The President of the Russian Federation signed Federal Law No. 132-FZ of July 1, 2017 "On Amending Certain Legislative Acts of the Russian Federation with regard to the placement in the state information system in the field of civil service of information on the application of punishment in the form of dismissal due to loss of trust for committing corruption offenses", which establishes the need to make publicly available information on officials dismissed for committing corruption offenses.

The Law provides for the creation of a specialized register which will include information on the application of such disciplinary sanction as dismissal (dismissal from office) for loss of confidence in respect of:

• public servants, including civil servants, military personnel, employees of investigative bodies, prosecutor's offices, internal affairs bodies, customs bodies, and the federal firefighting service;
• municipal servants;
• Persons holding state and municipal posts;
• persons holding positions in the Central Bank, state corporations (companies), public law companies, PFR, FSS, FOMS and other organizations established by the Russian Federation on the basis of federal laws;
• persons holding certain positions on the basis of an employment contract in organizations established to perform tasks assigned to federal state bodies.

The register will start functioning on January 1, 2018 and will be placed in the state information system in the field of civil service in the information and telecommunication network "Internet". The obligation to include relevant information in it shall be imposed on the employer of a person who was dismissed due to loss of confidence.

The procedure for keeping the register should be determined by a decree of the Government of the Russian Federation, the draft of which has not been published so far. In this regard, it remains unclear whether the register will be fully publicly available or whether only employees of personnel services of state bodies, local governments, state corporations and organizations with state and municipal participation will be able to familiarize themselves with the information contained therein.

According to the explanatory document to the draft law, the purpose of its formation is to obtain reliable information on compliance with the requirements of anti-corruption legislation by applicants for positions in the state (municipal) service, state corporations and organizations with state participation during the candidate selection procedure. In other words, the register is of an informational nature, and the right to make a decision is not limited to the employees of state bodies, local governments, state corporations and organizations with state and municipal participation.

At the same time, in the course of public coverage of the law, some experts speak about the inclusion of information about the dismissal of a person due to loss of confidence in the register as a de facto prohibition to hire him or her in any state and municipal structures. It seems that such an extended interpretation of the essence of the creation of the register may entail a violation of the labor rights of citizens.

UPD. On December 29, 2017, a law was adopted supplementing the norms on the creation of a register of persons dismissed for corruption offenses.

This law changes the period of storage of information in the register, which will be 5 years, and also directly in the Federal Law of December 25, 2008 No. 273-FZ "On Combating Corruption" establishes the grounds for excluding information from the register. Previously, such provisions were supposed to be included in the relevant government decree defining the procedure for maintaining the register, but at the time of writing this post, such a procedure has not yet been adopted.

At the same time, the law introduces a new Article ⁴⁴¹ to Federal Law No. 79-FZ of July 27, 2004 "On the State Civil Service of the Russian Federation", which stipulates the necessity for federal state bodies to use the federal state information system in the field of civil service, including for working with the register. State bodies of constituent entities of the Russian Federation must also use the FGIS or create their own information system compatible with the federal one.