Experiment on tracking migrants through a mobile app

On May 23, 2025, the Russian President signed a Federal Law,[1] which starts an experiment on introducing new ways of registering foreign citizens (and stateless persons) on the territory of Russia starting from September 1, 2025. The experiment will be implemented on the territory of Moscow and Moscow Region and will last 4 years – until September 1, 2029.

The participants of the experiment will be foreign citizens staying in Russia as per the regime that does not require a visa, whether for employment or for purposes not related to employment for a period of more than 90 days, with the exception of persons under age 18, citizens of the Republic of Belarus, diplomatic staff and their family members, officials of international organizations and their family members (subject to additional conditions), as well as persons residing in Russia with a permanent or temporary residence permit.

At the same time, in respect to foreign citizens staying for purposes not related to labor activity, the experiment will be valid from September 1, 2026.

The essence of the experiment is that the participants need to register in a mobile app through which they will provide information about the place of their actual location, except when staying in hotels, sanatoriums, rest homes, camping, medical organizations and so on.

If there is no information on the geolocation of the participant of the experiment for more than 3 work days from the date of the last monitoring, the foreign citizen will be deregistered. If by that time the participant of the experiment has no grounds for staying on the territory of Russia, they are subject to inclusion in the register of controlled persons.[2]

Note that foreigners included in the register of controlled persons are subject to the expulsion regime, under which controlled persons, in particular, are not allowed to drive, to open bank accounts and carry out other banking operations (except for transfers for the purpose of making compulsory payments, transfers in the amount of no more than 30 thousand rubles per month), to change their place of residence or place of stay in Russia without appropriate authorization. If the expulsion regime is violated on more than one occasion, the controlled person may be subject to deportation.

In order to implement the experiment, those foreign citizens who are on record with the migration authorities at their place of stay in Moscow or the Moscow Region at the time the law takes effect, will be obliged to register in the system within 30 days from the date the registration period expires, provided they have legal grounds to stay in Russia. If foreign citizens are legally present on the territory of the experiment and are not in the migration register, they are obliged to register no later than 90 days from the date the law introducing the experiment takes effect.

The provisions on migration registration will not apply on the territory of the experiment, except in respect to foreign nationals staying in hotels and other similar organizations. If a foreign citizen leaves the territory of the experiment, they will be subject to migration registration.

The regulations on the procedure of registration and its implementation will be adopted additionally.

Possibility for foreigners to work under one patent in neighboring Russian regions

Since September 1, 2025 the above-mentioned Federal Law[3] also provides the possibility for foreign citizens to work under one patent in two neighboring subjects of the Russian Federation in the city of Moscow and Moscow Region, as well as in the city of St. Petersburg and Leningrad Region.

For now, however, this is merely a possibility. Such a right will take effect for foreign citizens if these regions of the Russian Federation sign an appropriate agreement. These agreements may limit the list of occupations for persons authorized to work in the two regions, limit the hours of work and set other conditions.

Currently, such agreements have not been signed; if they are signed, such agreements must be published on the official web sites of the region's supreme executive authorities and will become effective 15 days from the date of publication.

A special procedure for submitting migration notifications will be defined for these workers.

We will keep an eye out for further developments.

We hope you find this information useful.

Additional information

This overview was prepared by Natalia Ryabova, senior associate, Svetlana Alexeeva, associate, and Vadim Strushko, associate, of the CLS Corporate practice.

Should any questions arise in connection with the above or if you need any additional materials, please contact the CLS office in St. Petersburg or Moscow.

This information letter keeps clients of CLS and other interested parties abreast of information that may, to some extent, affect their activity or cater to their interests. The opinions and commentaries expressed in this information letter shall not be deemed legal advice and do not cancel the need to obtain legal advice or legal opinion on separate issues.

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