From September 01, 2025 important amendments to the legislation of the Russian Federation on advertising will come into force, in accordance to which a ban will be imposed in regard to advertising performed via digital platforms and information resources of foreign and international organizations considered and declared undesirable on the territory of the Russian Federation, via organizations liquidated on the basis of performance of extremist or terrorist activities, as well as via information platforms, access to which was restricted on the territory of the Russian Federation in accordance with the decision of state authorities.
For members of the advertising market (advertisers and advertising distributors), the said changes entail the necessity to review existing advertising strategies as well as to thoroughly check any website before placing advertising materials on it.
Practical risks:
1. the “advertising” in this case shall be defined as any content aimed at informing an unlimited number of people on a product, service or commercial offer, as well as at drawing attention to the advertised object.
2. as of today, such Internet platforms as Instargam*, Facebook** have already been recognized as undesirable or extremist, which means that posting content using such platforms can entail substantial penalties.
Violation of the new provisions of the legislation on advertising entails administrative liability and significant penalties: for individuals – from 2 to 2.5 thousand RUB, for officials – from 4 to 20 thousand RUB, for legal entities – from 100 to 500 thousand RUB.
Preparation for the upcoming legislative change can involve the following measures:
a. conduct of a comprehensive audit of current advertising campaigns with verification of all digital platforms and information resources via which advertising is currently performed;
b. ensuring that advertising materials are removed from potentially problematic sites and resources before legislative changes take effect;
c. development of a verification system for new business partners, digital platforms and information resources before launching advertising projects.
Furthermore, it should be noted that the legislator has not provided official comments or clarifications regarding the retrospective effect of the ban after September 01, 2025, for example, in relation to earlier advertising and informational publications. However, in order to avoid the potential consequences of formal interpretation of the ban, we recommend that businesses remove publications posted before September 01, 2025 on banned platforms, since all published and relevant content is subject to verification by the state authorities.
To sum up, the outlined legislative changes require members of the advertising market to carefully make choice of advertising platforms and business partners. Timely preparation will help your business to avoid potential penalties and other negative consequences. We recommend that you start adapting your advertising strategies to the new requirements as soon as possible.
Should you have any questions concerning the analysis of your current advertising strategy or the application of the new legislative changes in regard to advertising, our legal team will be glad to provide clarifications.
* Owned by Meta, which is recognized as extremist and banned in the territory of the Russian Federation.
** Owned by Meta, which is recognized as extremist and banned in the territory of the Russian Federation.
