HQS (highly qualified specialists) entry into the Russian Federation under the COVID-19 pandemic restrictions

We kindly remind you that the restrictions on entry into the Russian Federation for foreign citizens are still in force. These restrictions are provided by the order of the government of the Russian Federation dated March 16, 2020 No. 635-r (as amended by the Government order dated 14.10.2020 No. 2649-r).

Currently most of foreigners are not allowed to enter the Russian Federation, with the exception for citizens or those who are entitled to permanent residence of the following countries:

  • United Kingdom
  • Tanzania
  • Turkey
  • Switzerland
  • Egypt
  • Cuba
  • Maldives
  • United Arab Emirates
  • Kazakhstan
  • Kyrgyzstan
  • The Republic of Korea
  • Serbia
  • Japan

As for the citizens of other countries, certain categories can also cross the border of the Russian Federation:

  • Diplomats and their family members;
  • Pilots and drivers, crew members of international cargo and passenger traffic;
  • Family members of Russian citizens;
  • Foreign citizens with a residence permit of the Russian Federation;
  • Persons involved in adjustment and technical maintenance of foreign-made equipment (visa type “Technical maintenance”);
  • Persons entering the Russian Federation for treatment purposes;
  • Employees (highly qualified specialists) who have employment (or civil) contracts signed – at the request of the employer;
  • Some other special categories of foreign citizens.

Conditions of entry

In this section we consider the details of obtaining a permission to enter Russia for highly qualified specialists. It is subject to several conditions:

  1. Only single entry is allowed. This means that if a foreign employee enters the country having a work visa and being on the approved list (described in more detail below), and then leaves it, the next entry is possible only after the Government of Russia officially opens the border for foreigners. This is the official position which is also reflected in the current version of the Government Decree No. 635-r. However, there are rare cases when re-entry is validated (under exceptional health-related circumstances, due to high significance of the project in which the specialist is involved and other important factors). However, it is currently impossible to guarantee such re-approval.
  2. Entry is only allowed after receiving the appropriate approval. Usually a full list of foreign citizens whose employers have submitted an application within a certain period of time is agreed at once. Currently there are two options for obtaining approval:
    Option 1: through the Ministry that controls the company's activities;
    Option 2: through the Operational Headquarters under the Government of the Russian Federation. It is possible to apply to the Government both directly with an application for approval of entry (recommended if the Ministry that controls the company's activities refuses to assist), or through a list formed by the association the employer belongs to (e.g. AEB or CCIFR).
  3. Entry is allowed to highly qualified specialists only and not to their family members. There also were exceptions to this issue, but for those family members who already have entry visas.

Approval of entry

As noted above the procedure may vary depending on the chosen option for obtaining approval.

Currently the list of actions for Option 1 includes the following:

First, you should determine the Ministry that controls the activities of your company according to the OKVED code for the main type of activity. You can find the full list of Ministries here: http://government.ru/ministries/.

The employer makes an official request to the Ministry, prepares all the necessary information and the corresponding cover letters to justify the entry.

The following information on entering persons is required:

  • passport,
  • assumed date (or period) of entry and checkpoint of entry,
  • address of intended residence in Russia,
  • route of travel,
  • valid employment contract.

It is recommended to choose air checkpoints of the Russian Federation, i.e. airports.

Since the regulations for approval in the Ministries are not set, there are no fixed terms for it. Usually it takes 10-15 days which may vary depending on a Ministry.

Entry is only possible with a signed employment contract.

Given this condition, the following options may exist:

  • The foreign specialist already has an HQS work permit and a work visa.

In this case the expat will be able come to the Russian Federation immediately, as soon as the information on the approval arrives at the Federal Air Transport Agency and the Border Control of the Federal Security Service (FSB) at the state border checkpoint indicated in the application.

  • At the time of filing the foreign specialist does not have an HQS work permit and a work visa - only an employment contract.

In this case after receiving the approval from the Ministry, a work permit and an invitation should be obtained to get a work visa for entry (Ministry of Internal Affairs also receives the information on approval). The documents are provided within 14 working days. Entry is possible after obtaining a work visa at the relevant Russian Consulate abroad.

Mazars strongly recommends to check the availability of information on the HQS employee with the relevant airline (the information should be transferred by the Federal Air Transport Agency).

Option 2 has its own features which are described below.

Companies that are members of associations such as the Association of European Businesses (AEB) and the Franco-Russian Chamber of Commerce (CCIFR) can apply for the entry of highly qualified specialists through them. The lists are submitted directly to the Operational Headquarters under the Government of the Russian Federation (hereinafter referred to as the “Operational Headquarters”).

In addition, the company has the right to apply to the Operational Headquarters directly indicating the reason for sending the application.

The terms of approval by the Operational Headquarters may be longer those of the Ministries.

In addition, unlike the Ministries, the Operational Headquarters does not further transmit the information on approval to other bodies. The Federal Air Transport Agency, the Border Control of the FSB and the Ministry of Internal Affairs are to be notified independently by sending information about the approval through electronic channels. This should be done no later than 5 working days before entering the Russian Federation.

Before boarding

According to the current version of the Resolution of the Chief State Sanitary Doctor of the Russian Federation dated March 18, 2020 No 7, when boarding an aircraft that performs an international air transportation to the territory of the Russian Federation, foreign citizens and stateless persons are obliged to have a medical document (in Russian or English) confirming a negative swab test result for COVID-19.

The person must be tested and the medical document should be issued no earlier than three days before boarding the plane.

After entering the Russian Federation

As per the current version of the Decree of the Chief State Sanitary Doctor of the Russian Federation dated March 30, 2020 No. 9 foreign citizens and stateless persons arriving in Russia for work purpose should follow quarantine requirements for a period of 14 calendar days from the date of arrival.

In addition, foreign citizens are subject to all other anti-epidemic requirements and restrictions provided by the acts of both federal and regional authorities (mask regime, etc.).

It should be noted that if a foreign highly qualified specialist stays in the Russian Federation for more than 90 days (continuously), migration registration must be performed.

Mazars team is ready to advise in more detail on individual cases, help passing through the multi-stage procedure of approval, entry, work permit and invitation for a highly qualified specialist.

We are constantly monitoring the updates and will keep you informed on any changes in the procedures - follow our news on the website and social media.

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