$OH[DQGHU6DOHQNR Although the presidential decree complicates the simplified naturalisation procedure and undermines the sense of the existing international agreements, all requirements for obtaining Russian citizenship based on the simplified procedure remained unchanged. As before it is necessary to have a spouse or parents who are citizens of the Russian Federation. Also persons who born in the territory of the former RSFSR, have the right to obtain citizenship due to the simplified procedure. However, now migrants from Belarus, Kazakhstan and Kyrgyzstan who earlier expected to obtain Russian citizenship based on the simplified procedure (taking up to three months), will be forced to pass all the stages of the standard naturalisation procedure.55 Additionally, the presidential decree can be considered as a violation of the principle of legal certainty. This decree deprived people of any possibility to prepare for the new conditions of the naturalisation procedure. Those who moved to Russia as migrants, having sold their real estate in the former Soviet republics and then expected to obtain Russian citizenship due to the simplified naturalisation procedure ('uproshenka'), were ex facto deceived by the Russian authorities (or to be exact by the Russian President Medvedev). The presidential decree entered into force on the day of its official publication, 21 October 2011. 5.2.2 Denunciation of the agreement between Russia and Kyrgyzstan regarding simplified procedure of naturalisation In March 2012 the head of the FMS, Konstantin Romodanovsky, announced that the Russian Government had decided to renounce the agreement between the Russian Federation and Kyrgyzstan regarding the simplified procedure of naturalisation. These measures were a direct consequence of the Presidential decree of October 2011. The Russian authorities justified this measure in terms of the need to streamline Russian legislation regarding migration, and also argued that the bilateral agreement between Russia and Kyrgyzstan duplicated the content of the quadrilateral agreement from 26 February 1999 on the same question, and was thus superfluous. 56 However, there are some problems with the argument that the bilateral treaty duplicated the quadrilateral agreement. The agreement between Kyrgyzstan and Russia about the simplified naturalisation procedure set forth two possible methods of naturalization: 1) choice of Russian citizenship for permanent residence in Russia (in this case citizens applied to the authorities of the FMS after arrival on the territory of the Russian Federation); 2) choice of Russian citizenship with the possibility of subsequent permanent residence in Kyrgyzstan (in this case citizens had to apply to the Embassy or the Consulate General of the Russian Federation in Osh in order to obtain Russian citizenship). Following the presidential decree of 19 October 2011, citizens of Kyrgyzstan have the right to apply for Russian citizenship only on the territory of the Russian Federation. All applicants must have permanent residence in Russia and an official permanent residence permit (‘vid na zhitelstvo’ - ‘*1- "& ,1/#$6./*)’). Factual acquisition of Russian citizenship by Kyrgyz citizens in diplomatic and consular missions of the Russian Federation in Kyrgyzstan became impossible after October 2011. Furthermore, there are certain differences between the bilateral and quadrilateral agreements regarding registration of citizenship. According to the quadrilateral agreement an application for 55 Yulia Savina. With the residence permit. Novye Izvestia. 25.10.2011. [[$12 A&*1"&. A *1-)= "& ,1/#$6./*). «O)*'# 19*#./12», 25 );/2:+2 2011 %)-&.] http://uisrussia.msu.ru/docs/http/demoscope.ru/weekly/2011/0483/gazeta02.php 56 Denunciation of the Agreement. FMS: Russia will terminate the Treaty with Kyrgyzstan. Expert Online. 21.03.2012. [S#")".&D12 -)%)*)+&. TVA: ?)..12 +&./)+%"#/ -)%)*)+ . K1+%191#@. Expert Online. 21 =&+/& 2012 %)-&.] http://expert.ru/2012/03/21/denonsatsiya-dogovora/  56&$6(8'2&,7&5‹$XWKRU