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July 7, 2021
Foreign Companies in the Internet: What the New Law
Regulates and Who Needs to Comply
SberSolutions blog on
By Ivan Katyshev
Head of Tax and Legal Practice at SberSolutions
Alexandra Markina
SberSolutions lawyer
Drafted by:
On July 1, 2021, the new Federal Law "On the Activities of Foreign Persons in the Information and Telecommunication Network "Internet" on the Territory of the Russian Federation" No.236- FZ entered into force (with the exception of some provisions that will come into force later). Now, foreign companies operating in Russia exclusively in the Internet are required to comply with a number of new rules. Today we will figure out which companies fall under the new law and what exactly it regulates.
What the new law regulates
In short, the new law controls the relations that are associated with the activities of foreign organisations in the Internet on the territory of the Russian Federation - it establishes requirements for the process of doing business in Russia, the rights and obligations of foreign companies, new measures and requirements for the process of organizing and conducting these activities.

The scope of the law applies to companies that own sites, pages of sites or computer programs, access to which during the day is provided to more than 500 000 Internet users living in the Russian Federation.

In addition to the half-million audience, it's necessary to comply with one more condition from the below specified ones, so that the company was subject to the new law.
If none of the above conditions is met, and a foreign organisation owns an Internet site with an audience of more than 500,000 users, then the new law will not apply to it. If at least one of the conditions is proven, the foreign organisation is obliged to comply with the requirements of the new law.
Financial and HR outsourcing services for foreign companies, as well as a full range of legal services. You can get advice from a SberSolutions lawyer here.
If your foreign organisation is not the owner of an information resource or software, this does not mean that it cannot fall under the scope of the reviewed law. If you are:

  • a hosting provider or a person providing the placement of an information resource on the network, if the users of such a resource are, among others, on the territory of the Russian Federation;
  • a company which activities are related to ensuring the functioning of information systems or computer programs that are used in the Internet to receive messages from Russian citizens or to distribute advertisements aimed at Russian audience;
you also fall under the requirements and norms of the new legislative act.
What to do for foreign companies, operating in the Internet on the RF territory
The present Federal Law also provides for some changes, that foreign companies need to go through in order to work on the RF territory without any problems:

1. The most basic thing is to create a branch, open a representative office or register a legal entity on the territory of the Russian Federation.
SberSolutions offer legal support related to the selection of the form of doing and registering a business in Russia to foreign persons.
2. Place on your resource a special electronic form for Russian citizens applying (the form itself will be additionally presented in the legislative act after agreement with Roskomnadzor).

3. Register a personal account on the Roskomnadzor website and use it to interact with government services of Russia.

4. Install one of the programs (of course recommended by Roskomnadzor) to count the number of users of the resource.
Will there be any fines?
For sure, the law introduces liability for non-compliance with new norms and requirements.
If the identified violations are not eliminated, Roskomnadzor has the right to restrict access to information resources of a foreign company or prohibit search results.
In order to avoid troubles associated with Russian legislation, use the comprehensive services from SberSolutions. We will take care of personnel, bookkeeping and tax accounting, calculate salary and prepare reports, we will be always in touch and answer any questions you may have.

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