On July 26, 2026, Federal Law No. 241-FZ of July 26, 2026, “On Amending the Federal Law ‘On the Legal Status of Foreign Citizens in the Russian Federation’” was adopted. The new rules change the approach to immigration control: the financial stability of the foreign national and his or her family is now the key criterion for the legality of their stay.

The general effective date for these amendments is January 1, 2027, but there are exceptions for certain provisions.

New Salary Threshold and Annual Indexation for Highly Qualified Specialists (HQS)

Effective March 1, 2027, the minimum wage requirements for HQS will change:

  • For most HQS — 717,000 rubles per month (currently 750,000 rubles per quarter).
  • For certain categories of highly qualified specialists (medical professionals, educators, researchers, IT specialists at accredited companies, residents of Skolkovo and Sirius, etc.) — 358,500 rubles per month (currently, the rate varies from 0 to 83,500 rubles per month).

An annual adjustment of these amounts is being introduced—the Ministry of Labor will determine the adjustment factor based on the growth in the country’s average wage.

Important: If a high-income earner’s salary falls below the threshold, the employee will lose their high-income earner status, and the tax rate for non-residents (those not from the EAEU) will increase from 13–22% to 30%.

At the same time, the law provides for a transition period: foreign citizens who obtained a work permit before March 1, 2027, are entitled to obtain a patent (for visa-exempt nationals) or a new annual work permit (hereinafter “AWP”) (for visa-required nationals) through the standard procedure without leaving the Russian Federation. In this case, foreign nationals requiring a visa are issued a standard multiple-entry work visa valid for the duration of the annual work permit (as standard).

This measure is intended to allow companies that are not prepared to raise salaries to continue their employment relationships with current employees. Given the time required to process all documents with the Ministry of Internal Affairs, employers should begin addressing the issue of renewing documents now, taking into account the expiration dates of existing work permits for foreign specialists and the March 1, 2027, deadline, which marks the start of paying salaries to foreign specialists at the new minimum level.

One question remains unanswered: How can a company legally terminate a foreign specialist’s employment if it cannot pay the new minimum wage? For now, the only options are a mutual agreement between the parties or reclassifying the employment status to a work permit or residence permit while continuing the employment relationship. This creates the risk of legal disputes.

The Principle of Economic Justification — for All Foreign Workers

The government is shifting from a registration-based approach to migration toward an economically sound basis for the presence of foreign nationals in Russia.

  • A general tightening of income requirements for foreign nationals.

Effective January 1, 2027, all foreign workers are required to provide for themselves and their family members (who are staying in or residing in the Russian Federation and are their dependents) at a level no lower than the subsistence minimum multiplied by the regional coefficient. If a foreign national works in multiple regions, the highest of these minimums applies.

  • The regional coefficient is established by law of the constituent entity of the Russian Federation (if no such law has been enacted, it is equal to 1).
  • Upper limit: The minimum amount cannot exceed the average monthly salary for the region (according to Rosstat).

The general rule regarding minimum income applies to all foreign workers, but exceptions apply to certain categories; the list of these exceptions and the conditions for their application vary depending on the foreign national’s legal status in the Russian Federation (whether they hold a temporary residence permit (TRP), a residence permit (RP), a patent, etc.) and may be supplemented by international treaties; for example, such provisions already exist for citizens of Belarus (see below).

The procedures for calculating tax amounts, filing tax returns, and paying fixed advance payments for personal income tax are established by Article 227.1 of the Tax Code of the Russian Federation, taking into account Federal Law No. 242-FZ of July 26, 2026, “On Amending Articles 85 and 102 of Part One and Article 227.1 of Part Two of the Tax Code of the Russian Federation,” which takes effect on January 1, 2027,

– While not covered in this article, due to the recently adopted amendments regarding income and taxes that have been incorporated into the Russian Federation’s migration and tax laws, these provisions now apply not only to those working under a patent but also to certain other categories of foreign citizens. It is important to take this into account well in advance to avoid migration and tax risks.

  • Automated Monitoring of Income and Work Activity

Effective October 1, 2026, a mechanism for interagency data exchange with the Ministry of Internal Affairs will be launched:

  • Tax authorities will provide the Ministry of Internal Affairs with information on the income of foreign nationals (for insurance contributions—for 3, 6, 9, and 12 months; for the self-employed—from the “My Tax” app for the calendar year).
  • Starting October 24, 2026, the Ministry of Internal Affairs will have access to this information upon request and will also exchange information with employment agencies (regarding the hiring of foreign nationals) and the Federal Tax Service (based on information provided by employers).
  • The new regulations will apply to information submitted or not submitted to government agencies for the relevant periods, starting in January 2027.

The Ministry of Internal Affairs, including through organizations authorized by it in certain constituent entities of the Russian Federation (Federal State Unitary Enterprise, Sakharovo International Migration Center), will be able to promptly verify the availability of information and income levels, as well as the payment of fixed advance personal income tax payments, in order to make prompt decisions regarding the legality of foreign citizens’ presence in the Russian Federation. The Ministry of Internal Affairs of Russia will approve the procedure for these checks.

  • Consequences of a Lack of Income or Income Below the Minimum Threshold

If a foreign worker has no official income or if the amount of their income is below the established minimum, the following may occur:

  • termination of an employment (civil law) contract;
  • shortening the duration of temporary stay (with notification to the foreign national and the employer);
  • refusal to renew, issue, or revoke a patent, temporary residence permit, temporary residence visa, or permanent residence permit;
  • the requirement that the foreign national (and his or her dependent family members) leave the Russian Federation within the specified time frame;
  • In the event of evasion—inclusion in the Register of Controlled Persons (RKL) and the application of other immigration control measures, including deportation.

Specifics for Different Immigration Statuses

    • EAEU citizens and other foreign nationals working without an RNR or work permit

Strict rules are being introduced for foreign nationals who are entitled to work in the Russian Federation without a work permit (pursuant to Russian law or international treaties with the Russian Federation):

  • If such an employee has no official income, or if the amount of their income is below the subsistence minimum (taking into account the regional adjustment factor for the foreign national and each dependent family member), or if the Ministry of Internal Affairs has not received information regarding their income, then:

– An employment contract is considered terminated as of the moment this fact is confirmed by an audit,

– The duration of the temporary stay of a foreign national and his or her dependent family members is being reduced.

  • Income is calculated as the average monthly income for the calendar year (taking into account all months worked). If the spouses have joint dependents, the combined income of both spouses is taken into account.
  • The rules apply to the work of legal entities, sole proprietors, notaries, attorneys, and other individuals whose activities are subject to licensing or registration. Similar provisions apply to self-employed foreign nationals.
  • When working for individuals for personal or household purposes, authorities verify whether a fixed advance payment of personal income tax has been made for each month of work during the calendar year—if no such payments have been made, the same consequences will apply (termination of the contract and reduction of the length of stay). This rule does not apply to the self-employed.
  • If the duration of a temporary stay is reduced, the deadline for departing the Russian Federation—effective March 1, 2027—is 3 calendar days from the date the decision takes effect (15 days after it is issued). Failure to comply will result in inclusion in the Register of Foreign Nationals and deportation.
  • Exception: None of the above provisions regarding citizens with such status apply to citizens of a foreign state that is a party to an international treaty of the Russian Federation on the establishment of a union state, as well as to members of their families—in particular, citizens of Belarus.

 

  • Patent
  • The period of stay for dependent children under 18 years of age is extended for the duration of the parent’s residence permit, provided that a fixed advance payment of personal income tax is made for each child in accordance with the new rules of Article 227.1 of the Tax Code of the Russian Federation (effective January 1, 2027) and only until the child reaches the age of 18.
  • Upon turning 18, a child must leave the country within 30 days, apply for a residence permit (without a late fee), or have another legal basis for staying in the Russian Federation.
  • If a patent is not renewed or is revoked, a 15-day deadline is set for departure from the Russian Federation for both the foreign national who holds the patent and his or her dependent children under the age of 18.
  • New grounds for refusing to issue or revoking a patent: lack of income information or income below the minimum threshold (taking into account minor children). Exceptions: when a patent is being issued for the first time, or when the work is performed solely by individuals for personal use.

 

  • Work Permit (WP)
  • The grounds for denial or revocation are the same as those for work permits issued under a patent, but income is assessed solely based on the foreign national (excluding children and other family members). The exception is when applying for a work permit for the first time.
  • The deadline for leaving the Russian Federation if a temporary residence permit is not renewed or is revoked is 15 days.

 

  • Temporary Residence Permit (TRP) and Permanent Residence Permit (PRP)
  • When confirming residence in the Russian Federation, you must attach documents verifying your income to the relevant notification (a statement from your employer, a tax return, documents confirming payment of the fixed personal income tax advance payment, information on income from deposits, dividends, securities, etc.).

Certain categories of taxpayers in this status must submit all of the above-mentioned documents (except for the document confirming a fixed personal income tax advance payment) if they receive such income (for example, full-time students at certain educational and research institutions in the Russian Federation, retirees, individuals who are unable to work and their children under 18, etc.)

  • Parents who are financially responsible for foreign citizens under the age of 18, or persons who are legally incapacitated or have limited legal capacity, who are temporarily or permanently residing in the Russian Federation (with a Temporary Residence Permit or Permanent Residence Permit), must submit the relevant documents for such individuals.
  • New grounds for denying or revoking a Temporary Residence Permit (TRP) or Permanent Residence Permit (PRP): no employment or business activity for one year; income below the minimum threshold (taking into account dependent family members); or failure to pay the minimum fixed payment when working for private individuals (also taking into account dependent family members).

There are some exceptions to this rule—full-time students, retirees, individuals who are unable to work, dependent children of Russian citizens, citizens of Belarus and their family members, and others.

  • Benefits: If a foreign national loses their job but finds employment with a new employer within 3 months, and their income for the period of employment meets the minimum threshold calculated based on the duration of employment during the reporting period, their Temporary Residence Permit (TRP) or Permanent Residence Permit (PRP) will not be revoked.

A residence permit is also not revoked for university graduates who graduated with honors if they find employment within 6 months of the date the residence permit was issued—and similarly, if their income meets the requirements calculated based on the period of employment.

Changes to Notifications for the Ministry of Internal Affairs

  • Employers (clients)—Russian citizens who hire foreign nationals with a work permit for personal needs—are exempt from the requirement to file notifications regarding the conclusion or termination of a contract.
  • For foreign nationals with temporary or permanent residence status (holding a Temporary Residence Permit or Permanent Residence Permit) who work for individuals for personal needs, a new notification of employment is being introduced—the foreign worker must submit this notification within 10 days of the start date of employment.
  • Patent holders are not required to submit a notification of employment if their employer is a legal entity, a sole proprietor, a notary, an attorney, or any other person whose professional activities are subject to state registration or licensing.

What does this mean for businesses and foreign nationals?

The new measures have two objectives: to increase tax revenue and to simplify the verification of foreign nationals’ legal status.

Employers will have to scrutinize the financial records of foreign employees more closely, calculate salaries accurately, and be prepared to update their documentation immediately.

In most cases, foreign nationals themselves will be required to confirm that they can support not only themselves but also their families.

Given the deadlines for the start of income information sharing and inspections, employers and foreign nationals are advised to:

  • determine the status of a foreign worker;
  • verify official income/salary—starting in 2027, income must be no less than the subsistence minimum × the regional coefficient (taking dependents into account, if applicable). For foreign workers, a new minimum wage will apply starting March 1, 2027;
  • review the correct calculation of the fixed personal income tax advance payment based on status and other circumstances (if applicable);
  • determine whether a foreign worker qualifies for any exemptions or benefits;
  • keep track of the deadlines: October 1, 2026—data exchange with government agencies; January 1, 2027—general requirements; March 1, 2027—minimum wage thresholds and the 3-day departure rule.
  • If discrepancies or financial difficulties are identified, take appropriate measures, plan expenses and actions to ensure compliance with the established minimum income/salary requirements, including reaching an agreement with the employee. For remote work: amend the employment contract regarding the salary level; reach an agreement between the parties to terminate the contract; switch to a work permit or temporary residence permit; or apply for a different status, with a preliminary assessment of timelines and feasibility.
  • Be prepared for the new notification regarding employment—effective January 1, 2027, for foreigners with a Temporary Residence Permit (TRP) or Permanent Residence Permit (PRP) working for individuals (for personal needs)—submit the notification within 10 days; familiarize yourself with the form and the procedure for completing and submitting it well in advance.
  • Monitor clarifications and new orders from the Ministry of Internal Affairs regulating these changes—the notification form and inspection procedures have not yet been approved.

Our specialists can provide advice on the above-mentioned changes to the Russian Federation’s immigration, labor, and tax laws, and assist with payroll processing and tax calculations for foreign employees in light of these new regulations.

Author

Olga Tumasova
  • Senior lawyer, labour and migration practice

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