An employer’s reimbursement for an agreed move to work in another locality should not simply be treated as ordinary wages. But the label “relocation allowance” does not settle the issue: establish what is being reimbursed, the legal basis and the amount.
Checked on 7 September 2026. This guide covers employment-related relocation reimbursement in Russian personal bankruptcy, mainly during asset realisation. Special government support programmes for professionals require a separate assessment.
An agreed move
Establish the prior arrangement with the employer, not merely a change of address.
Separate components
Travel, transport of belongings and settling-in costs must be distinguished from wages and a hiring bonus.
Records before payment
Send the relocation terms and calculation to the administrator before the money is credited where possible.
What the law protects
Article 101(1)(8)(a) of Federal Law No. 229-FZ protects employment compensation connected, among other things, with transfer, recruitment or assignment to work in another locality. In bankruptcy, that basis is considered together with Article 213.25 of Federal Law No. 127-FZ: the protected amount should not be distributed to creditors as ordinary income.
Article 169 of the Russian Labour Code governs relocation reimbursement. It requires a prior arrangement with the employer and identifies the costs of moving the employee and family members, transporting belongings and settling into the new place of residence. There is a transport exception where the employer supplies the corresponding means of transport.
Amounts and procedures depend on the employer category. Government regulations apply to federal public bodies, funds and institutions; the relevant regional or municipal regulations apply at those levels. For other employers, a collective agreement, local policy or agreement between the parties to the employment contract determines the terms unless special rules provide otherwise. Article 169 does not set one universal relocation allowance for everyone.
Four situations that should not be confused
| Situation | What to check | Bankruptcy significance |
|---|---|---|
| Reimbursement of tickets and transport of belongings for an agreed move | Relocation terms, route, recipient and payment records | Establish employment compensation rather than automatically treating it as wages |
| A settling-in payment under the applicable rules | A local or statutory rule, agreement and calculation | Establish the basis and amount; the required evidence depends on the payment rules |
| A recruitment or retention bonus | Why it was awarded and whether it reimburses relocation | The label “relocation allowance” does not protect an incentive payment |
| An independent move without an employer arrangement | Whether an arrangement existed and whether another basis applies | Do not promise reimbursement or protection under Article 169 |
How to assemble the evidence
- Establish the basis. The employment contract, amendment, transfer order or recruitment documents should connect the move with work in another locality.
- Find the reimbursement rules. Obtain the current applicable policy, regulation or agreement. Identify eligible expenses, the calculation method, required documents and settling-in payment conditions.
- Separate the costs. List employee travel, family travel, transport of belongings and settling-in costs. Add tickets, the transport contract, receipts and evidence of family status where necessary.
- Check what has already been provided. If the employer paid a carrier directly or supplied transport, do not claim the same amount again as money payable to the employee.
- Match the calculation to the bank transaction. Ask payroll to identify compensation, wages and bonuses separately. Keep the bank statement and a breakdown of any combined transfer.
If the applicable rules provide a calculated allowance, examine those rules first. Do not demand an identical set of receipts from every employee or assume that every unsupported amount is protected. Evidence must establish the conditions of the particular compensation.
Receiving the money during asset realisation
Send the financial administrator a request identifying the case number, employer, amount, reimbursement components and expected payment date. Attach the documents and request exclusion of the protected compensation, with written arrangements for receipt. Add a bank statement after payment; identify each credit separately if there are several transfers.
Under paragraph 1 of Supreme Court Plenum Resolution No. 48, the administrator deals with protected funds and the bankruptcy court resolves disagreements. If the request is refused, seek the reasons: a dispute over the employment basis, amount, evidence or transfer components requires different supporting documents. Simply saying “this is a relocation allowance” is not enough.
Protection does not entitle you to independently open a new account or divert money to a relative’s card to evade the procedure. Arrange a lawful method with the administrator and bank. If the payment has not yet been assessed, separately clarify the employer’s conditions and timing: the administrator does not replace the employer or create an obligation to pay an arbitrary sum.
Illustration: the components of RUB 90,000
An employee is paid RUB 90,000: RUB 20,000 for documented transport expenses, RUB 30,000 as a settling-in payment under the applicable agreement, and a RUB 40,000 recruitment bonus. If the first two components genuinely meet the conditions for employment compensation, the protection claim concerns RUB 50,000. The bonus is assessed separately as other income; a combined transfer does not make the entire RUB 90,000 exempt.
These figures are hypothetical, not government rates or a court case. Wages and funds retained for living expenses have a separate procedure: see receiving wages during personal bankruptcy.
Frequently asked questions
Is every relocation allowance protected from creditors?
No. The label may refer to employment reimbursement, a bonus or a payment under a special programme. Read the award’s legal basis, not just the bank description. Article 169 should not be substituted for the rules of specific programmes for doctors, teachers or other professionals.
Are family members’ relocation costs included?
Article 169 names the relocation of family members and transport of belongings. Check the prior arrangement, applicable rules and eligible costs. A family relationship alone does not require the employer to pay for any trip at any time.
Can monthly apartment rent be included?
Not automatically. Housing rental reimbursement may have its own conditions and legal basis. Do not treat all rent as settling-in costs simply because accommodation is needed after the move.
What happens to an advance if the move is cancelled?
Tell the employer and administrator, keep the cancellation records and clarify the reporting and repayment rules. Do not treat an unused advance as unconditionally yours and protected, or dispose of a disputed amount independently.
Need to assess a relocation payment?
We can review the employer agreement, payment components and documents for the financial administrator. The assessment depends on the terms of the specific payment.
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