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Sharp increase in minimum salary requirement for HQS – bill passed first reading in Duma on 18 March 2026

19.03.2026

If the amendments are adopted, HQS employees whose salaries do not meet the new requirements will not be able to continue working in Russia under the HQS regime. Employers would have to terminate their employment contracts or ensure that migration documents appropriate for other migration regimes are obtained. Selecting the appropriate regime and completing all the necessary procedures would take a significant amount of time. It is possible for a time gap to occur where a foreign employee is unable to work from September 2026 until the new migration process has been completed.

The preferential migration regime for highly qualified specialists (HQS) is used to recruit foreign nationals to executive positions but can also be used for blue-collar positions (such as a welder). The employer itself decides whether a foreign specialist is suitably qualified (has the necessary work experience and skills or achievements in a specified field of activity). The only criterion established by law as confirmation of an employee’s qualification is the minimum salary level.

The current minimum salary requirements for HQSs not falling within special categories is 750,000 rubles per quarter (or approximately 250,000 rubles / month).

The bill[1] sets a minimum salary of 717,000 rubles per month, which is almost 3 times higher than the current level. Besides this initial increase, it is also proposed that the salary threshold be indexed on an annual basis.

Under the bill, the changes to the salary requirements would take effect starting 1 September 2026.

What immediate action should HQS employers take?

Make a list of current / new HQSs whose salaries do not currently meet the new requirements.
Decide whether it would be practical to retain the employees concerned and raise their salaries to meet the new requirements.
Examine the feasibility of rehiring those employees under other migration regimes, taking into account the timescales and specific requirements of the processes involved (the need to obtain a quota to hire foreign nationals, the need for employees to take Russian language, history and law tests, requirements to submit apostilled education certificates, and the feasibility of obtaining a temporary residence permit under the simplified procedure or using special migration regimes).
Develop a detailed roadmap for transition to the new migration regime or make a decision to terminate an employee before the new requirements take effect. Determine what steps must be taken in the event of a time gap between the entry into force of the new HQS salary requirements and the receipt of a work permit by a non-HQS. Begin implementing the plan.
Inform foreign employees of the changes and the action the employer intends to take.
Inform apartment landlords, the HR department, the accounting department and other interested parties of changes ensuing from the loss of HQS status (shorter deadlines for migration registration, the application of standard personal income tax rate to income of tax non-residents, the need to pay social contributions, etc.).

These are not easy tasks, and the bill provides very little time to adapt to the proposed changes. As a result, employers might find themselves without key employees, unable to meet project deadlines or deprived of a foreign manager at the worst possible moment. B1’s migration team is ready to support you through every stage of this challenging process: determining the migration framework that best suits your circumstances, drafting a roadmap, identifying potential problems in advance, conducting briefing sessions on migration and personal income tax for foreign employees, and preparing information materials on changes resulting from the loss of HQS benefits for interested parties.