On 10 December 2025, the Russian occupation administration in Crimea adopted “decree No. 382-U”, which effectively bans the employment of “foreign citizens” working under patents in 84 of 88 types of economic activity starting in 2026.

A patent is an official work permit for “foreign citizens” residing in Russia without a visa, permanent residence permit, or temporary residence permit. From 1 January 2026, such individuals may only be employed in the construction of buildings, civil engineering, specialised construction works, and the provision of temporary accommodation.

Meanwhile, “foreign citizens” working under patents in other sectors must be dismissed by enterprises as of 1 January 2026. This is the largest-scale regulatory act of the occupation administration in the field of regulating foreign labour, effectively establishing a total ban on their use in the peninsula’s economy.

How will this affect Ukrainian citizens?
The occupation administration considers Ukrainians who refused to obtain a Russian passport to be “foreign citizens”. Formally, such individuals are otherwise “legalised” within the occupation “legal framework” and can work without obtaining an occupation patent; however, given our long-term monitoring of the situation in Crimea, it cannot be ruled out that this practice will be extended to all “foreigners”.

What is the purpose of these changes?
First and foremost, through such changes, the occupation administration seeks to force those who do not have Russian citizenship to accept it. After that, Russia will be able to mobilise such individuals or involve them in other work for the benefit of its armed forces.

Furthermore, with this decree, the occupiers seek to establish full control over the internal mobility of the population and strategic sectors of the economy, as well as to eliminate competition from workers without Russian citizenship. This is also confirmed by the fact that in 2024–2025, the list of restricted activities included 35 positions, whereas in 2026 it expanded to 84.

Consequences
It is important to note that this is not the first such change regarding the work of foreign citizens, a category into which the occupation administration also places Ukrainians. This is a long-term policy of the Kremlin with a number of consequences.

Firstly, this and similar decrees only increase the isolation of temporarily occupied Crimea and minimise the access of individuals without a Russian passport to critical infrastructure and other socially important facilities.

Secondly, the introduced restrictions open the way for the complete replacement of workers without Russian citizenship by workers from Russia itself. This aligns with the Russian Federation’s strategy for the demographic and social transformation of Crimea, which it has been carrying out since 2014.

Thirdly, it creates a legal basis for the dismissal and deportation of foreign workers, which increases the risks of human rights violations in Crimea and deepens the overall atmosphere of repression in the region.

Thus, “decree No. 382-U” reflects an increase in isolation and total administrative control in the temporarily occupied territory. This is accompanied by further restrictions on the rights of “foreign citizens” and a growing dependence of the economy on Russian personnel.