The Controlled Persons Register: A Complete Guide

What Is the Controlled Persons Register

Since 2025, Russian immigration legislation has shifted towards a model of preventive digital enforcement. The central instrument of this system is the Controlled Persons Register — a state information system that consolidates data on foreign nationals whose presence in Russia has been deemed unlawful.

The legal basis for the Register is established in Article 31.2 of Federal Law No. 115-FZ. Under the letter of the law, the Register is not merely a database; it is the legal mechanism through which the so-called "expulsion regime" is implemented.

Inclusion in the Register automatically restricts the individual's legal capacity. From the moment of inclusion, the foreign national is effectively excluded from full participation in civil and commercial life until either the grounds for the immigration violation have been remedied or the individual has physically departed from Russian territory.

The Register is administered by the Russian Ministry of Internal Affairs and is technically integrated into the state migration registration information system, which enables records on foreign nationals to be generated automatically on the basis of data received from other government agencies.

Grounds for Inclusion in the Register

"Controlled person" status is assigned to a foreign national or stateless person upon the occurrence of certain legal events indicating the absence of a lawful basis for their presence in Russia. Under Article 31.2 of Federal Law No. 115-FZ, the inclusion procedure is triggered automatically upon detection of an immigration violation.

The principal grounds for entry into the Register are as follows.

1. Expiry of the authorised period of temporary stay applies where the foreign national has not departed Russian territory upon the expiry of their visa or the permitted visa-free period, including the "90 out of 180 days" rule.
2. Cancellation of authorisation documents covers the revocation of a temporary residence permit, permanent residence permit, work patent, or work permit.
3. Reduction of the permitted period of stay is initiated by a Ministry of Internal Affairs decision to curtail the individual's time in Russia in connection with the commission of an offence or a change in the circumstances that originally justified their entry.
4. Decisions on expulsion encompass administrative removal orders, deportation orders, and declarations that a person's presence in Russia is undesirable.
5. Finally, unlawful presence covers cases where the individual was found to have crossed the border using forged documents or through an unauthorised crossing point.

All records are entered by the Ministry of Internal Affairs automatically through inter-agency data exchange — without any application by the foreign national and without individual notification. The moment of inclusion in the Register simultaneously marks the commencement of the expulsion regime.

Legal Consequences and Restrictions: The Expulsion Regime

Inclusion in the Register automatically activates the expulsion regime — a special legal status designed either to secure the foreign national's departure from Russia or to facilitate the legalisation of their stay. The expulsion regime is not equivalent to immediate deportation: the individual remains on Russian territory but is subject to a broad range of restrictions.

In the area of property transactions, there is an absolute prohibition on the acquisition and registration of real estate and motor vehicles. The individual may not act as a party to any purchase, sale, gift, or pledge transaction. With regard to vehicle use, controlled persons are prohibited from driving motor vehicles, are barred from taking driving licence examinations, and any existing licences — whether Russian or international — are rendered invalid for the duration of their inclusion in the Register. Financial restrictions require banks to refuse the opening of new accounts for such individuals, while withdrawals from existing accounts are capped at 30,000 roubles per month for personal needs. In terms of civil status, the registration of marriages is prohibited, as is registration as a sole trader or as a founder or participant in a legal entity. With respect to freedom of movement, the individual is required to remain within the boundaries of the Russian region in which they were registered. Departures from that region are permitted only for the purpose of travelling to a border crossing point to leave the country, and any change of location requires prior approval from the Ministry of Internal Affairs.

All of these restrictions apply automatically from the moment the record is entered into the Register and remain in force until the individual is removed from it.

Obligations of a Person Included in the Register

Controlled person status imposes a number of affirmative obligations on the foreign national. The expulsion regime requires not only passive compliance with the prohibitions described above, but also regular engagement with the internal affairs authorities to ensure ongoing monitoring of the individual's whereabouts.

The individual is required to notify the territorial body of the Ministry of Internal Affairs of their actual place of residence and of any change of address, with such notification to be submitted within the period prescribed by law — generally no later than the following business day. When planning to depart from Russia, the individual must inform the supervising authorities in advance of the date, time, and border crossing point through which departure will be made. The individual is obliged to appear before the Ministry of Internal Affairs or other competent authorities upon request — whether by summons or other notification — for the purposes of supervision and control. If not previously completed, the individual must undergo mandatory fingerprinting and photography by the state authorities. Finally, should circumstances arise that objectively prevent timely departure from Russia — such as a serious medical condition or force majeure — the individual is required to notify the Ministry of Internal Affairs immediately and to provide supporting documentation.

Failure to comply with these obligations is treated as a flagrant violation of the immigration regime and may serve as grounds for the application of more stringent measures, including detention in a dedicated Ministry of Internal Affairs facility pending actual deportation.

How to Check Whether a Person Is in the Register

The Register is publicly accessible in so far as it concerns the fact of a specific individual's inclusion. Any natural person or legal entity may conduct a check — without registration and without special authorisation.

Queries may be submitted through one of two channels: the interactive form on the official website of the Russian Ministry of Internal Affairs at mvd.rf/rkl, or the Unified Portal of State and Municipal Services at gosuslugi.ru/655781/1. In both cases, the system operates on a query-and-response basis: the user enters the required details, and the system returns one of two responses — either confirming the presence of a record in the Register, or confirming its absence.

To conduct a search, the user must enter the foreign national's surname, first name, and patronymic (if applicable), date of birth, and the series, number, and date of issue of their identity document. It is essential that the data entered matches the document exactly, as any discrepancy in the spelling of the name or document number may produce an inaccurate result.

The database is updated every four hours. Following any amendment to the Register, the updated information is automatically transmitted within 24 hours to banks and other organisations that are required to enforce the expulsion regime restrictions.

The legislation does not provide for individual notification of inclusion in or removal from the Register. A foreign national is deemed to have been notified from the moment the information is published on the Ministry of Internal Affairs website. This means that unawareness of one's inclusion does not exempt the individual from the obligations arising under the expulsion regime and does not constitute grounds for challenging the restrictions applied.

For Russian companies and sole traders, checking counterparties and employees against the Register has become an essential element of due diligence. Entering into a contract with a person included in the Register carries real risks — ranging from the inability to process payments through a bank to potential accusations of facilitating unlawful migration.

How to Be Removed from the Register

The grounds for removal from the Register are set out in paragraph 7 of Article 31.2 of Federal Law No. 115-FZ and are likewise exhaustive. Removal, like inclusion, takes place automatically — no later than one business day from the moment the relevant information reaches the Ministry of Internal Affairs.

The most straightforward ground is physical departure: when a foreign national leaves Russia and crosses the state border, the border services transmit that information to the Ministry of Internal Affairs, triggering automatic removal from the Register.

Where a foreign national regularises their status — by obtaining a visa, a temporary residence permit, a permanent residence permit, or any other document conferring the right to remain — they are to be removed from the Register. The same applies to the issuance of a temporary identity document to a stateless person under Article 5.2 of Federal Law No. 115-FZ.

If a decision to cancel authorisation documents, to deport, to declare a person's presence undesirable, or any other administrative decision is overturned by a higher authority, the basis for the individual's presence in the Register ceases to exist. Where, rather than administrative reversal, a court declares the underlying decision unlawful, removal from the Register takes effect from the date the relevant court ruling enters into legal force. Upon receipt by the Ministry of Internal Affairs of information concerning the death of an individual, or of a court order declaring the person legally deceased, the record is removed from the Register.

In all cases other than physical departure, the foreign national must themselves take active steps to legalise their status or to challenge the relevant decision. The system's automated functionality operates only to the extent that the necessary information has actually been received by the Ministry of Internal Affairs. If documents have been submitted and obtained but the record has not been removed, the foreign national is entitled to apply directly to the territorial body of the Ministry of Internal Affairs requesting removal.

To initiate removal, the foreign national applies to the local Migration Affairs Division at their place of actual residence, presenting documents confirming the lawfulness of their stay and compliance with their immigration obligations. These typically include a valid work patent, a migration card, migration registration documents, receipts confirming advance patent payments, and documents evidencing the completion of a medical examination and fingerprinting.

Consequences for Employers

The introduction of the Register has materially altered the position of employers who engage foreign workers. The mere fact that an employee has been included in the Register does not automatically constitute grounds for termination of the employment contract — the critical factor is the reason for inclusion.

An employer is required to independently verify whether a foreign employee or job applicant appears in the Register before concluding any employment or civil law contract, and to repeat that check during the course of the employment relationship whenever the employee's immigration status changes. Ignorance of an individual's inclusion in the Register does not exempt the employer from liability: the courts proceed on the basis that the public Register is accessible to all, and that the obligation to check it rests with the employer.

An employer is prohibited from concluding or extending an employment or civil law contract with any person whose details appear in the Register. Breach of this prohibition gives rise to administrative liability: fines for officials range from 50,000 to 100,000 roubles, and for legal entities from 250,000 to 1,000,000 roubles per unlawfully engaged worker, with the possibility of an administrative suspension of activities for up to 90 days.

Where an employee already engaged under an employment contract is entered into the Register due to the expiry of their temporary residence permit, permanent residence permit, work patent, or work permit, the employer is required to suspend them from work. If the violation is not remedied within one month, the employment contract is subject to termination under Part 2 of Article 327.6 of the Labour Code of the Russian Federation. Where an order of administrative removal has been issued, the employment must be terminated immediately under Article 83 of the Labour Code as a circumstance beyond the control of either party.

Conclusion

The Controlled Persons Register is one of the most effective instruments of immigration enforcement to have appeared in Russian legislation in recent years. Its fundamental distinction from earlier mechanisms lies in the fact that it operates entirely automatically: inclusion occurs without warning, and its consequences take effect immediately, affecting a wide range of the individual's rights.

For a foreign national, the only reliable way to avoid inclusion in the Register is to monitor one's status proactively and to keep all authorisation documents in good order. For employers, checking employees and counterparties against the Register is no longer an optional precaution — it is a legal obligation with specific sanctions for non-compliance.

If you discover that you or one of your employees has been entered into the Register, the matter should not be deferred. The legal consequences compound over time, and the available avenues for legalisation narrow accordingly.