Currency residency under 173-FZ, the obligation to notify the FNS about foreign bank accounts, the annual cash-flow report, the 183-days-abroad exemption…
Russia's currency control regime — Federal Law No. 173-FZ — imposes reporting obligations on individuals who hold bank accounts outside Russia. But the law's concept of a "currency resident" is entirely separate from tax residency, and many foreign individuals living and working in Russia are surprised to learn that the rules either do not apply to them at all, or apply in a way that has nothing to do with how long they have spent in the country this year. This guide explains who is affected, what the obligations are, and the exemptions that matter most for foreign individuals.
Russian law operates two independent residency tests that are frequently — and incorrectly — assumed to be the same thing:
A foreign individual can be a Russian tax resident without being a currency resident at all — and vice versa. The two statuses need to be assessed separately, and conflating them is the most common source of confusion among foreign nationals trying to work out whether they need to report a foreign account.
For individuals, "currency resident" status under 173-FZ is based on citizenship and immigration status, not on time spent in Russia:
Russian citizens are currency residents (subject to certain exceptions for those permanently resident abroad, which are outside the scope of this guide).
Foreign citizens and stateless persons holding a permanent residence permit (ВНЖ) in Russia are currency residents.
Foreign citizens without ВНЖ — including those on a temporary residence permit (РВП), a work visa, HQS status, or any other temporary basis — are not currency residents under 173-FZ, regardless of how long they have lived and worked in Russia or whether they are Russian tax residents.
The practical consequence is significant: a foreign executive on an HQS work permit who has lived in Russia for years, pays NDFL as a tax resident, and holds a bank account in their home country has no obligation under 173-FZ to notify the FNS about that account or to file the annual cash-flow report — because without ВНЖ, they are simply not a currency resident. The obligations described in this guide become relevant only once an individual obtains ВНЖ (or, for those who acquire it, Russian citizenship).
An individual who is a currency resident — typically a foreign national with ВНЖ, or a Russian citizen — and who opens, closes, or changes the details of an account or deposit at a bank or other financial market organisation located outside Russia must notify the Federal Tax Service within one month of the event. The notification is filed with the tax office at the individual's place of registration in Russia, using the current standardised form, and can typically be submitted electronically through the taxpayer's personal account.
This notification obligation applies to a broad range of accounts — bank accounts, brokerage accounts, and accounts with other financial market participants — and, under more recent guidance, extends to certain foreign electronic payment instruments and digital wallets as well.
Beyond the one-off notification, currency-resident individuals with foreign accounts must — unless an exemption applies (see next section) — file an annual report on the movement of funds and other financial assets (Отчет о движении денежных средств и иных финансовых активов, ОДДСФА) for each foreign account, covering:
Opening and closing balances for the calendar year;
Aggregate inflows and outflows during the year (the report does not require a transaction-by-transaction breakdown);
Foreign brokerage and securities accounts, in addition to standard bank accounts;
Balances and flows on foreign electronic wallets (such as PayPal-type services) without a conventional bank account attached.
The annual report for a given calendar year is due by 1 June of the following year — for example, the report covering 2025 is due by 1 June 2026.
173-FZ contains an important carve-out, set out in Article 12: a currency-resident individual who has spent more than 183 days outside Russia during the calendar year is exempt from both the notification obligations and the annual report for that year, in respect of their foreign accounts.
Notice what this means in combination with the tax residency test: a currency-resident individual (e.g. a foreign national with ВНЖ) who spends more than half the year abroad is, by the same token, very likely a Russian tax non-resident for that year — yet it is precisely this group that is exempt from currency reporting on foreign accounts. Conversely, a ВНЖ holder who spends most of the year in Russia (and is therefore a tax resident) is the one who does have full currency-reporting obligations on any foreign accounts they retain.
Because this exemption depends on a precise day count for the calendar year — the same type of calculation used for tax residency, but counting the opposite direction (days outside Russia rather than days inside) — individuals who divide their time between Russia and abroad should keep their own travel records rather than relying on assumptions about which side of 183 days they fall on.
For individuals, administrative penalties for currency control violations are modest in absolute terms but apply per violation and can accumulate across multiple accounts and years:
The statute of limitations for currency control violations under the Code of Administrative Offences is two years from the date of the violation — meaning historic non-compliance can still be pursued within that window once identified.
Establish whether you are a currency resident under 173-FZ — this depends on citizenship and ВНЖ status, not on how long you've lived in Russia
If you hold ВНЖ (or Russian citizenship) and have foreign accounts, notify the FNS within one month of opening, closing, or changing account details
Track days spent outside Russia each calendar year — exceeding 183 days abroad can exempt you from the annual report for that year
Remember that foreign e-wallets and brokerage accounts fall within the same reporting framework as conventional bank accounts
Practical support for international business in Russia.