Russia: Registry of Irregular Foreigners with Severe Rights Restrictions

What Changed

On February 5, 2025, two complementary federal laws came into force that create a formal registry of foreign nationals in an irregular immigration situation in Russia and impose a broad set of civil and economic restrictions on those listed. The laws are:

• Federal Law No. 636-FZ of December 28, 2024, "On Amendments to Federal Law No. 115-FZ on the Legal Status of Foreign Citizens in the Russian Federation" (establishing the registry).
• Federal Law No. 637-FZ of December 28, 2024, "On Amendments to Certain Legislative Acts of the Russian Federation in Connection with the Improvement of Control over the Stay of Foreign Citizens" (imposing the restrictions).

Together, these laws represent the most significant expansion of Russia's immigration enforcement infrastructure since the 2002 adoption of the foundational immigration law.

The Registry: How It Works

Grounds for Inclusion

The MVD (Ministry of Internal Affairs) maintains the registry, known formally as the "Register of Foreign Citizens Subject to Control" (Reyestr inostrannykh grazhdan, podlezhashchikh kontrolyu). A foreign national is entered into the registry if they meet any of the following criteria:

• Overstay: Remaining in Russia beyond the authorized period of stay (visa expiration, 90-day visa-free limit, expired migration card) without having filed for an extension or new immigration status.
• Revoked status: Having a work patent, work permit, temporary residence permit, or permanent residence permit revoked by the MVD and failing to depart within 15 days.
• Deportation or expulsion order: Being subject to a court-ordered deportation or administrative expulsion that has not yet been executed.
• Entry ban: Being present in Russia despite an active entry ban (which can occur if the person entered before the ban was imposed or if the ban was imposed after entry).
• Failure to register: Not completing mandatory migration registration within the required timeframe (seven business days for most nationalities, one day for citizens of certain countries).

Notification

The law requires the MVD to notify the foreign national of their inclusion in the registry. Notification is delivered through:

• The RuID mobile application (for those who have registered).
• Written notice to the last known address of registration.
• In-person notification during any interaction with MVD migration offices or law enforcement.

The foreign national has 15 days from the date of notification to regularize their status (by obtaining a valid document, filing an extension, or departing Russia). If they fail to do so, the restrictions described below take effect.

Restrictions Imposed

Once the 15-day grace period expires without regularization, the person classified as "controlled" faces the following restrictions under Federal Law No. 637-FZ:

Civil Rights

• Marriage: The individual cannot register a marriage at a Russian civil registry office (ZAGS). Any marriage application filed by or with a person on the registry will be refused.
• Property transactions: The individual cannot purchase, sell, or register ownership of real estate or vehicles. Notaries and the Rosreestr (Federal Service for State Registration) are required to check the registry before processing any transaction involving a foreign national.
• Legal proceedings as plaintiff: The individual retains the right to legal defense and may be a defendant or witness in court proceedings, but their ability to initiate civil lawsuits is restricted.

Financial Rights

• Bank accounts: Banks and other financial institutions are prohibited from opening new accounts or issuing new bank cards to individuals on the registry. Existing accounts are not automatically frozen, but new deposits exceeding 30,000 rubles per month may be flagged for MVD review.
• Money transfers: The individual is prohibited from sending international money transfers through banks or licensed transfer services. Informal transfer channels (hawala-type systems) are unaffected in practice, though they are separately illegal.
• Loans and credit: Financial institutions may not issue loans, mortgages, or credit lines to individuals on the registry.

Employment

• Work prohibition: The individual may not be legally employed by any employer, including under a work patent or work permit. Employers who knowingly hire a person on the registry face fines of 250,000 to 800,000 rubles per violation under Article 18.15 of the Code of Administrative Offences.

Social Services

• Education: The individual may not enroll in educational institutions (schools, universities, vocational training). Children under 18 who are dependents of a person on the registry retain their right to basic education under Russia's international obligations.
• Healthcare: Emergency medical care remains available under Federal Law No. 323-FZ "On the Basics of Healthcare." However, scheduled and elective medical services at public facilities are unavailable.

Mobility

• Vehicle registration: The individual cannot register vehicles or obtain or renew a Russian driver's license.
• SIM cards: The law restricts the purchase of new SIM cards, as telecommunications operators are required to verify immigration status. Existing SIM cards remain functional.

Removal from the Registry

A person is removed from the registry when they:

1. Depart Russia: Confirmed departure through border control records. This also triggers the applicable entry ban (three, five, or ten years, depending on the severity of the violation).
2. Regularize their status: Obtain a valid immigration document (visa, work patent, RVP, VNZh) and present it to the MVD migration office.
3. Receive a court order: A Russian court may order removal from the registry in specific circumstances, such as pending asylum claims or humanitarian considerations.

Importantly, departure from Russia does not erase the record. The individual's registry history is permanently recorded in the Unified Migration Database and will be considered in any future visa or entry applications.

Scale of the Problem

Official estimates suggest a significant number of foreign nationals in Russia are in an irregular situation. MVD statistics from 2024 indicate:

• Approximately 800,000 to 1.2 million foreign nationals were estimated to be residing in Russia with expired or invalid immigration documents.
• The largest groups by nationality were citizens of Uzbekistan, Tajikistan, Ukraine, Azerbaijan, and Kyrgyzstan.
• In 2024, approximately 350,000 administrative violation protocols were issued for immigration offenses under Articles 18.8 through 18.10 of the Code of Administrative Offences.

The registry system is designed to transition enforcement from case-by-case administrative actions to a systematic, automated mechanism.

Practical Implications

For Foreign Nationals Currently in Russia

Those who suspect they may be in an irregular situation should take immediate steps:

1. Check your status: The RuID application now includes a function to verify immigration status. Alternatively, visit the MVD migration office in person.
2. Seek legal advice: A licensed migration attorney can assess options for regularization before the 15-day grace period expires.
3. Do not ignore notifications: Failure to respond to a registry notification accelerates the imposition of restrictions and may result in a longer entry ban upon departure.

For Employers

Employers are now required to verify the immigration status of foreign employees through the MVD's electronic verification system. Hiring a person on the registry carries significant financial penalties and may result in suspension of the employer's right to hire foreign workers.

For Family Members

Russian citizens married to or in relationships with foreign nationals should be aware that the registry restrictions can affect joint property, shared bank accounts (new accounts only), and family planning (marriage registration).

Comparison with Other Countries

The registry system draws comparisons with similar mechanisms elsewhere:

• United States: Individuals with final removal orders face restrictions on employment authorization and certain public benefits, though marriage and banking rights are generally not affected.
• European Union: The Schengen Information System (SIS) flags individuals for entry bans and alerts, but individual member states apply varying levels of civil restrictions.
• Gulf States (UAE, Saudi Arabia, Qatar): These countries maintain robust systems linking immigration status to nearly all civil and economic activities, which is the model closest to Russia's new approach.

Russia's system is notable for the breadth of restrictions it imposes simultaneously and the speed with which they take effect.

Key Legal References

• Federal Law No. 636-FZ of December 28, 2024, amending Federal Law No. 115-FZ.
• Federal Law No. 637-FZ of December 28, 2024, amending various legislative acts.
• Code of Administrative Offences, Articles 18.8 through 18.15.
• Federal Law No. 323-FZ of November 21, 2011, "On the Basics of Healthcare in the Russian Federation."

The creation of the registry signals a deliberate move toward stricter and more automated immigration enforcement. Foreign nationals in Russia should ensure their documentation is current and seek professional guidance if there is any uncertainty about their status.