Posted 2012-10-03 12:58 AM (#53143) Subject: Strange interpretation of "90 days in a 180 day window" rule
The FAQ section of the RealRussia site contains the following (surely correct!) statement:
“If you have a multiple entry visa then you are restricted to staying in Russia for a total of 90 days in a 180 day window. This 180 window starts from the first day that you use the visa.”
Using my current one-year multi-entry visa (valid up to 30 November 2012), I entered Russia on 15 January of this year. So, counting the days, my (first) 180-day window was from 15 January to 12 July.
In this first 180-day window I was in Russia for 81 days in total: from 15 Jan to 11 March (57 days) and from 19 June to 12 July (24 days).
In the second 180-day window, beginning on 13 July, I would have been in Russia for just 42 days in total, from 13 July to 23 August (the date of my return ticket)
No problem, you might think, since my stays in each 180-day period would both have been shorter than 90 days. Unfortunately, you would be wrong! The registration authorities in the city where I stayed (which is not on RealRussia’s list of “difficult cities”!) refused to register my visa beyond 21 July, making it impossible for me to stay up to my intended departure date of 23 August unless first I left the country on 21 July and then returned, possibly on the same day. (I left on 21 July on a newly bought air ticket, and, as it happens, have not returned again so far.)
The reason the registration authorities gave was that 21 July would be be the 90th day of my total days in Russia under this visa.
In other words, they insisted on treating 21 July as if it was still in my first 180-day window, despite the fact that this date was clearly already nine days into my second 180-day window!
I have looked at the legislation in the original Russian [see below], which is a model of clarity and gives absolutely no support to the registration authorities’ surprising interpretation that the phrase “180-day period” can mean “a period of more than 180 days”!!
If official or legislative support exists elsewhere for this city’s strange interpretation, perhaps the excellent Real Russia site could kindly direct me to it? I would then also respectfully suggest that the site might then warn one-year multi-entry visa holders in the FAQ section that: If your second visit (or a later one) begins in the first 180-day window and continues into the second window to the point where you reach the 90th day in total of all your visits so far, you will not be allowed to register to stay beyond that 90th day, even though, on that date, you will have been in Russia for less than 90 days during the second window!
If, on the other hand, the registration authorities have no written legislative or statutory support for this strange, nonliteral interpretation of the phrase “period of 180 days”, I should appreciate early advice as to how I could have achieved a reconsideration.
[The relevant legislation is in Section 17 of the Decree of the Government of the Russian Federation of 9 June 2003, No 335 (Addendum added by Decree of the Government of the Russian Federation of 4 October 2007, No 635), and reads as follow:
Суммарный срок пребывания иностранного гражданина в Российской Федерации по многократной визе устанавливается при уполномоченном государственным органом, но не более чем 90 дней в течение каждого периода в 180 дней, за исклучением случаев, предусмотренных настоящим Положением.]
I would like to return soon, for a visit of a few weeks before my visa expires at the end of November. Can I expect that my visa will be registered after I arrive (after all, no 90-day limit will have been breached!), or might I find that I have to return to the UK as soon as I have touched down in Moscow?!! I should appreciate your answer on this before I travel in mid-October.
Posted 2012-10-03 12:59 PM (#53146 - in reply to #53143) Subject: Re: Strange interpretation of "90 days in a 180 day window" rule
I'm not sure if this helps but you can only stay for 90 days then you have to leave for 90 days whether its the first 180 or the second 180 is irrelevant. Its to stop people working the only way round it is to get back to back 3 month visas or private visas
Posted 2012-10-03 2:24 PM (#53149 - in reply to #53146) Subject: Re: Strange interpretation of "90 days in a 180 day window" rule
Location: In the Windmills of my mind...
scampypants - 2012-10-03 5:59 PM I'm not sure if this helps but you can only stay for 90 days then you have to leave for 90 days whether its the first 180 or the second 180 is irrelevant. Its to stop people working the only way round it is to get back to back 3 month visas or private visas
I think that you are getting a little confused with people who live and work in Russia with the back to back visa system scampybaby
Posted 2012-10-03 2:34 PM (#53150 - in reply to #53143) Subject: RE: Strange interpretation of "90 days in a 180 day window" rule
Location: In the Windmills of my mind...
From the local FMS here......
The rule is simple, you can visit and stay in Russia for a total of 90 days in each 180 day period, however, you are not allowed to be in the country after the last day of this first 180 day period, even if your visit has not completed 90 days, so your FMS was correct (even if they got their count wrong)(be happy that they didn't give you an administration fine)..
You can start the second 90 days visit on the first day of the second 180 day period without any problems..
Your visits can be at any period during the 180 days as long as you do not exceed 90 days in total, including the days of arrival, and the days of departure
btw, your 90 days begin when you arrive in Russia, but the second 180 days finishes when your visa reaches its expiry date, so you may only end up with e.g. a 100 day second stint, as 360 days (2 x 180) are counted from the date that the visa was issued.
Posted 2012-10-07 12:28 PM (#53164 - in reply to #53150) Subject: RE: Strange interpretation of "90 days in a 180 day window" rule
Thank you, Mel, and your local FMS, for providing such a clear and helpful answer.
The key statement in your reply seems to be "you are not allowed to be in the country after the last day of this first 180 day period, even if your visit has not completed 90 days".
(I think it would be good to put this statement into the registration-guidance section (or FAQ section) of the website, as this would allow visitors to choose their first-entry date to be such as to avoid their having to leave the country (and perhaps re-enter a day or two later) at what might be an inconvenient time for them. (Apologies if it is already there, somewhere, and I missed it.)
Posted 2013-01-28 3:15 PM (#55672 - in reply to #53143) Subject: Re: Strange interpretation of "90 days in a 180 day window" rule
This is absolutely something all the visa agencies and embassies should have on their site. I wasnt aware of this " not allowed to be in the country after the last day of this first 180 day period, even if your visit has not completed 90 days". I travel quite frequently to Russia, so this is something i will think about when planning future trips. When travelling frequently, it seems quite easy to get stuck between these two periods.
Posted 2013-10-20 8:47 AM (#59459 - in reply to #59458) Subject: Re: Strange interpretation of "90 days in a 180 day window" rule
Location: When at home either Sakhalin Island or Scotland
I assume that you are talking about Russian visas, if yes then do not stick the photograph onto the visa. All Russian visas do have a place for a photograph but the photograph is not placed on the visa.
On a different note if you modify a visa (regardless of which country the visa is for) you invalidate the visa.