Notification of dual citizenship or residence permit: What legal consequences should Russian citizens be aware of?

Recently, situations have increasingly arisen where citizens of the Russian Federation living abroad are unaware of their obligation to notify government agencies of their dual citizenship.

In accordance with Article 11 of Federal Law No. 138-FZ "On Citizenship of the Russian Federation" dated April 28, 2023, a citizen of the Russian Federation is required to submit a notification of each acquisition of citizenship (nationality) of a foreign state or receipt of a residence permit (RP) or other document confirming the right of a Russian citizen to permanent residence in the territory of a foreign state, and also has the right to submit a notification of the loss of citizenship or RP of another state.

As a general rule, these notifications are submitted to the Ministry of Internal Affairs. Russian citizens residing outside the Russian Federation can apply to the Russian embassy or consulate. For minors under 18, notifications are submitted by their parents.

The law also provides for the possibility of submitting a notification by power of attorney, drawn up and legalized in accordance with the procedure established by law.

Notification must be submitted no later than sixty calendar days from the date a Russian citizen acquires another citizenship or residence permit. If a person fails to submit notification on time due to being abroad, they must submit it no later than sixty calendar days from the date of entry into the Russian Federation.

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The forms of notifications, the composition of the information included in them and the list of documents attached to them are established in accordance with the regulations on the procedure for considering issues of citizenship of the Russian Federation.

International treaties and laws of the Russian Federation may establish individual cases of exemption from this obligation.

Many believe that living abroad or staying briefly in the Russian Federation does not entail the obligation to notify of dual citizenship or a residence permit. This is a misconception. Notification is required, and liability for failure to comply with the legal obligation arises even if a Russian citizen enters Russia for just one day—it is on this day, the first day of border crossing, that the timer starts.

Article 19.8.3 of the Code of the Russian Federation No. 195-FZ "On Administrative Offenses" of December 31, 2001 (as amended on March 8, 2026) establishes liability for violating the procedure for a citizen of the Russian Federation to notify of another citizenship or residence permit. Such a violation consists of late notification or the provision of incomplete or knowingly false information. The administrative fine ranges from 500 to 1000 rubles.

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The line between an administrative offense and a criminal offense is very fine. Administrative liability arises for violating the notification procedure, while criminal liability arises for failure to file such notification. However, as we all know, ignorance of the law is no excuse.

According to Article 330.2 of the Criminal Code of the Russian Federation, reasons for failure to file such notification have no legal significance. Committing this crime by a citizen not only entails a fine or community service, but also a criminal record.

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In practice, such violations are most often identified when citizens contact government agencies of the Russian Federation, in particular:

• when applying for a new foreign passport;
• when resolving property or inheritance issues;
• when applying to consular offices;
• when submitting documents to government agencies.

To avoid liability, our clients submit notifications of dual citizenship or residency through our office, without having to travel to Russia in person. This completely eliminates the possibility of criminal liability. Regarding administrative liability, it can be avoided by waiting for the expiration of the time limit for administrative liability (Article 4.5 of the Code of Administrative Offenses of the Russian Federation). In this case, this is three months from the date of late filing of the aforementioned notification.

These and other issues can be successfully resolved by contacting Karina Duval's office, which is located at 1400 Ave Z, Office 502, Brooklyn, NY 11235. Registration by email: [email protected].

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