Germany has announced that Russian Federation passports issued in the so called “Model 2001” format will no longer be recognized as valid travel documents for immigration purposes as of 1 January 2026. While a limited grandfathering rule applies to certain existing residence permits issued before that date, the change will have significant practical implications for employers, assignees, and business travelers. Early action is strongly recommended.
German immigration law requires foreign nationals to hold a valid and recognized passport in order to enter and remain in Germany. Recognition of passports is determined by the German authorities through general administrative decisions.
With effect from 1 January 2026, the recognition of the Russian “Model 2001” passport is withdrawn. From that date onward, this passport type will generally no longer be accepted for entry into Germany, for visa issuance, or for residence permit procedures.
A narrow transitional rule applies: a “Model 2001” passport may remain recognized if the expiry of a residence rightis documented in, or linked to, that passport. In addition, the relevant residence document must have been issued before 1 January 2026. Once the relevant residence right expires, the passport can no longer be used for immigration purposes. This grandfathering does not apply to new applications or status changes filed from 2026 onward.
For employers, the main challenge lies in timing. Employees or candidates holding a “Model 2001” Russian passport may experience delays or complications in visa processes or international travel if a new passport is not obtained in time. Assignment planning, onboarding, and business travel schedules may therefore be affected.
At the same time, the change provides an opportunity to strengthen internal immigration and document-readiness processes. Identifying affected individuals during 2025 and aligning internal stakeholders early can significantly reduce operational and compliance risks in 2026.
We advise employers on the practical and strategic implications of this change, including assessing which employees or applicants are affected, developing immigration timelines with a focus on risk mitigation, managing visa and residence procedures, and reviewing right-to-work and compliance documentation.
If you would like to discuss the impact on your workforce or specific cases, please feel free to reach out to us.
For a deeper discussion on the above, please reach out to your Vialto Partners point of contact, or alternatively:
Mostafa Massoud
Partner
Inga Mayer
Senior Manager
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