New Notification Forms for Foreign Employees
From 1 September 2026, employers will be required to use new notification forms for foreign employees.
Order No. 290 of the Russian Ministry of Internal Affairs, dd. 12.05.2026, has approved new notification forms, which must be used from 1 September 2026.
The changes will affect virtually all employers who hire foreign staff, including companies employing highly qualified specialists (HQS).
Which forms will change
From 1 September 2026, the following updated forms will apply:
- application by a foreign national (or stateless person) to be employed as an HQS
- notification of the employment of a foreign national by an organisation providing employment services
- notification of an employer’s fulfilment of obligations to pay wages to an HQS
- notification of the conclusion of an employment contract or a civil law contract with a foreign national
- notification of the termination (cancellation) of an employment contract or a civil law contract with a foreign national.
What employers need to know
1. Separate consent to the processing of personal data (PD) becomes mandatory
The most significant change relates to the requirements of data protection legislation.
From 1 September 2026, notifications concerning:
- conclusion of an employment contract;
- termination of an employment contract;
- payment of wages to foreign nationals,
must be accompanied by a separate consent form from the foreign national for the PD processing.
Previously, consent was included directly in the text of the notification. This is no longer sufficient.
The change stems from the provisions of Federal Law No. 156-FZ of 24.06.2025, which have come into force, stipulating that consent to the PD processing must be set out as a separate document and may not be included as part of other documents.
2. The notification of employment will need to specify the term of the contract
When completing the notification of the conclusion of an employment contract or a civil law contract, employers will need to specify the term of the contract.
3. Changes to the procedure for filing HQS reports
When filing a notification confirming compliance with wage payment obligations to an HQS, employers will be required to state the foreign employee’s TIN.
At the same time, the following information has been removed from the form:
- details of the profession (position)
- details of the territory covered by the HQS’s work permit.
What should be done currently
We recommend that employers take the following steps in advance:
- check current notification templates
- prepare separate consent forms for the processing of foreign employees’ personal data
- update internal procedures for migration record-keeping
- amend HR processes and instructions for staff responsible for migration support
- conduct an audit of migration document workflows to avoid errors after 1 September 2026.
