Dear CERBA Members and Partners,

On the basis of the information kindly provided by CERBA Corporate Member – Intermark Relocation, we would like inform you that on 8 June 2020 the President of Russia signed a law on amendments to the legislation regulating the address registration in Russia. The changes will take effect on 7 September 2020.

Which law introduces the changes?

Federal law No. 182-FZ of 08.06.2020 "On amendments to the Federal law "On the migration registration of foreign citizens and stateless persons in the Russian Federation"

What are the changes?

1. Foreign nationals who own a living premise in the territory of Russia may act as host parties for any other foreign nationals who actually dwell in this premise.

Intermark: The foreign nationals’ new entitlement to register other foreign nationals in their own living premises is indisputably a positive novelty because it will allow such landlords to register family members or guests regardless of their own immigration status and should make it easier for them to lease such premises to other foreign nationals.

2. Aside from already existing means of submitting the address registration application (at migration office in person or via MFC or via post office) the new law introduces a new option to submit it in electronic form via Public Services Portal.

Intermark: Introduction of the electronic address registration option may simplify the registration process, though in practice this option may be implemented with delay and may be not applicable in certain situations. We will keep track of further clarifications received from the migration authorities.

3. In case a foreign national’s host party owning a premise is a Russian national permanently residing outside Russia, a foreign national or a foreign organisation staying or located outside Russia then this foreign national is obliged to report their arrival to the migration office in person in order to perform their address registration. To this end, they will need to provide a notarised consent of the owner for their stay in the relevant premise. The form of consent is to be approved by the MIA of Russia.

Intermark: Though the very possibility of performing the address registration in circumstances when the host party stays outside Russia is very topical, this new regulation provides only for in-person visits of foreign tenants to migration offices as a solution. In addition, it is unknown how the authorities will evaluate that a particular Russian landlord is “permanently residing outside Russia” – this depends, at least, on the landlord’s consent form that is yet to be approved.

4. When registering upon arrival at a hotel or similar organisation (sanatorium, recreation centre etc.) foreign nationals will no longer be automatically de-registered from their previous place of stay provided that the latter was not another hotel or similar organisation.

Intermark: This change may be deemed positive as long as it means that the host party is exempted from re-registering a foreign tenant upon their return to the previous place of stay after staying at a hotel. However, this will depend on how the migration authorities will construe this regulation in practice.

5. The law provides that the residence registration for the holders of temporary or permanent residence permits, in addition to the option of visiting a migration office in person, is also available via Multifunctional centre or in electronic form.

Intermark: This change may simplify the process of residence registration both for the foreign resident and for the landlord.

Who is affected?

Foreign nationals as well as companies or individuals who provide them with premises for actual dwelling.