Restrictions on employment and business activities for Russian and Belarusian citizens

On 9 April 2022, the Government of the Republic of Estonia issued a Regulation, which introduced restrictions on the short-term employment of Russian and Belarusian citizens in Estonia and on the issuance of temporary residence permits or visas for employment or engagement in business.

The regulation introduced the following sanctions:

• Russian and Belarusian citizens will not be issued visas for employment, teleworking or engagement in business, including start-ups
• Russian and Belarusian citizens will not be issued residence permits for employment or engagement in business (including start-ups and large investors)
• Russian and Belarusian citizens are not registered for short-term employment unless they already have a legal basis for stay in Estonia

Who will be subject to these sanctions?

Russian and Belarusian citizens who do not have a legal basis for stay in Estonia and whose employer wishes to register them for short-term employment in Estonia.

Russian and Belarusian citizens who apply for a visa or residence permit for employment or engagement in business.

Are there any exceptions to whom the sanctions do not apply?

Sanctions do not apply to the issuance of visas to Russian and Belarusian citizens on other grounds or the issuance of residence permits to them on other grounds. Nor do they apply to Russian and Belarusian citizens who extend their residence permit for employment or engagement in business or who hold the above-mentioned residence permit and apply for a new residence permit for employment due to a change of employer. Nor to the issuance of long-stay visas to citizens of Russia and Belarus who are registered for short-term employment and are legally staying in Estonia.

What is the purpose of these sanctions?

The purpose of these sanctions is to stop granting new grounds for stay or residence for the purposes of employment or engagement in business. The Regulation does not affect existing grounds for stay and employment.

What will happen to those who already hold a valid visa but are subject to a sanction under this Regulation?

All visas already issued will remain valid until their expiry date.

Are sanctioned persons forbidden from submitting such applications?

Sanctioned persons are not forbidden from submitting applications, but it is a futile exercise, because the decision will be negative in any case and the applicant will only be wasting his/her time and money.

What will happen to those who have submitted an application and are currently awaiting a decision, but are subject to sanctions under the new Regulation?

Sanctions will also be extended to applications submitted before the sanctions were confirmed and entered into force, for which the procedure is still ongoing.

Do you accept D visa applications for employment from sanctioned persons?

If a citizen of Russia or Belarus who is not staying in Estonia has a valid Schengen visa, the employer has the right to apply for registration of short-term employment and the person is entitled to apply for a D visa in Estonia. This is the case if there are no circumstances that preclude entry into Estonia or general grounds for refusal of short-term employment and D visa.

Is there also a sanction for extending the period of stay?

Applications for extension of stay are not subject to sanctions.