Reimbursement of a sanatorium or health-improvement stay may be protected from enforcement. This does not cover every holiday expense: tourist packages are expressly excluded, and other payments require checks of the beneficiary, payer and institution.
Checked on 7 September 2026. This guide addresses money received as reimbursement during Russian personal bankruptcy, primarily at the asset-realisation stage.
Not every holiday
A tourist trip and a stay at a sanatorium or health-resort institution have different legal treatment.
Not every payment basis
A holiday bonus does not become stay reimbursement merely because its payment description sounds similar.
Not the whole account
Protection must be established for a specific amount, not every balance on the card.
What the law actually protects
Article 101(1)(15) of Federal Law No. 229-FZ protects full or partial reimbursement of the cost of non-tourist vouchers or stays, subject to statutory conditions. The first part identifies payments by employers to their employees and family members, and to people with disabilities who do not work for that organisation. It concerns sanatorium, health-resort and health-improvement institutions located within the Russian Federation.
The same paragraph separately identifies reimbursement for children under 16 attending such institutions in Russia. Conditions applicable to adult payments should not simply be substituted for this part of the rule. In particular, “under 16” does not mean “under 18”. Identify which part covers the particular reimbursement and the document under which it was awarded.
In bankruptcy, protection is considered alongside Article 213.25 of Federal Law No. 127-FZ. Receipt during asset realisation does not remove statutory protection. However, the payment label does not replace evidence of its legal nature.
Five questions to ask of the documents
- What was paid for? Check the contract and stay description: a tourist product, sanatorium treatment or health-improvement services. The word “wellness” in advertising is insufficient.
- Where is the institution? Location in Russia is material to this ground of protection. A foreign resort does not qualify under paragraph 15 merely because it is recommended for rest or treatment.
- Who is the stay for? An employee, family member, a person with a disability not employed by the organisation, or a child under 16. Collect evidence of the relevant status.
- Who reimburses it and why? Obtain the order, decision, programme terms or internal policy. A rule protecting money from enforcement does not oblige every employer to pay for every sanatorium stay.
- How much was reimbursed? Reconcile the calculation, payment documents and bank statement. Partial reimbursement may also be protected, but does not protect every other receipt.
Payments that should not be confused
| Situation | What to check | Position in your request |
|---|---|---|
| Employer reimburses an employee’s sanatorium stay | Non-tourist nature, Russian institution, award order and calculation | Establish paragraph 15 protection if the conditions are met |
| Reimbursement for a child under 16 | Age, Russian institution, beneficiary and payment basis | Rely on the relevant part of paragraph 15 |
| Reimbursement of a tourist trip | Contract, actual services and any separate legal grounds | Do not promise paragraph 15 protection: tourist packages are excluded |
| Ordinary holiday bonus or annual-leave pay | Order and payslip, relationship to remuneration | Do not reclassify it as reimbursement of actual stay costs |
Receiving the money during asset realisation
Before the credit arrives, send the financial manager a written request identifying the case, amount and reimbursement basis. Attach the award decision, contract or voucher, payment records and information about the institution and beneficiary. Add the bank statement after receipt. Evidence of the child’s status, family relationship or disability is supplied where needed to establish the relevant category.
Ask for the protected amount to be excluded and for written arrangements for receiving it. Under paragraph 1 of Supreme Court Plenum Resolution No. 48, the manager addresses protected funds; disagreements go to the court handling the bankruptcy case. Receiving reimbursement does not mean you may independently open a new card or disregard restrictions on banking operations.
If the bank will not release the money, establish why: a card blocked because of bankruptcy is not the same as enforcement against the reimbursement. Give the bank and manager evidence of the payment purpose and arrange lawful access. If the manager refuses, request a written position and prepare supporting records for the court. An application alone does not guarantee immediate payment or suspend distribution of disputed funds.
Illustration of partial reimbursement
An employee pays RUB 60,000 for a non-tourist stay at a Russian sanatorium. The employer’s scheme reimburses RUB 25,000. If the records establish the conditions of paragraph 15, protection is claimed for the RUB 25,000 received. This does not oblige the employer to reimburse the remaining RUB 35,000 or entitle the employee to receive that additional amount from the bankruptcy estate.
Wages credited alongside the reimbursement are assessed separately. See receiving wages during bankruptcy. This is a hypothetical illustration, not a court case or a statutory payment amount.
The stay and travel to treatment are different expenses
Ticket costs should not automatically be included in stay reimbursement. Compensation for travel to treatment and back has a separate ground under Article 101(1)(16), requiring compensation provided for by federal law. Keep the documents and calculations for these amounts separate. See medical-travel reimbursement during bankruptcy.
Frequently asked questions
Can I retain reimbursement for a tourist package?
Paragraph 15 expressly excludes tourist packages. Any separate legal basis requires its own assessment; a link to a holiday alone does not justify promising protection.
My child has turned 16. Is all protection lost?
The specific wording covering children under 16 no longer applies by itself. However, other parts of the rule must still be checked, such as an employer’s reimbursement for an employee’s family member. The age limit for one category must not automatically be applied to every other category.
Is a certificate showing a need for treatment enough?
No. It may support medical circumstances, but does not replace records of the stay, institution, beneficiary and reimbursement. This guide does not establish treatment-prescription rules or eligibility for a particular benefit.
Is only full reimbursement protected?
No. Paragraph 15 also covers partial reimbursement. Establish the awarded amount and all other conditions rather than claiming exclusion of the whole trip cost without a legal basis.
Need to check your stay reimbursement?
We can review the payment basis, documents and how to approach the financial manager. The legal assessment depends on the actual conditions, not only the payment label.
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