15 of Article 5 of Federal Law No. 121

[18] Part 25 of Article 5 of Federal Law No. 121

[19] Part 25 of Article 5 of Federal Law No. 121

[20] Part 18 of Article 5 of Federal Law No. 121

[21] Part 19 of Article 5 of Federal Law No. 121

[22] Chapters 3 and 4 of the Law on Migration Registration; Part 20 of Article 5 of Federal Law No. 121

[23] Clause 2.1 of Article 31.2 of Federal Law No. 115

[24] Part 21 of Article 5 of Federal Law No. 121

[25] Part 22 of Article 5 of Federal Law No. 121

[26] Article 3 of Federal Law No. 121; Part 2 of Article 11 of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data”

[27] Article 4 of Federal Law No. 121; Clause 44.4, Part 3, Article 17 of Federal Law “On Police” dated February 7, 2011, No. 3-FZ