Full Report
The Russian government has introduced a new law that makes installing a tracking app mandatory for all foreign nationals in the Moscow region. [...]
Analysis Summary
# Regulation/Compliance: Mandatory Location Tracking for Foreigners in Moscow
## Overview
This regulation mandates that all foreigners staying in Moscow install and utilize a government-provided mobile application for real-time location monitoring and data submission to the Ministry of Internal Affairs (MVD). The stated purpose of this mechanism is to strengthen control over migration and reduce violations and crimes associated with migrants.
## Key Details
- Issuing Authority: Russian Government/Ministry of Internal Affairs (MVD) (as enforced by statements from officials like V. Volodin).
- Effective Date: Not explicitly stated for final implementation, but the mass-surveillance experiment is set to run until September 2029.
- Jurisdiction: Moscow, with potential expansion nationwide if the experiment is successful.
- Status: Proposed/In Development (Specific technical and practical details are still under discussion between the Ministry and regional authorities).
## Requirements
### Mandatory Requirements
1. **Application Installation:** All foreigners (excluding specified exemptions) must install the mandated tracking mobile application on their personal smartphones.
2. **Data Submission:** The application must transmit the following data to the MVD:
* Residence location.
* Fingerprint data.
* Facial photograph data.
* Real-time geo-location monitoring data.
3. **Address Updates:** If a foreigner changes their actual place of residence, they are required to inform the MVD within three working days via the application/system.
### Recommended Practices
1. **Address Technical Obstacles:** Organizations/stakeholders should proactively identify and propose solutions for foreseen technical hurdles (e.g., device theft, loss).
2. **Legal Review:** Conduct a review regarding conformity with existing constitutional protections on privacy (Articles 23 and 24 of the Russian Constitution).
## Affected Organizations
- Industries: Primarily impacts tourism, temporary labor, education, and any sector employing foreign nationals within Moscow.
- Organization Size: Applies universally to any entity or individual hosting or employing foreigners required to comply.
- Geographic Scope: Currently focused on Moscow, with intent to expand nationally.
## Compliance Timeline
- **Until September 2029:** Mass-surveillance experiment runs.
- **Future Determination:** If the experiment is deemed successful, the mechanism will be extended to cover additional parts of the country.
- **Ongoing:** Three working days to notify the MVD of any change in the declared residence location.
## Implementation Guidance
### Assessment Phase
- Identify all foreign nationals currently residing or planning travel/work within the regulatory scope.
- Determine the specific technical requirements and expected data points the application will demand from end-users.
### Implementation Phase
- Prepare for the rollout of the application installation requirement for all affected foreign nationals.
- Establish internal procedures for monitoring and verifying that foreign employees/guests comply with the mandatory address update notification.
### Validation Phase
- Monitor MVD broadcasts or official publications for final operational details and technical specifications of the required application.
- Verify that required data (location, fingerprint, face scan) is successfully transmitted and logged according to MVD specifications.
## Technical Requirements
* **Mandatory Application Use:** Requires installation of specific government software.
* **Biometric Data Collection:** Requires capture and transmission of fingerprints and facial photographs.
* **Continuous Tracking:** Requires real-time geo-location monitoring capability.
* **Data Synchronization:** Mechanism must be robust enough to handle updates within a strict three-day window when the user moves.
## Penalties & Enforcement
- Fines: Not explicitly detailed in the provided text.
- Other Consequences: Foreigners who fail to comply with the obligation to install/use the app or notify the MVD of address changes will be:
1. Added to a registry of monitored individuals.
2. Subject to deportation from Russia.
- Enforcement: Enforcement will be managed by the Ministry of Internal Affairs (MVD).
## Related Standards
- **Russian Constitution:** The regulatory proposal is explicitly noted to potentially violate Articles 23 (Right to Privacy) and 24 (Inadmissibility of collecting, storing, using, and disseminating information about private life without consent).
## Resources
- Official Documentation: Duma.gov.ru/news/61435/ (Official statement source)
- Guidance Documents: Roskomsvoboda.org/en/post/spying-on-foreigners-via-smartphone/ (Legal and advocacy group analysis)
- Tools: None specified; compliance relies on proprietary government-issued mobile software.
## Practical Recommendations
- **For Foreign Nationals:** Ensure immediate installation and activation of the app upon entry/start of their stay in Moscow, and keep contact information meticulously updated. Plan for potential legal challenges related to privacy infringement.
- **For Employers/Sponsors:** Develop documented verification processes to confirm that all foreign personnel have successfully installed and are actively using the required location tracking application, as non-compliance leads directly to deportation.
- **Advocacy Groups:** Prepare counterarguments or legal challenges focusing on established constitutional privacy rights (Articles 23 and 24) ahead of the full implementation.