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HR documents via MAX: Ministry of Labour experiment until December 15, 2026

HR documents via MAX: Ministry of Labour experiment until December 15, 2026
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The Ministry of Labour is running an experiment on signing HR documents via the MAX messenger from September 21 to December 15, 2026. From October 30 to November 15, participating employers are implementing the updated software. Participation is voluntary. For companies with employees abroad, this opens an additional remote signing channel without replacing the existing electronic HR document system.

The experiment is based on Ministry of Labour Order No. 423 of 17.09.2026. An employer joins voluntarily by sending an application to the ministry indicating the company name, the list of documents to be tested and the list of participating employees.

MAX does not replace the existing electronic HR document management system. The company continues to work in its own system or via an operator platform, while the messenger becomes an additional channel of interaction with the employee. Documents are signed with an enhanced unqualified electronic signature, whose certificate is created and used through the e-government infrastructure.

The Ministry of Labour has not established a single mandatory list of documents for the experiment. Each employer determines in its application which HR documents to test — as a rule, those already kept electronically: employment contracts, supplementary agreements, transfer orders, vacation schedules, local regulations. The limitations of the Labour Code remain: documents that cannot be fully converted to electronic form are still drawn up on paper. The ministry explicitly cites a dismissal order as an example.

Two groups may take part in the experiment: employers already using electronic HR document management and those only planning to introduce it. The third stage is now under way — implementation of the operators' updated software at participants. The Ministry of Labour sends companies recommendations on organising the signing of electronic HR documents via MAX.

For companies already using electronic HR document management that have joined the experiment, it is important to check the compatibility of the operator's software with the new channel, as well as whether local document management acts comply with the requirements for signing via MAX.

The possibility of using MAX for electronic HR document management in general is so far only proposed to be enshrined in the Labour Code. Until the amendments are adopted, joining remains purely voluntary and experimental. Employers whose staff work remotely or are outside Russia should follow the results of the experiment: if the amendments to the Labour Code are adopted, the messenger signing channel may become a standard tool for companies with distributed teams.

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