As reported by The Moscow News Weekly, over the past several months it has become more difficult for companies to hire and retain foreign employees in Russia. A major issue cited by various foreign business associations is that the enforcement of migration rules can be unpredictable. For example, the Federal Migration Service has become stricter in enforcing certain rules: Two years ago, diplomas attesting to the applicant's educational qualifications were required only for language teachers, but since October 2008, the rule is being enforced for all professions.

There also are concerns about the quota system for work permits and the bureaucratic obstacles that employers sometimes encounter with the system. One possible solution is to give certain white-collar employees from the European Union, the United States and Japan "green cards" that would exempt card holders from the quota system. The Federal Migration Service has drafted a bill along these lines that may be introduced in the Duma in July.

Another reason for the difficulties is the procedure by which representative offices hire foreign workers. A representative office is issued a permit by an accrediting body (such as the Chamber of Commerce and Industry or the State Registration Chamber) which states how many foreign employees the representative office may hire. Under this arrangement, foreign employees working for the representative office do not receive work permits, but rather an accreditation card from the accrediting body. Recently there have been reports of police officers questioning the validity of these accreditation cards during their routine document checks in the streets. The Japan Business Club and the Association of European Businesses have been advising their members to obtain work permits for accredited foreign employees working in representative offices.