Hiring EAEU Citizens in Russia Without a Work Permit. What Actually Changed for Employers in 2026
For years, the lack of a work-patent requirement for citizens of Armenia, Belarus, Kazakhstan, and Kyrgyzstan created an illusion of simplicity for HR departments. Since no patent is required, onboarding presumably takes one day and needs no deadline tracking. It is precisely this illusion that is currently costing companies dearly: the shortened period of visa-free stay, a new Ministry of Internal Affairs (MIA) notification form, and a five-tier personal income tax (PIT) scale apply to EAEU citizens just as they do to other foreign nationals. A mistake at any of these points results in a fine or the loss of a specialist in the middle of a project.
The Treaty on the EAEU exempts employers from work quotas and employment permits. Migration registration, tax reporting, and social insurance contributions remain fully the employer’s responsibility. The overall volume of paperwork for an EAEU citizen in 2026 is roughly the same as before. What has changed is its content: every single point now requires separate monitoring.
How EAEU Citizens Were Hired Before 2025
Prior to 1 January 2025, the «90 out of 180 days» rule applied: a visa-free foreign national, including an EAEU citizen without an employment contract, could stay in Russia for 90 days within any 180-day period, after which they were required to leave the country. This setup allowed job seekers to stretch their job search over several months by repeatedly exiting and re-entering the country.
Employers submitted employment notifications using the form in Appendix No. 7 to Order No. 536 of the Ministry of Internal Affairs of Russia, dated 30 July 2020. That form did not allow for specifying multiple actual work addresses, so employees working across multiple sites in different regions were formally registered under only one address.
Personal income tax on the earnings of EAEU citizens was withheld at «tax-resident» rates starting from their first day of work, as prescribed by Article 73 of the Treaty on the EAEU dated 29 May 2014. One risk remained: if, by the end of the year, an employee had not accumulated 183 days of physical presence in Russia and failed to confirm tax residency status, the employer had to recalculate the tax at a 30% rate and demand additional payment from the worker. Disputes over the recalculation often emerged only after the employee had already resigned, leaving no practical way to recover the unpaid amount.
Employers paid pension and medical insurance contributions for EAEU citizens on standard terms from the first day of the employment contract, since Article 96 of the Treaty on the EAEU places them on equal footing with Russian workers for social insurance purposes.
Another distinct feature that still applies today: EAEU citizens, alongside citizens of Ukraine, are the only foreign nationals legally permitted to register as self-employed and pay professional income tax. This right is established by Part 3 of Article 5 of Federal Law No. 422-FZ dated 27 November 2018. For a job seeker from Kazakhstan or Armenia who is looking for work while taking on one-off assignments, self-employment is a fully legal way to earn income before an employment contract is signed.
For comparison, a visa-required foreign national or a patent worker from a visa-free non-EAEU country needs a separate work permit or patent, monthly advance PIT payments, and verified proficiency in the Russian language, history, and basic legislation. None of these requirements apply to EAEU citizens. This is exactly why HR departments have grown used to treating the hiring of workers from Armenia, Belarus, Kazakhstan, and Kyrgyzstan as a formality that needs no dedicated oversight.
What Changed in 2025 and 2026
Three reforms took place in parallel, affecting distinct links in the same chain: migration registration, taxes, and social contributions.
| Parameter | Before 2025 | From 2025-2026 |
|---|---|---|
| Period of stay without an employment contract | 90 days out of 180 | 90 days per calendar year |
| MIA employment notification form | Appendix No. 7 to Order No. 536, single work address | Same form as amended by Order No. 552, field for multiple addresses |
| EAEU non-resident PIT at year-end | Risk of recalculation at a 30% rate | The 13-22% rate is preserved regardless of tax residency status |
| Maximum base for social contributions | Below 2025 levels | RUB 2,759,000 in 2025; RUB 2,979,000 in 2026 |
Period of Stay and MIA Notifications
Federal Law No. 260-FZ dated 8 August 2024 (hereinafter, FL No. 260-FZ) amended Article 5 of Federal Law No. 115-FZ dated 25 July 2002, «On the Legal Status of Foreign Citizens in the Russian Federation» (hereinafter, FL No. 115-FZ). Starting 1 January 2025, a visa-free foreign citizen without other legal grounds to stay is entitled to remain in Russia for no more than 90 days within a calendar year, rather than 90 out of 180 days as before. The count resets every year on 1 January.
For an EAEU citizen who is already employed, this rule is not critical: a signed employment contract remains valid grounds to stay in the country for its full term, typically up to one year with the option to renew. The restriction hits candidates during the job search and those temporarily left without a contract. After dismissal, an EAEU citizen has 15 days to sign a new employment contract in order to avoid leaving Russia. An employer taking on such a candidate should check the date of their last dismissal and confirm the 15-day window has not expired.
Violating the permitted period of stay, including exceeding the new annual limit, is penalised under Article 18.8 of the Code of Administrative Offences of the Russian Federation (CAO RF). In practice this means a fine and, on repeat violation, a requirement to leave the country along with an entry ban. For the employer, this is a direct staffing risk: a candidate who breached the migration regime before employment may receive an entry ban after the parties have already agreed on a start date. The company then loses only time and recruiting costs, even though the HR department was not at fault.
As of 1 September 2025, an updated form applies for notifying the MIA of the execution and termination of employment contracts with foreign citizens, approved by MIA Order No. 552 dated 6 August 2025 (hereinafter, Order No. 552), which amended Appendices No. 7 and No. 9 to Order No. 536. The main change in the form is an extra field for entering multiple actual work addresses. It is aimed primarily at foreign nationals working under a patent in two regions at once (Article 13.3 of FL No. 115-FZ). The updated form is nonetheless mandatory for notifications covering all categories of foreign workers, including EAEU citizens. Submitting the old form after 1 September 2025 counts as a violation of the established notification procedure.
The territorial MIA body at the employee’s place of work must be notified no later than three business days from the date the contract is signed or terminated. Liability for missing this deadline or using the wrong form is set out in Article 18.15 of the CAO RF: for legal entities, a fine of 400,000 to 800,000 rubles, or suspension of activity for 14 to 90 days. In Moscow, Saint Petersburg, and the Moscow and Leningrad regions, the fine for legal entities is higher: 400,000 to 1,000,000 rubles under Part 4 of the same article. Notifications are filed separately for each employee, so a systematic error in HR can trigger fines across dozens of violations at once.
Hiring citizens of Belarus raises a separate question. The stay of Belarusian citizens in Russia is governed both by the EAEU Treaty and by a separate treaty on the Union State, so lawyers hold no single position on whether the MIA must be notified of contract execution and termination for them. The view that notification is not required comes up often. No official clarification from the MIA exists on this point. Paragraph 8 of Article 13 of FL No. 115-FZ formally makes no exception for citizens of Belarus, so it is safer to notify the MIA for this category of workers too rather than rely on a disputed interpretation and risk a fine under Article 18.15 of the CAO RF.
Taxes and Social Contributions
Starting 1 January 2025, a five-tier personal income tax scale introduced by Federal Law No. 176-FZ dated 12 July 2024 is in effect: 13% on income up to RUB 2.4 million a year, 15% on the portion between RUB 2.4 and 5 million, 18% on the portion between RUB 5 and 20 million, 20% on the portion between RUB 20 and 50 million, and 22% on the portion above RUB 50 million. The higher rate applies only to the amount above each threshold, not to the whole income. For an employee with an annual income of RUB 6 million, the calculation works out as follows: RUB 2.4 million is taxed at 13% (RUB 312,000), the next RUB 2.6 million up to the RUB 5 million mark is taxed at 15% (RUB 390,000), and the remaining RUB 1 million is taxed at 18% (RUB 180,000). For EAEU citizens, this scale applies from day one of employment regardless of tax status. That follows directly from Article 73 of the EAEU Treaty.
Until the end of 2025, the risk of recalculation remained: if an EAEU worker did not confirm tax residency status by year-end, some tax authorities insisted on recalculating PIT at a 30% rate. Federal Law No. 425-FZ dated 28 November 2025 closed this question. Starting 1 January 2026, Clause 3.1 of Article 224 of the Tax Code of the RF states directly that employment income of EAEU citizens is taxed under the progressive 13-22% scale with no year-end recalculation to 30%, even if tax residency status is never confirmed. The same rule now applies to patent workers and highly qualified specialists (HQS), so payroll no longer needs to hold back funds for a possible year-end adjustment in December.
Employers pay social insurance contributions for EAEU citizens at a single unified rate from the first day of the employment contract: 30% within the maximum base and 15.1% on amounts above it. Government Decree No. 1457 dated 31 October 2024 set the maximum contribution base for 2025 at RUB 2,759,000 per employee on a cumulative basis; for 2026 it rises to RUB 2,979,000. Paying these contributions gives the EAEU citizen access to compulsory health insurance (CHI), so a separate voluntary health insurance (VHI) policy, mandatory under Article 327.3 of the Labor Code of the RF at the time the contract is signed, does not need to be renewed once the first contributions have been made.
Growth in social payouts is also worth building into the budget. Insurance pensions were indexed on 1 January 2025 by 9.5% under Government Decree No. 34 dated 23 January 2025, above the initially planned 7.3%, because actual 2024 inflation ran ahead of the forecast and the extra payment to pensioners was backdated to January. For EAEU citizens, the indexation means a larger volume of pension rights accrued in Russia, which are eligible for export to their home country on reaching retirement age.
Hiring Medical and Pharmaceutical Specialists
Diplomas issued in EAEU member states do not require nostrification (formal academic recognition) for most professions; a notarised translation is enough. Medicine and pharmacy are the exception. A worker holding a diploma as a physician, pharmacist, or pharmaceutical specialist from Kazakhstan, Armenia, Kyrgyzstan, or Belarus must go through recognition of their education and accreditation before starting work with patients or in a pharmacy.
Accreditation is governed by Ministry of Health Order No. 709n dated 28 October 2022. Periodic accreditation runs through the Federal Accreditation Centre every five years and includes 144 hours of continuing professional education, paid for by the employer. The application and supporting documents go through the Federal Register of Medical and Pharmaceutical Workers, part of the Unified State Information System in Healthcare (EGISZ). Without completed accreditation, a specialist is not allowed to practise, and an employee already working must be suspended until accreditation is complete.
Mid-level medical staff who graduated from a medical college in an EAEU country go through a simplified diploma-recognition procedure. Accreditation before starting a shift is mandatory for this category of specialist as well. Employers planning to hire a physician, pharmacist, or nurse from an EAEU state should build extra lead time into the hiring schedule: recognition of the diploma and accreditation run through several sequential steps and rarely fit into a standard two-to-three-week onboarding window.
Action Plan for Employers
Check the candidate’s migration history. Confirm their entry date into Russia and the date of their last dismissal, if any. For a candidate without an employment contract, count the 90-day stay from the start of the calendar year. For a recently dismissed EAEU citizen, check whether the 15-day window to find a new employer has expired. A candidate who has already used up the annual limit can only be hired after the new calendar year begins, or after legalising their status by other means.
Use the current MIA notification form. From 1 September 2025, complete Appendix No. 7 to Order No. 536 as amended by Order No. 552. If an employee works at several sites in one region, or under a patent in two regions, list every address and file notifications with each territorial MIA office covering those locations. Do not rely on informal claims of an exception for citizens of Belarus; notify the MIA for this group too.
Set up PIT calculations on the progressive scale from day one. Confirm that your payroll system applies the 13-22% rates to EAEU citizens’ earnings without waiting for residency confirmation. As of 1 January 2026, there is no need to hold back funds for a possible 30% recalculation. For the 2025 tax year, tracking residency status through 31 December is still required.
Recalculate the 2026 social contributions budget. Factor in the rise in the maximum base to RUB 2,979,000 and check that sick-leave and holiday-pay calculations reference the current figures rather than 2025 ones. Confirm that a VHI policy is in place when the contract is signed, and that the move to CHI coverage is recorded once the first contributions are made.
Build in time for accreditation on medical and pharmaceutical vacancies. When hiring a physician, pharmacist, or nurse from an EAEU state, start the diploma-recognition process and submit documents to the Federal Accreditation Centre well ahead of the planned start date. Budget for the mandatory 144 hours of continuing education, which the employer pays for.
Hiring an EAEU citizen remains faster and cheaper than hiring a visa-required foreign national or a patent worker. The 2025-2026 reforms did remove the main advantage of the old approach: the freedom to ignore deadlines. Companies that have built the 90-day limit, the current notification form, and the progressive PIT scale into their HR checklist pass MIA and tax audits without fines. The rest find out about a violation only once it is too late to fix.
For holdings with a distributed branch network, it is worth assigning someone responsible for migration compliance in every region of operation rather than relying on head office alone. Order No. 552 requires notifying the territorial MIA office at the employee’s actual place of work, and the fine under Part 4 of Article 18.15 of the CAO RF is assessed per employee. When using contractors or staffing agencies, ask them to confirm that notifications have been filed: regulators increasingly apply a «de facto employer» concept and hold the client company liable for a contractor’s violations if the foreign workers were operating under the client’s direct supervision.
Regulatory Framework:
1. Treaty on the Eurasian Economic Union dated 29 May 2014 (Art. 73, 96, 97)
2. Federal Law No. 115-FZ dated 25 July 2002, «On the Legal Status of Foreign Citizens in the Russian Federation»
3. Federal Law No. 260-FZ dated 8 August 2024, «On Amendments to Certain Legislative Acts of the Russian Federation»
4. Order of the Ministry of Internal Affairs of Russia No. 536 dated 30 July 2020 (as amended by Order No. 552 dated 6 August 2025)
5. Code of Administrative Offences of the Russian Federation No. 195-FZ dated 30 December 2001 (Art. 18.15)
6. Labor Code of the Russian Federation (Art. 327.1-327.3)
7. Federal Law No. 176-FZ dated 12 July 2024 (progressive PIT scale)
8. Federal Law No. 425-FZ dated 28 November 2025 (removes 30% PIT recalculation for EAEU citizens from 2026)
9. Government Decree No. 1457 dated 31 October 2024 (maximum base for social contributions in 2025)
10. Government Decree No. 34 dated 23 January 2025 (indexation of insurance pensions)
11. Order of the Ministry of Health of Russia No. 709n dated 28 October 2022 (accreditation of medical and pharmaceutical workers)