Russian Government Resolution No. 916 of 21 July 2026 amends Resolution No. 1880, which sets out the additional information to be included in the registers of members of self-regulatory organisations (SROs) in the fields of engineering surveys, design and construction.
In practical terms, the registers will contain not only information about an organisation’s SRO membership and level of liability, but also details of its specialists and contracts.
What will change from 1 March 2027?
- information on contracts concluded before 1 March 2026 may be submitted for inclusion in the register on a voluntary basis;
- the requirement to indicate a specialist’s primary place of employment will be removed from the employee information recorded under Resolution No. 338. The NRS registration number will be provided where available;
- information on other specialists involved in construction will only be included where the applicable self-regulation rules contain relevant requirements. For this category, the primary place of employment requirement remains in place, and the register will include the specialist’s full name and NRS registration number.
Important: removing the reference to a primary place of employment from the information recorded under Resolution No. 338 does not, by itself, abolish the requirements applicable to employees’ employment relationships and qualifications.
These requirements must still be verified against the Russian Urban Planning Code, Resolution No. 338 and the applicable SRO rules.
Why does this matter?
The register is becoming a more detailed source of information about an organisation’s personnel and professional track record. Its data may be reviewed by SROs, clients and other market participants.
If the information in the register does not match the NRS records and personnel documentation, the organisation may have to demonstrate that the relevant specialists are actually employed and correct any discrepancies.
If a review identifies an actual lack of mandatory specialists, this may create a risk of non-compliance with the requirements for SRO membership.
At the same time, the register does not need to include the entire engineering and technical staff.
It is important to distinguish between:
- specialists responsible for the organisation of engineering surveys who are included in the NRS;
- employees covered by Resolution No. 338, where the company carries out work at particularly hazardous, technically complex or unique facilities;
- other specialists for whom requirements are established by the applicable self-regulation rules.
Key risks
- the register lists an employee who has already left the company or been transferred to another position;
- the specialist’s name or NRS registration number does not match the NRS records;
- the specialist’s primary place of employment, education, professional experience or independent qualification assessment (NOK) has not been properly documented where required;
- the company has incorrectly classified the employee and therefore applied the wrong requirements;
- SRO records are inconsistent with employment contracts and personnel orders.
Failure to submit information about older contracts is not, in itself, a violation, as their inclusion is voluntary. However, without this information, the register may not reflect the organisation’s full documented track record.
Why are we discussing this now?
There is still time before 1 March 2027, but correcting information in the NRS and SRO register, verifying qualifications, obtaining supporting documents and completing the NOK process may take several weeks. In some cases, clarification from the relevant SRO may also be required.
A preliminary action plan for the period leading up to 1 March 2027 is shown in the image.
I would start by appointing one responsible employee to consolidate information from the SRO, NRS and HR departments into a single table. This will make it easier to identify which records are compliant and where additional documents or clarification are required.
