Regarding the obligation of highly qualified specialists to register in the personal accounting system
According to the amendments of April 1, 2019, when signing an employment contract, an employee must present to the employer a document (including in electronic form) confirming registration in the system of individual (personalized) accounting, which can be issued to a highly qualified specialist (unlike Individual insurance account number), which in turn indicates the obligation of foreign employees who are categorized as HQS to obtain a certificate of registration of individual personal account.
Olga Igorevna Prygova, Deputy Head of the Russian Pension Fund's Moscow and Moscow Regional Department, gave the following comments on these changes:
«1. If an individual personal account (ILS) has not been opened for an individual entering the workforce for the first time, the employer must submit to the territorial body of the Pension Fund of the Russian Federation the information necessary for registration of the individual in the system of individual (personalized personified) accounting.
2. In the event of changes in the information (personal data) included in the employee's ILS, the employer shall submit the updated information to the relevant body of the Pension Fund of the Russian Federation.
At the same time, there is currently no certainty as to whether the employer is obligated to issue ILS for foreign employees it already employs or have been employed before April 1, 2019. With regards to this matter, LEVINE Bridge employees have sent an official request to the Pension Fund of the Russian Federation to obtain clarification on this issue.
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