News & Events http://sl.legal ru Thu, 23 Jul 2026 15:14:12 +0300 Right for repair: Draft law on transfer of technical documentation by manufacturers passes first reading http://sl.legal/tpost/right-for-repair-draft-law-on-transfer-o http://sl.legal/tpost/right-for-repair-draft-law-on-transfer-o?amp=true Thu, 09 Jul 2026 18:00:00 +0300 Publication What will change?

Right for repair: Draft law on transfer of technical documentation by manufacturers passes first reading

Русская версия | Japanese version | Chinese version

The Russian State Duma has passed in the first reading amendments* to the Consumer Protection Law. The draft law has been supported by the Russian Government and is highly likely to be adopted in the second and third readings before the end of the Spring parliamentary session in 2026. Under the draft law, the changes are to take effect on 1 March 2027.

The draft law is targeted at manufacturers of technically complex goods, primarily automotive vehicles, from China and other “friendly” countries. However, it may also affect manufacturers from “unfriendly” countries that continue to maintain presence in Russia.

What will change?

The current version of the Consumer Protection Law requires the manufacturer to ensure repair and maintenance, as well as production and supply of spare parts, throughout the service life.

The amendments introduce an additional obligation for the manufacturer to provide information (technical documentation) necessary for the maintenance and repair of the goods.

This applies in particular to vehicles that have been imported into the country in the absence of an official dealer, or in respect of which official dealers have not been supplied with the documentation required to arrange repairs, or do not share that documentation with independent service centres.

Access to the information will be granted to organisations and individual entrepreneurs engaged in trade, repair and maintenance. It is not yet clear who in particular will be entitled to receive the technical documentation, nor what the consequences will be for failing to provide it.

The procedure for the transfer and the scope of the technical documentation to be transferred will be determined by the Russian Government.

What is the main risk?

Under the draft law, the manufacturer must provide the information throughout the entire production run of the goods. Once production has been stopped, the obligation will continue to apply until the end of the service life.

The main risk is that if no service life has been set for the product, the obligation will apply for ten years from the date the product was handed over to the consumer.

Similar rules currently apply to the obligation to ensure the supply of spare parts.

Recommendations for businesses

Manufacturers should give careful consideration to setting service lives. To avoid the application of the ten‑year period, it is important to clearly record a justified service life for all categories of goods.

It is also necessary to assess the risks associated with transferring sensitive information to a practically unlimited circle of third parties engaged in repair and maintenance and to prepare service manuals that are sufficiently detailed to comply with the new requirements.

Possibly, the Government would later narrow the scope of such persons to so‑called official or authorised service organisations. We will keep you informed as to the status of this draft law and the adoption of bylaws by the Russian Government.

*In Russian

Contacts:

]]> AI training and content generation: practical risks for businesses http://sl.legal/tpost/ai-training-and-content-generation-pract http://sl.legal/tpost/ai-training-and-content-generation-pract?amp=true Tue, 07 Jul 2026 16:00:00 +0300 Publication The article for AEB Business Quarterly is available in Russian and English.

AI training and content generation: practical risks for businesses

Русская версия >>

In business the term artificial intelligence (“AI”) is so widely used nowadays that it can mean anything: from a recommendation system for an online store to a robotic customer support station.

However, in terms of copyright not all of these models are equivalent. Generative AI implies models capable of creating new content: text, images, audio, video or programme codes.

Taken together, these features are the cause of three major problems in copyright.

  • The use of third-party works during the training process,
  • A person’s creative contribution,
  • The risk of infringements in the course of content generation.

Authors:
  • Shermet Kurbanov, Co-Head of Intellectual Property & Digital Law, SL LEGAL
  • Elizaveta Isaeva, Associate, SL LEGAL
  • Elena Chetverikova, Associate, Intellectual Property and Technology Practice, Denuo

Download the PDF from the link >>.
]]> User authorisation and recommendation technologies: new fines for businesses http://sl.legal/tpost/user-authorisation-and-recommendation-te http://sl.legal/tpost/user-authorisation-and-recommendation-te?amp=true Tue, 30 Jun 2026 18:00:00 +0300 Publication The new rules will take effect on 7 July 2026.

User authorisation and recommendation technologies: new fines for businesses

Русская версия >>

On 26 June 2026, the President signed Federal Law* No. 199-FZ (the “Law”), which introduces administrative liability for various violations under the Information Law* related to user authorisation and the use of recommendation technologies.

Fines for authorisation via foreign services

Since 2023, owners of information resources (websites, applications, and information systems) have been required* to authorise Russian users exclusively through the following means:

  • Mobile phone number;
  • Unified Identification and Authentication System (UIAS) – “Gosuslugi” portal;
  • Unified Biometric System (UBS);
  • Other Russian services. A service is deemed Russian if a Russian citizen or Russian company directly or indirectly holds more than 50%.

Non‑compliance now carries the following fines:
Individuals
RUB 10,000 – 20,000 (EUR 112 – 225)
Officials and individual entrepreneurs
RUB 30,000 – 50,000 (EUR 338 – 564)
Legal entities
RUB 500,000 – 700,000 (EUR 5,642 – 7,899)
Authorisation via Apple ID, foreign email services, or foreign messengers is prohibited. These restrictions apply solely to users located within the territory of Russia.

Fines for violating recommendation technology requirements

The Law introduces fines for resource owners who fail to comply with the following requirements:

  • Informing users about the use of recommendation technologies;
  • Publishing the rules governing such technologies on the resource;
  • Displaying a contact email address and the company name (for individuals – full name) of the resource owner;
  • Prohibition of using recommendation technologies that infringe the rights and interests of citizens and organisations;
  • Prohibition of using the technologies to disseminate information that violates Russian law.

Fines for non‑compliance with any of the above are as follows:
Individuals (for the first violation)
RUB 10,000 – 20,000 (EUR 112 – 225)
Individuals (for the repeated violation)
RUB 20,000 – 40,000 (EUR 225 – 451)
Officials and individual entrepreneurs (for the first violation)
RUB 30,000 – 50,000 (EUR 338 – 564)
Officials and individual entrepreneurs (for the repeated violation)
RUB 60,000 – 100,000 (EUR 677 – 1,128)
Legal entities (for the first violation)
RUB 500,000 – 700,000 (EUR 5,642 – 7,899)
Legal entities (for the repeated violation)
RUB 1m – 1.4m (EUR 11,284 – 15,798)
Additionally, liability is introduced for failure to comply with a prescription of the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) to cease the use of recommendation technologies.

Fines for non‑compliance are as follows:
Individuals (for the first violation)
RUB 20,000 – 40,000 (EUR 225 – 451)
Individuals (for the repeated violation)
RUB 40,000 – 80,000 (EUR 451 – 902)
Officials and individual entrepreneurs (for the first violation)
RUB 60,000 – 100,000 (EUR 677 – 1,128)
Officials and individual entrepreneurs (for the repeated violation)
RUB 120,000 – 200,000 (EUR 1,354 – 2,256)
Legal entities (for the first violation)
RUB 1m – 1.4m (EUR 11,284 – 15,798)
Legal entities (for the repeated violation)
RUB 1.4m – 2.8m (EUR 15,798 – 31,597)
Recommendations

The new rules will take effect on 7 July 2026. Prior to that date, information resource owners are advised to:

  • Conduct an audit of their platforms to ensure compliance with the Information Law and Roskomnadzor requirements regarding recommendation technologies, including posting the relevant legal disclaimer and rules of use;

  • Adjust user authorisation methods by disabling login via foreign services. If an immediate shutdown risks mass account loss, arrange a gradual transition, allowing users to link an approved identifier to their existing account while subsequently blocking former login methods.

* In Russian
Authors
]]> Legal implications for businesses of countersanctions violations: key takeaways from the Russian Supreme Court http://sl.legal/tpost/legal-implications-for-businesses-of-cou http://sl.legal/tpost/legal-implications-for-businesses-of-cou?amp=true Mon, 29 Jun 2026 18:00:00 +0300 Publication The Supreme Court issued review covering application of countersanctions rules by Arbitrazh courts.

Legal implications for businesses of countersanctions violations: key takeaways from the Russian Supreme Court

Русская версия | Japanese version | Chinese version

The Russian Supreme Court issued long-awaited review* covering application by Arbitrazh (commercial) courts of countersanctions rules and regulations. The Review covers the following main issues:

  • The validity and legal consequences of transactions violating Russian countersanctions,
  • Procedural aspects of disputes involving the application of Russian countersanctions,
  • Intellectual property protection in the context of Russian countersanctions,
  • Exemptions from liability for non-performance of obligations due to foreign sanctions,
  • Jurisdiction of Russian courts in sanctions-related disputes,
  • Customs rules for goods subject to Russian countersanctions.

These topics are covered in more detail in our alert.

Transactions circumventing Russian countersanctions are null and void

  • The Supreme Court confirmed that transactions aimed at circumventing Russian countersanctions are void from the outset, regardless of whether the parties acted in good faith. Such transactions include:

1. Sale of real estate to a Russian entity controlled by a person from an “unfriendly” state, if prior approval from the Government Commission was not obtained (Section 1);

2. Transactions intended to establish foreign control over a strategic enterprise without prior Government Commission approval (Section 2);

3. Violations of the special procedure for fulfilling obligations under the countersanctions regime, including splitting payments to transfer more than RUB 10m (approx. EUR 114k) per month, and assignment of claims (Sections 3–5).

  • The Supreme Court clarified that assignment of a claim is allowed if the underlying obligation is not subject to the countersanctions regime (Section 6).

Procedural aspects of disputes involving Russian countersanctions

  • The court may, on its own initiative, assess whether an assignment of a claim is valid if the claim arises from an obligation subject to the countersanctions regime (Section 7).

  • A violation of the countersanctions regime may qualify as a newly discovered circumstance (Section 8). This means a final court judgment may be reopened and reviewed on that ground.

  • The court will refuse to approve a settlement agreement if it was concluded to circumvent the countersanctions (Section 9).

Intellectual property and Russian countersanctions

A key point of the review is that special economic measures do not limit the protection of exclusive rights of foreign companies.

  • The special payment mechanism (type “O” accounts) applies to all obligations owed to right holders from “unfriendly” states, including obligations arising from unauthorised use of intellectual property (Section 10).

  • The special payment mechanism does not apply to right holders that continue to operate in Russia and fulfil their contractual obligations. The right holder bears the burden of proving these circumstances (Section 11).

  • Compulsory licensing may be granted if a right holder abuses its intellectual property rights or otherwise acts in clear bad faith (Section 12).

This position is based on a series of court rulings in a long-running dispute between a U.S. manufacturer of an original medicinal product and a Russian generic manufacturer. The courts found that the volumes of the original product supplied to the Russian market were insufficient and held that such limited supply amounted to an abuse of intellectual property rights. In practice, this creates a presumption of bad faith on the part of right holders from “unfriendly” states that have reduced their supplies to Russia or significantly increased their prices, especially in the pharmaceutical sector. As a result, in compulsory licensing disputes, the burden of proof shifts to the “unfriendly” right holder, who must justify its pricing and show that the reduced supply is not sanctions-related.

Exemption from liability due to foreign sanctions

  • The following parties may be exempt from liability, including liability for damages:

1. A broker – for failing to execute a client’s instructions relating to foreign securities, if the failure results from sanctions imposed on a Russian stock exchange that the broker could not prevent or overcome (Section 13);

2. The payer’s bank – for failing to execute a payment order, if the transfer was blocked due to sanctions of which the bank was unaware and could not reasonably have known (Section 14).

In both cases, the Supreme Court clarified that foreign sanctions may constitute force majeure only where they objectively prevent performance of the relevant obligation.

Cross-border aspects of sanctions-related disputes

  • A Russian court may not refuse to hear an application for an anti-suit injunction in disputes involving persons subject to foreign sanctions solely because the contract contains an arbitration clause (Section 15).

  • Visa restrictions preventing Russian nationals from participating in court proceedings in an “unfriendly” state limit their right of access to justice (Section 16). In such cases, the Russian party may apply to a Russian court for an anti-suit injunction or bring a claim on the substance of the dispute.

  • Even if an arbitration clause exists, Russian courts retain jurisdiction over a dispute if it arises from foreign sanctions or if one of the parties faces obstacles in accessing justice abroad (Section 17).

  • Courts should consider the actual place of performance of the contract (Section 18). If the contract is performed in Russia, Russian courts have jurisdiction.

  • When considering recognition and enforcement of a foreign arbitral award issued in an “unfriendly” state, Russian courts must assess it for compliance with Russian public policy. If the arbitral tribunal consists of arbitrators from “unfriendly” states, their lack of impartiality and independence is presumed (Section 19).

  • Enforcement of an arbitral award in favour of an entity incorporated in an “unfriendly” jurisdiction may contradict Russian public policy (Section 20).

  • A Russian court may impose a monetary penalty for violating an anti-suit injunction by starting or continuing proceedings before a foreign court or arbitral tribunal (Section 21).

Customs issues

  • Commercial imports of goods subject to the countersanctions regime are only allowed under the customs transit procedure. Attempts to declare such goods as goods of the Eurasian Economic Union (EAEU) in order to import them into Russia constitute an abuse of rights (Section 22).

* In Russian

Authors

Should you have any questions, please do not hesitate to contact our experts.
Download PDF
English version >>
Russian version >>
Japanese version >>
Chinese version >>
]]> SL LEGAL is one of the best M&A teams in Russia http://sl.legal/tpost/sl-legal-one-of-the-best-mampa-teams-in http://sl.legal/tpost/sl-legal-one-of-the-best-mampa-teams-in?amp=true Fri, 26 Jun 2026 11:00:00 +0300 News According to Pravo.ru annual study.

SL LEGAL is one of the best M&A teams in Russia

Русская версия >>

Russian leading legal media Pravo.ru has released its latest Corporate Law ranking, highlighting the top firms for M&A support in Russia.

In the 2026 results, SL LEGAL strengthened its standing and confirmed its place among Russia's premier corporate practices, ranking in the following categories:

  • Top for M&A transactions
  • Top‑10 largest deals
  • Leaders by average deal value
  • Leaders in legal advisory

For more details, follow the link (in Russian) >>.

Contact:

Artashes Oganov, Partner, Head of Corporate / M&A, Head of Real Estate & Construction, artashes.oganov@sl-legal.ru
]]> Extended Producer Responsibility in Russia - rules for importers clarified http://sl.legal/tpost/experimental-extended-producer-responsib http://sl.legal/tpost/experimental-extended-producer-responsib?amp=true Thu, 25 Jun 2026 18:00:00 +0300 Publication The new rules will affect goods imported between 01.09.2026 and 01.09.2027.

Extended Producer Responsibility in Russia - rules for importers clarified

Русская версия >>

As we previously reported, the experimental period for the new Extended Producer Responsibility (EPR) mechanism for specific categories of imported goods was extended at the end of last year.

At that time, however, the rules for conducting the experiment during its extended period had not yet been established. Therefore, importers of goods covered by the experiment were required to pay the environmental fee and submit reports according to the general procedure – by 15 April of the year following the reporting period.

Government Decree* No. 650 as of 30 May 2026 has now clarified the position. For goods participating in the experiment that will be imported into Russia between 1 September 2026 and 1 September 2027, importers will be required to pay the environmental fee in advance (prior to customs clearance) and submit report on the weight of imported goods separately for each consignment. For goods supplied outside this period, the general procedure will apply.

No other significant changes have been made to the experimental rules so far. At the same time, discussions continue on a draft law* which, inter alia, provides for:

  • Introduction of a deferral of up to 90 days from the date of import for payment of the environmental fee and submission of the report on the weight of imported goods; and
  • Removal of the suretyship agreement from the list of available methods for securing the environmental fee payment in case of failure to independently fulfil waste disposal obligations.

If the draft law is adopted, we can expect further clarification to the experimental procedure.

We will continue to monitor developments in EPR regulation.

* In Russian

Author:

Dmitry Bogdanov, Counsel, Head of Environmental Law, dmitry.bogdanov@sl-legal.ru
]]> Russia restricts bank deposits for non-residents from “unfriendly” countries http://sl.legal/tpost/restrictions-on-bank-deposits-for-non-re http://sl.legal/tpost/restrictions-on-bank-deposits-for-non-re?amp=true Fri, 19 Jun 2026 15:00:00 +0300 Publication The restrictions entered into force on 1 June 2026.

Russia restricts bank deposits for non-residents from “unfriendly” countries

Русская версия | Japanese version

Presidential Decree No. 377*, which entered into force on 1 June 2026, introduces a targeted but highly significant amendment to the existing counter-sanctions regulatory framework established by Decree No. 95* of 5 March 2022. Previously, the special procedure for fulfilling obligations to foreign creditors from the so-called “unfriendly“ states applied to transactions involving loans, borrowings, and financial instruments. The new Decree explicitly extends its scope to include bank deposits of foreign companies and individuals from “unfriendly“ countries who are not currency residents of the Russian Federation. At the same time, the new restrictions should not affect transactions of Russian legal entities.

The threshold of RUB 10 m (approx. EUR 118,000) per month established by Decree No. 95 now applies to deposit transactions as well. Since this limit is calculated on the basis of the bank’s aggregate obligations to all foreign creditors falling within the scope of Decree No. 95, in practice it may be exhausted quickly.

Upon deposit closure and interest payment, banks will be required to transfer funds to Type “C” accounts, which may only be disposed of with a separate permit from the Government Commission.

Comments
The purpose of this regulatory expansion is to close a previously available channel for withdrawing funds, including interest on deposits, that had allowed parties to circumvent counter-sanctions mechanisms. Non-residents associated with “unfriendly” states and Russian companies with existing deposit agreements involving foreign counterparties are advised to review their payment flows in light of the new restrictions, and to monitor official clarifications from the Bank of Russia, though such clarifications have not yet been published. We will keep you posted on any updates.
* In Russian

Authors:

]]> Draft Law on Scientific Consulting for Pharmaceutical Industry submitted to the Russian State Duma http://sl.legal/tpost/draft-law-on-scientific-consulting-for-p http://sl.legal/tpost/draft-law-on-scientific-consulting-for-p?amp=true Fri, 05 Jun 2026 10:00:00 +0300 Publication Read the alert prepared by our Life Sciences & Healthcare practice.

Draft Law on Scientific Consulting for Pharmaceutical Industry submitted to the Russian State Duma

In April 2026, a draft law (ID 1215377-8) introducing amendments to the Federal Law “On Circulation of Medicines” No. 61-ФЗ dated 12 April 2010 (the “Federal Law No. 61”) was submitted to the State Duma. It extends and clarifies the existing framework for scientific consultations concerning the development of medicines.

Currently, scientific consultations regarding medicines for human use are regulated by Article 13(7) of the Federal Law No. 61 and the Order of the Russian Ministry of Health No. 343н dated 30 May 2019 (the “Order”). Under these rules, a pharmaceutical company may request a paid scientific consultation from the Ministry of Health.

The proposed amendments introduce significant changes to the current approach to scientific consultations. A comparison of the current and proposed legal frameworks is set out in the table below.
Comparison Criterion
Current version
Proposed version
Timing
Not specified
Prior to submitting an application for state registration of a medicine
Consulting scope
- pre-clinical and clinical studies; - assessment of quality, efficacy and safety; - state registration.
- analytical studies; - pre-clinical and clinical studies; - various aspects of state registration (in particular, issues relating to qualification and type of the application, sufficiency of the registration dossier, necessity of providing samples and other materials for testing, etc.)
Responsible organisation
Subordinate educational and scientific organisations (excluding the ones responsible for the assessment within a state registration procedure)
Expert organisation responsible for the assessment within a state registration procedure (most likely, it will be the Federal State Budgetary Institution “Scientific Centre for Expert Evaluation of Medicinal Products”)
Consultants
Not defined
- certified experts having a relevant higher education; - other persons, subject to additional requirements to be established
Advice delivery
Written response only
- in-person consultation (minutes of the meeting are provided); - remote consultation (minutes of the meeting are provided); - written response
Impact on the state registration process
The advice is non-binding and does not predestinate further regulatory decisions
The advice is subject to inclusion into the registration dossier and shall be considered during the registration process
Publication of information
Basic information about consulting services, the content of requests and responses
Basic information about consulting services, summarised consulting results
If the draft law is adopted, the proposed amendments will come into force on 1 September 2026. The Ministry of Health will also issue regulatory acts on: (1) timing and procedure for consultations; (2) fees and payment procedures; and (3) categories of medicines eligible for priority consulting.

The extension of the consulting scope, the inclusion of the expert organisation in the consultation process, and the integration of its results into the registration dossier make the new framework of scientific consulting an attractive tool for mitigating regulatory risks at the market launch stage.

If adopted, we recommend that pharmaceutical companies strenghthen their regulatory strategies with the new form of scientific consulting, especially in respect of sensitive elements of the Russian drug pipeline.

*In Russian

Authors

Life Sciences & Healthcare practice of SL LEGAL advises on all issues related to the circulation of medicines, including their market launch in Russia and EAEU.
]]> Russian courts expand their jurisdiction over international disputes http://sl.legal/tpost/russian-courts-expand-their-jurisdiction http://sl.legal/tpost/russian-courts-expand-their-jurisdiction?amp=true Wed, 20 May 2026 18:00:00 +0300 News Article for Asia Business Law Journal.

Russian courts expand their jurisdiction over international disputes

Русская версия >>

When sanctions are involved, Russian courts can now assert jurisdiction over disputes that parties intended to resolve in international arbitration. This article explains what the latest Russian Supreme Court rulings mean for Asian businesses.

Before 2020, most high-profile disputes involving Russian entities and individuals were resolved abroad. The London Court of International Arbitration served as the preeminent hub, favoured for its sophisticated arbitration framework. The International Chamber of Commerce and Stockholm Chamber of Commerce were also preferred venues. The use of Asian arbitral institutions, such as CIETAC, HKIAC and SIAC, was limited by Russian parties. But in 2020, amendments to the Russian Commercial Procedure Code conferred exclusive jurisdiction of Russian courts over disputes involving sanctioned Russian individuals and legal entities.

Under the CPC, exclusive jurisdiction of Russian Arbitrazhcourts covers disputes involving parties subject to Russia-related sanctions; or arising from such sanctions and involving Russian and/or foreign parties (even if no party is sanctioned). Such parties may apply to the Russian court for resolution of the dispute on its merits and/or an anti-suit injunction. The key provision for Asian companies is that these remedies may be used despite any arbitration agreements if sanctions make recourse to a foreign forum – whether CIETAC, HKIAC, SHIAC or SIAC – 'impossible to perform'. Russian courts interpret this broadly.

Our experts Georgy Daneliya, Natalia Kozyrenko and Igor Sokolov have prepared a comprehensive overview for the eminent legal magazine – Asia Business Law Journal.

Read the full article on asia.law.
]]> SL LEGAL advises on launch of Rosagroleasing’s pilot AgTech project http://sl.legal/tpost/sl-legal-advises-on-launch-of-rosagrolea http://sl.legal/tpost/sl-legal-advises-on-launch-of-rosagrolea?amp=true Thu, 14 May 2026 15:00:00 +0300 News Under the leadership of Artashes Oganov, partner of SL LEGAL.

SL LEGAL advises on launch of Rosagroleasing’s pilot AgTech project

Русская версия >>

Moscow, 14 May 2026 – SL LEGAL has advised on the establishment of a joint venture (JV) between JSC Rosagroleasing and the firm’s client, private agricultural company. The JV provides end-to-end support across all stages of the agricultural process – from bringing land into use, sowing, and cultivation to harvesting and crops primary processing.

The partnership with Rosagroleasing, Russia's largest leasing company for the farming sector, will allow the client to significantly leverage its industry expertise and unique agrotechnical know-how, while also expand its geographic footprint and range of services. This transaction sets a powerful precedent for successful public-private collaboration in the agricultural sector. The JV has formed a Machinery and Technology Company (MTC), which is already rolling out a full-cycle agrotechnical project in Russia’s Central Federal District.

The SL LEGAL team was led by Artashes Oganov, Partner, Head of Corporate. The team prepared the full set of transaction documents in record time, including complex corporate governance arrangements and mechanisms for future share transfers among JV participants linked to financial performance. The team also included Anastasia Chapurina, Senior Associate (Corporate), and Elizaveta Isaeva, Junior Associate (Corporate).

Artashes Oganov comments:
“We developed a set of option agreements that gives the JV partners flexibility in managing shares – no need to amend the shareholders' agreement each time, based on how they perform against agreed KPIs. We delivered this project in an exceptionally short timeframe, and its structure could serve as a model for JV partners looking to roll out similar projects in other Russian regions."

Contacts:

Artashes Oganov, Partner, Head of Corporate/M&A, artashes.oganov@sl-legal.ru.
]]> Yulia Smourova joins the management of the Tax Committee of the German-Russian Chamber of Commerce http://sl.legal/tpost/yulia-smourova-joins-the-management-en http://sl.legal/tpost/yulia-smourova-joins-the-management-en?amp=true Fri, 08 May 2026 12:00:00 +0300 News Yulia appointed Deputy Chair of the Tax Committee for a term of two years.

Yulia Smourova joins the management of the Tax Committee of the German-Russian Chamber of Commerce

Русская версия >>

We are pleased to announce the appointment of Yulia Smourova, Partner, Co-Head of Tax at SL LEGAL, as Deputy Chair of the German-Russian Chamber of Commerce.

Since 2024, Yulia has been actively working within the Tax Committee as the head of the working group on currency regulation. Now, in her new role as Deputy Chair of the Committee, Yulia, together with the committee team, will focus on advancing the interests of the Chamber’s members, forming a consolidated business position for the Federal Tax Service, organising meetings with government representatives and the business community, as well as addressing many other matters.

Yulia is a recognised expert with over 20 years of experience in tax law, currency regulation, and private wealth ownership and management advisory. She provides legal and tax support to Russian and international companies, banks, as well as private clients on matters related to the currency transactions regulation.

The Russian-German Chamber of Commerce (Kammer Russland) is the largest international business association in Russia, established in 2007 to support and develop economic cooperation between Germany and Russia. It represents the interests of German companies in the Russian Federation and Russian companies in Germany, bringing together around 900 members.

Contacts:

Yulia Smourova, Partner, Co-Head Tax, Currency Control SL LEGAL
E yulia.smourova@sl-legal.ru
T +7 495 134 22 00
]]> Mandatory registration and renewal of .ru /. рф / .su domains http://sl.legal/tpost/mandatory-registration-and-renewal-of-ru-domains http://sl.legal/tpost/mandatory-registration-and-renewal-of-ru-domains?amp=true Wed, 06 May 2026 21:12:00 +0300 Publication How to register and renew a domain

Mandatory registration and renewal of .ru /. рф / .su domains

Русская версия >>

As of 1 September 2026, the Federal Law No. 569-FZ* comes into force, introducing mandatory identification of domain name administrators through the Unified Identification and Authentication System (the “ESIA” or “Gosuslugi” portal).

The requirement applies to both Russian and foreign legal entities and individuals acting as domain name administrators or planning to register a domain.

According to the draft Government Resolutions currently under review (ID 166378* and ID 166376*), the new rules will apply to .ru / .рф / .su domains. They will affect not only new domain names but also previously registered domain names. It will be impossible to renew a domain name without confirming the administrator’s data through the Gosuslugi portal.

Proposed registration procedure

To register a domain name, the applicant must:

  • Submit an application on the registrar’s website and enter into a service agreement with the registrar,
  • Authenticate via the Gosuslugi portal at the time of submitting the application, and
  • Provide consent for the registrar to access certain personal information about the applicant.

Following successful verification, registrars enter the domain names and administrator data into the Domain Name Registry. However, only registrars included in the “white list” are authorised to do so. This list is maintained by specialised non‑profit organisations* (referred to as coordinators).

Domain names are registered for one year. Registration can be renewed an unlimited number of times. To renew, the administrator must have a Gosuslugi account and submit an application to the registrar two months before the registration expires.

Coordinators will also maintain a “stop list” of domain names that are not permitted for registration.

Practical conclusions and recommendations

To comply with the new rules, domain name administrators should take the following steps:

  • Complete identification via the ESIA when registering a domain name,
  • Maintain a valid ESIA account for domain name renewal purposes, and
  • Transfer the domain name to another registrar if the current registrar is not included in the “white list.”

These amendments are intended to enhance the transparency of the Russian internet segment and provide effective protection for internet users against fraudulent activities. We recommend that companies audit their registered domain names in the .ru / .рф. / .su zones, create an ESIA account in advance if necessary, and re‑register their domain names.

*In Russian

Authors

]]> SL LEGAL advised on “Deal of the Year” at the CRE Moscow Awards 2026 http://sl.legal/tpost/sl-legal-advised-on-deal-of-the-year-at http://sl.legal/tpost/sl-legal-advised-on-deal-of-the-year-at?amp=true Mon, 27 Apr 2026 16:00:00 +0300 Deals News On 23 April 2026, the winners of the CRE Moscow Awards 2026 were announced at the 23rd annual ceremony.

SL LEGAL advised on “Deal of the Year” at the CRE Moscow Awards 2026

Русская версия >>

The CRE Moscow Awards represent the highest distinction in Russia’s commercial real estate sector, recognising the most outstanding projects, companies, and industry professionals.

The “Deal of the Year: Sale and Purchase” was awarded to the acquisition of Outlet Village Belaya Dacha and Outlet Village Pulkovo by the investment holding company Kama Capital.

SL LEGAL acted as legal counsel to the purchaser. The team was led by Artashes Oganov, Partner and Head of the Corporate and Real Estate.

This marks the second consecutive year that a transaction handled by our team has received top honours at Russia’s most prestigious commercial real estate awards.

We are grateful to our clients for the opportunity to participate in landmark transactions and the award’s jury for this high recognition.

Learn more about the award and the winners >>.
]]> Tech M&A 2025 Study http://sl.legal/tpost/tech-ma-en http://sl.legal/tpost/tech-ma-en?amp=true Fri, 17 Apr 2026 20:12:00 +0300 Publication What’s Happening with Tech Deals in Russia.

Tech M&A 2025 Study

Русская версия >>

This week the first part of a comprehensive and unique study of the Russian market for tech asset deals based on the results of 2025 was published.

The study, spanning over 260 pages, covers a wide range of topics:

  • Overview of the Tech M&A market in 2025
  • Drivers of the Tech M&A market dynamics in 2025
  • Pre-IPO, IPO, and SPO deals in the TMT sector
  • M&A deals involving AI assets
  • AI technologies as a standalone transaction asset
  • Forecasts and outlook for 2026

Download the study (in Russian) >>.

The second part of the study will be released shortly.

This study is unique as well, having been produced by a team of leading advisory firms in the tech market: it was conducted by Anastasia Nerchinskaya, ALRUD, B1, and ADVANCE CAPITAL, with the support of our team at SL LEGAL, Denuo, and DFCenter.

The study also involved industrial players from the TMT sector and investment banks specialising in Tech M&A deals.
SL LEGAL team members involved in the study:
  • Artashes Oganov, Partner, Head of Corporate and M&A
  • Anastasia Dukhina, Senior Associate, Corporate and M&A
  • Shermet Kurbanov, Co-Head of IP & Digital Law
]]> SL LEGAL among the leaders of the Kommersant legal ranking http://sl.legal/tpost/sl-among-the-leaders http://sl.legal/tpost/sl-among-the-leaders?amp=true Fri, 10 Apr 2026 19:16:00 +0300 News SL LEGAL recognised in 15 nominations.

SL LEGAL among the leaders of the Kommersant legal ranking

Русская версия >>

On 9 April 2026, Kommersant Publishing House released the results of its annual ranking “Leaders of the Legal Services Market – 2026”.

According to the new survey, SL LEGAL has been recognised in 15 nominations, with 8 lawyers receiving individual recognition across 18 practice areas.

Top Legal Practices:

  • International Trade: Customs Regulation – Band 2
  • International Trade: Currency Regulation – Band 2
  • Personal Data Protection – Band 1
  • Intellectual Property – Band 4
  • Corporate Law: M&A of Russian Assets (High-end) – Band 3
  • International Litigation – Band 2
  • Tax Law Advisory (High-end) – Band 3
  • Insurance – Band 1
  • Employment and Migration – Band 1
  • Digital Economy / Fintech – Band 2
  • Environmental Law – Band 2

Top Industry Practices:

  • Healthcare and Pharmaceuticals: advising leaders in the healthcare services and pharma industries – Band 2
  • Retail, Trade & FMCG: advising industry leaders – Band 2
  • Finance and Banking: Advising leaders in the financial and banking sector – Band 2
  • Private Clients – Band 3

Top Lawyers:

o Insurance (Band 1)
o International Dispute Resolution (Band 2)
o Personal Data Protection (Band 1)
o Digital Economy / Fintech (Band 2)
o Transport and Logistics (Band 2)
o TMT: Telecommunications, Media, Technology (Band 2)

o Corporate Law / M&A of Russian Assets (Band 2)

o Banking & Finance (Band 2)


o Tax (Band 3)
o Digital Economy / Fintech (Band 2)
o International Trade: Customs Regulation (Band 2)
o Retail, Trade & FMCG (Band 2)

o Employment (Band 1)
o Digital Economy / Fintech (Band 1)
o TMT: Telecommunications, Media, Technology (Band 2)

We congratulate the team on this achievement, thank the researchers for their work, and thank our clients for the opportunity to support their projects.

More details about the ranking results can be found via the link >>.

Contacts:
press@sl-legal.ru
]]> SL LEGAL named among top firms for client support in the UAE http://sl.legal/tpost/njy5v95ap1-sl-legal-named-among-top-firms-for-clien http://sl.legal/tpost/njy5v95ap1-sl-legal-named-among-top-firms-for-clien?amp=true Wed, 08 Apr 2026 19:29:00 +0300 News According to Pravo.ru annual study.

SL LEGAL named among top firms for client support in the UAE

Русская версия >>

Pravo.ru has released the results of its annual study on legal services for businesses in the United Arab Emirates.

This year, SL LEGAL has been ranked in four most competitive and client-focused practice areas:

  • Corporate / M&A (Group 2)
  • Tax (Group 2)
  • Private Wealth (Group 2)
  • General Legal Support (Group 3)

We congratulate our colleagues and thank the Pravo.ru team for their comprehensive study.
This recognition is a true reflection of our deep expertise and proven experience in the region. We help our clients succeed within it, offering effective legal solutions in one of the most dynamic business environments in the world.
More details (In Russian) >>.
]]> Leonid Zubarev to speak at the AEB meeting on Cyber Risk Insurance: Current Trends and New Challenges http://sl.legal/tpost/upp070hlb1-leonid-zubarev-to-speak-at-the-aeb-meeti http://sl.legal/tpost/upp070hlb1-leonid-zubarev-to-speak-at-the-aeb-meeti?amp=true Mon, 06 Apr 2026 12:51:00 +0300 Events Date: 08.04.2026

Leonid Zubarev to speak at the AEB meeting on Cyber Risk Insurance: Current Trends and New Challenges

Русская версия >>

On 8 April 2026, Leonid Zubarev, Partner and Head of Insurance at SL LEGAL, will take part in the Association of European Businesses (AEB) Insurance Committee meeting titled Cyber Risk Insurance: Current Trends and New Challenges.

Leonid will give a presentation on Legal Aspects of Cyber Risk Insurance.

Other topics include:
  • Analysis of the cyber incident market
  • Overview of the cyber insurance market

The program features speeches from representatives of AEB member companies: Turikum Insurance Company, Zetta Insurance Company, and Kaspersky Lab.

The event will also feature Vanessa Vargas, Insurance law expert from the Ibero-Latin American Committee of AIDA (CILA), who will present an overview of the cyber insurance market in Latin American countries.

Details:
  • Date: Tuesday, April 8, 2026
  • Meeting time: 4:00 PM – 6:00 PM (Moscow time)
  • Format: Hybrid (in-person / online)
  • Languages: Russian, English

To register, contact: Polina Skorovarova, polina.skorovarova@aebrus.ru
]]> Supreme Court upheld Federal Antimonopoly Service in dispute on unlawful market launch of generic drug http://sl.legal/tpost/supreme-court-upheld-federal-antimonopoly-service http://sl.legal/tpost/supreme-court-upheld-federal-antimonopoly-service?amp=true Sat, 04 Apr 2026 09:30:00 +0300 Publication This position can change the pro-generic approach.

Supreme Court upheld Federal Antimonopoly Service in dispute on unlawful market launch of generic drug

Русская версия >>

In 2024, the Federal Antimonopoly Service (the “FAS”) issued several decisions in favour of originator companies in response to their complaints on unlawful circulation of generic products before expiration of patent protection for the brand-name drugs. Initially, this seemed to be a new and effective strategy for protecting the originators’ interests.

However, in 2025 the trend shifted. Generic companies succeeded in challenging the FAS’s decisions. Courts consistently overturned orders against companies marketing generic “Axitinib”, “Osimertinib”, “Ruxolitinib”, and “Bosutinib”. As a result, by the end of the year the industry concluded that a pro-generic approach had already become a stable judicial practice*.

However, the situation changed again in this March, when the dispute on “Axitinib” was examined** by the Russian Supreme Court. In its decision, the Supreme Court upheld the antimonopoly authority, which had previously initiated proceedings against “Axelpharm” under the complaint of the originator, and ordered “Axelpharm” to transfer approximately RUB514m (approx. EUR 5,5m) to the state budget.

The Supreme Court’s ruling formulates legal positions that sharply contrast with the pro-generic approach previously formed in the lower courts. The comparison of the positions on the most significant issues is set out in the table below.
Issue
Positions of Lower Courts
Position of the Supreme Court
Whether the existence of competitive relations between a patent holder and an infringer is a mandatory condition for qualifying the latter’s actions as unfair competition?
Yes For the application of Article 14.5 of the Federal Law “On Protection of Competition” the existence of competitive relations directly between an infringer and a patent holder must be established (Decision of the 9th Appeal Arbitrazh Court as of 16.12.2025*, and as of 15.12.2025*).
No An infringement of IP rights may be recognized as unfair competition not only in cases where a patent holder directly competes with an infringer, but also in other cases of causing harm to rightsholder’s interests.
Is it possible to ascertain the use of an invention on the basis of indirect evidence?
No Patent expertise is mandatory for ascertaining the use of an invention (Decision of the Arbitrazh Court of Moscow as of 27.11.2025*). An administrative authority’s decision based on assumptions or conjecture is unlawful (Decision of the 9th Appeal Arbitrazh Court as of 15.12.2025*).
Yes Obligation to conduct patent expertise leads to an unreasonably high standard of proof. A finding of infringement of IP rights may be made by the FAS based on cumulative evidence: specialists’ reports, facts ascertaining the circulation, extracts from the Eurasian Pharmaceutical Register, etc.
Can preliminary actions aimed at the lawful use of an invention (for example, applying for a compulsory license) prove the use of an invention?
No The choice of legal remedies cannot prove an infringement (Decision of the 9th Appeal Arbitrazh Court as of 16.12.2025*).
Yes Obligation to conduct patent expertise leads to an unreasonably high standard of proof. A finding of infringement of IP rights may be made by the FAS based on cumulative evidence: specialists’ reports, facts ascertaining the circulation, extracts from the Eurasian Pharmaceutical Register, etc.
Is the FAS competent to independently examine unfair competition cases related to the unlawful use of intellectual property?
No Some courts noted that the antimonopoly authority is not competent to resolve the cases involving patent infringement (Decision of the 9th Appeal Arbitrazh Court as of 17.07.2025*).
Yes The Supreme Court has not commented on this issue directly, but the FAS’s decision would hardly have been upheld if the service had not originally had the competence.
The Supreme Court’s position can change the pro-generic approach established in judicial practice. Following the Supreme Court’s decision, in the dispute concerning “Osimertinib” the cassation instance has already overturned the lower courts’ decisions, ruling in favour of the FAS. In April, there will also be appeal hearings regarding the disputes on “Ruxolitinib” and “Bosutinib”.

The Supreme Court’s position may encourage patent holders to more actively use the antimonopoly track of protecting their interests. Considering the balance of outcomes, speed, and costs, this mechanism may be more efficient than traditional court litigation.

* We have previously overviewed the history of unfair competition disputes between originator and generic companies. Our materials on this are available at the following links: [1], [2; p. 10]*.
** All links to judicial documents are in Russian.
Links:
Authors
]]> SL LEGAL ranked among top legal M&A advisors http://sl.legal/tpost/7k6i6xj491-sl-legal-ranked-among-top-legal-mampa-ad http://sl.legal/tpost/7k6i6xj491-sl-legal-ranked-among-top-legal-mampa-ad?amp=true Mon, 30 Mar 2026 13:22:00 +0300 According to mergers.ru study.

SL LEGAL ranked among top legal M&A advisors

Русская версия >>

For the second consecutive year, SL LEGAL has been named among the leading legal advisors in the annual M&A Consultants Ranking, prepared by the information and analytical agency PREQVECA as part of its mergers.ru: Mergers and Acquisitions in Russia project.

Based on the results of last year, SL LEGAL's M&A team was recognised as a leader in several categories: total number of deals, aggregate deal value, and overall advisor activity.

The mergers.ru ranking draws on both market participant data and public sources – an approach that has made it one of the most trusted benchmarks for M&A-activity in the market.

In addition to legal advisors, the study also evaluates investment, financial, and GR consultants. The 2025 ranking featured 26 legal advisors, 9 investment advisors, 5 financial advisors, and 1 GR advisor.

For more details, follow the link (in Russian) >>.
Key contact:

]]> New rules for foreign investors in strategic sectors in Russia http://sl.legal/tpost/new-rules-for-foreign-investors-in-strategic-sectors http://sl.legal/tpost/new-rules-for-foreign-investors-in-strategic-sectors?amp=true Fri, 27 Mar 2026 16:00:00 +0300 Publication More companies and assets now under control.

New rules for foreign investors in strategic sectors in Russia

Русская версия | Japanese version | Chinese version

On 8 March 2026, the President has signed Federal Law* No. 51-FZ, which introduces extensive amendments to the Law on Foreign Investments in Strategic Companies, as well as to a number of related legislative acts.

The law is aimed at strengthening foreign investments control. Most of the amendments will enter into force on 7 June 2026. Below is a brief overview of the key changes.
1. More companies and assets now under control
The requirements of the new law apply not only to companies engaged in strategic activities, but also to those holding licences for such activities. Even if they do not actually carry them out.

  • State and municipal property subject to Government Commission control

Foreign investors must now obtain prior approval from the Government Commission before acquiring state or municipal property that is used for strategic activities.

  • Non-Profit Organisations (NPOs) controlled by foreign entities must obtain approval for strategic activity licences

The requirements of the law now explicitly extend to non-profit organisations. This applies to transactions resulting in foreign investors acquiring control over NPOs engaged in strategic activities, as well as to the acquisition of their fixed assets (valued at 25% or more of the book value of total assets). In addition, NPOs under control of foreign investors are required to obtain approval for the acquisition of licences for strategic activities.
2. Expansion of the list of strategic activities
  • Subsoil use

Regulatory control now extends not only to deposits of federal significance, but also to fields with smaller reserves. For example, this includes fields with oil reserves ranging from 50 to 70m tonnes or gas reserves from 30 to 50bn cubic meters. The list has also been expanded to cover users of subsoil plots containing groundwater, where extraction exceeds 3,000 cubic meters per day and the water is intended for commercial sale.

  • Fisheries and processing

Fish processing companies are now classified as strategic companies if more than 50% of their revenue is derived from core operations and the value of their assets (including those of the group) exceeds RUB 800m (ca. EUR 8,4m). In addition, the breeding of Pacific salmon has been designated as a strategic activity.
3. New requirements for transactions and investor obligations
  • Disclosure of beneficial owners in transactions subject to prior approval

When filing an application for transaction approval, the applicant is now required to provide information on beneficiaries, beneficial owners, and controlling persons. If this information is missing, the application will be returned without consideration.

  • Approval of transactions

Transactions are subject to approval by the Government Commission if a foreign investor gains the power to exercise more than 10% of the voting rights (or to appoint more than 10% of the management bodies) in a company holding subsoil plots of federal significance, where the company obtained those rights under specific circumstances (including reorganisation, bankruptcy, etc.).

  • Notification of minority shareholdings

Foreign investors holding 5% or more in a company are required to notify the Federal Antimonopoly Service of Russia (FAS Russia) if the company gains strategic status (for example, by obtaining a licence or rights to extract aquatic biological resources).
4. Transitional provisions and implications for existing owners
The law establishes special transitional periods for companies newly classified as strategic due to the inclusion of new activities (such as fish products and aquaculture):

  • Within 180 days from the law’s entry into force – i.e., by 3 December 2026 – foreign investors holding 5% – 50% of voting rights must provide information on ownership structure to the FAS Russia.
  • Within 365 days – i.e., by 7 June 2027 – foreign investors holding more than 50% of voting rights must either file an application for approval of control or divest shares to 50% or less.

Important: If these requirements are not met, a court may deprive the foreign investor of its voting rights.
5. Other amendments
The changes also extend to the following laws:

  • Law On Transport Safety*: Clarified the procedure for confirming the absence of foreign control when accrediting legal entities as transport security units.
  • Law On Protection of Competition*: Expanded the list of beneficial owner information required for transaction approval.
  • Law On Fishing and Preservation of Aquatic Biological*: Established a mechanism for returning rights to extract aquatic biological resources to companies that are now more than 75% state-owned.
Recommendations
The new rules will come into effect on 7 June 2026. We recommend that foreign investors and companies with foreign participation:

  1. Audit their current ownership structures to identify any involvement in strategic activities, including the newly added ones (subsoil use, fish processing).
  2. Keep in mind the established transitional deadlines (180 and 365 days) for filing notifications or applications to the FAS Russia.
  3. Take into account the expanded scope of control for new transactions: transactions involving state property and NPOs are now regulated, and disclosure requirements have been tightened.

* In Russian

Authors:

]]> New rules for use of foreign words in consumer information http://sl.legal/tpost/new-rules-for-use-of-foreign-words-en http://sl.legal/tpost/new-rules-for-use-of-foreign-words-en?amp=true Thu, 19 Mar 2026 16:00:00 +0300 Publication Such information must now be provided in Russian or in both Russian and a foreign language.

New rules for use of foreign words in consumer information

Русская версия >>

On 1 March 2026, amendments* to the Law of the Russian Federation “On Protection of Consumer Rights” No. 2300-1 dated 7 February 1992 (the “Consumer Law”) came into force. These amendments introduce restrictions on the use of foreign languages in public information intended for consumers. Such information must now be provided in Russian or in both Russian and a foreign language.[1]
What information is subject to the new requirements?
The new requirements regarding the use of the Russian language apply to public information intended for consumers. This refers to information that:

  1. is not an advertisement or mandatory information about a product, its manufacturer, or other mandatory disclosures (e. g. information on product packaging; Articles 8–10 of the Consumer Law),
  2. is placed in publicly accessible locations and/or communicated to consumers at large,
  3. is communicated through signage or other means of displaying information (including inscriptions, signs, external surfaces, information plates, information signs, installations, technical devices, and other media intended for disseminating information, excluding advertising installations),
  4. is provided as part of dealing with customers.

Based both on a literal interpretation of the above wording (considering, in particular, the reference to “signage or other means of displaying information”) and on the explanatory note* to the amendments, the new requirements should apply only to information displayed on tangible objects, such as stands, installations, pointers and so on.

However, the Federal Service for Surveillance on Consumer Rights Protection and Human Wellbeing (“Rospotrebnadzor”) applies a broad interpretation of the term “publicly accessible location”, extending it to the Internet (Section II of the Guidelines* on Compliance with Mandatory Requirements, approved by Rospotrebnadzor on 2 March 2026 (the “Guidelines”)).

As a result, in practice, the new requirements will apply not only to information displayed on tangible objects, but also to online resources through which companies deal with consumers.
What relationships are subject to the new requirements?
The requirements apply only to relationships governed by the Consumer Law, i. e. relationships involving consumers.

This scope of the new requirements is also emphasized in the Rospotrebnadzor’s guidance, which states that manufacturers, providers, and sellers of goods, works, and services intended for consumers are the only entities that fall under the new requirements (Section II of the Guidelines).

Thus, the new requirements do not apply if (1) the information is not accessible to consumers (for example, internal corporate communications or information displayed in staff-only areas), or (2) the company is not a manufacturer, provider, or seller under the Consumer Law, meaning it operates in B2B only.
Substance of the new requirements
The information must be presented either in Russian or in both Russian and a foreign language. In the latter case, the information in Russian and a foreign language must be:

  1. identical in content;
  2. equivalent in placement and in technical formatting (i. e. with the same parameters of color, font type, and size);
  3. legible;
  4. identical in content, pronunciation, and mode of transmission (applies to audio information).

Furthermore, the use of a foreign language is permitted only as a supplement to Russian. In duplicate translations (e. g. “магазин / shop”) the text in Russian must go first (Article 10.1(3) of the Consumer Law, Section II of the Guidelines).

Consumer information must comply with the norms of Russian language, as established in dictionaries and grammars approved by the Russian Government. Currently, only four dictionaries have been approved*. In particular, when using Russian words borrowed from foreign languages (e. g. “чат”, “прайс лист”, “маркетплейс”, “бестселлер”, “лайк”), the Dictionary* of Foreign Words must be checked in advance. If a borrowed word is not included in the dictionary, its use is not permitted.

4.Exemptions

The new rules shall not apply in the following cases:

  • when using trademarks and service marks registered in Russia (including under international registrations);
  • when using company trade names registered in the Unified State Register of Legal Entities;
  • in other cases provided for by technical regulations, acts of the Eurasian Economic Union, federal laws, and other normative legal acts.

In the cases listed above, words not included in the approved dictionaries, as well as words in a foreign language, may be left untranslated.

5.Liability for non-compliance with the new requirements

No specific liability is established for violations of the new requirements. Nevertheless, Rospotrebnadzor may potentially apply one of the following Articles of the Code of Administrative Offenses of the Russian Federation (“AOC”):
Description of the Offence
Fine for Company Officials
Fine for Legal Entities
Breach of the consumer’s right to obtain necessary and accurate information, if goods have not been sold (Article 14.8(1) of AOC)
up to RUB 1 000 (approx. EUR 10)
up to RUB 10 000 (approx. EUR 100)
Breach of the consumer’s right to obtain necessary and accurate information, if goods have been sold (Article 14.5(1) of AOC)
up to RUB 4 000 (approx. EUR 40)
up to RUB 40 000 (approx. EUR 420)
Deception of the consumer (Article 14.7(2) of AOC)
up to RUB 20 000 (approx. EUR 210)
up to RUB 500 000 (approx. EUR 5 200)
Recommendations
If a business involves working with consumers or producing consumer goods, further recommendations can be considered:

  • Conduct an audit of information available to consumers, including signage, websites, social media, information boards, menus, and price lists. Special attention should be paid to online resources, which are also subject to the new requirements.
If information is found in a foreign language, it must be duplicated in Russian in compliance with the requirements from this material.
  • Verify whether key company brands are registered as trademarks or service marks. Where possible, register such brands.

[1]The rules set out in this material regarding the use of foreign languages apply similarly to the use (when allowed by local laws of the regions of Russia) of the official languages of the Russian regions and other languages of the peoples of Russia.
Authors:
Downloads
| PDF in English >> | PDF in Russian >>
]]> 15 SL LEGAL lawyers individually ranked by Pravo-300–2026 http://sl.legal/tpost/pravo300-individual-en http://sl.legal/tpost/pravo300-individual-en?amp=true Wed, 25 Feb 2026 15:52:00 +0300 News Receiving recognition in 13 practices.

15 SL LEGAL lawyers individually ranked by Pravo-300–2026

Русская версия >>

The annual individual ranking Pravo-300-2026 is live today. 15 our lawyers received high praise in their respective practice areas. This significant achievement confirms the high level of expertise of our specialists and strengthens the firm’s reputation in the legal market.

Pravo-300 is an independent annual ranking of Russian law firms and legal professionals. It is one of the most prestigious and comprehensive guides to the legal market in Russia.

The list of lawyers and practices recognised in the ranking:

Dmitry Bogdanov
  • Land Law
  • Real Estate, Land, Construction (Advisory, Mid-Market)

Anastasia Chapurina
  • Corporate / M&A (High-Market deals)

Anastasia Dukhina
  • Corporate / M&A (High-Market deals)

Valeriy Fedoreev
  • Employment & Migration

Shermet Kurbanov
  • Digital Economy
  • Personal Data Protection

Alisa Mikheeva
  • Personal Data Protection

Artashes Oganov
  • Corporate / M&A (High-Market deals)
  • Real Estate, Land, Construction (Advisory, Mid-Market)

Anna Pavlova
  • Employment & Migration

Alla Ryashentseva
  • Insurance

Hayk Safaryan
  • Tax (Advisory, High Market)
  • International Trade: Customs Law

Yulia Smourova
  • Tax (Advisory, High Market)
  • International Trade: Currency Regulation

Igor Sokolov
  • Insurance

Vsevolod Tyupa
  • Antitrust Law
  • Pharmaceuticals and Healthcare (Medicine and Healthcare)
  • Pharmaceuticals and Healthcare (Pharmaceuticals)

Ivan Zaraiskiy
  • Pharmaceuticals and Healthcare (Medicine and Healthcare)
  • Pharmaceuticals and Healthcare (Pharmaceuticals)

Leonid Zubarev
  • Insurance Law

The number of mentions totals to 23. This result demonstrates the depth of our expertise in key areas of legal practice – from High Market M&A transactions and High Market tax advisory to pharmaceuticals, digital economy, data protection, employment and insurance law.

We express our sincere gratitude to our colleagues for their professionalism, to our clients for their trust, and to the research team of Pravo-300 for their objective assessment of our work.

More details via the link >>
]]> Generative AI and copyright: legal risks during training and content generation http://sl.legal/tpost/generative-ai-and-copyright-legal-risks http://sl.legal/tpost/generative-ai-and-copyright-legal-risks?amp=true Tue, 17 Feb 2026 13:00:00 +0300 Publication Comprehensive analysis by our IP & Digital law practice.

Generative AI and copyright: legal risks during training and content generation

Русская версия >>

This review analyses key legal issues arising at the intersection of copyright and generative artificial intelligence (AI).

It focuses on two main sets of legal risks: for AI developers during the model training stage and for users during the content generation stage.

The purpose of the review is to examine two narrow yet critically important stages: the input of data into the AI model (for training) and the output of data from the model (during generation).

This material has been prepared taking into account current regulations and emerging international practices and can be used in assessing the legal risks of developing and operating generative AI.
Downloads

| PDF in English >> | PDF in Russian >>

Authors

]]> Dmitry Bogdanov to speak on environmental impact fees at Association of European Businesses Committee meeting http://sl.legal/tpost/lx9nvcj9y1-dmitry-bogdanov-to-speak-on-environmenta http://sl.legal/tpost/lx9nvcj9y1-dmitry-bogdanov-to-speak-on-environmenta?amp=true Tue, 17 Feb 2026 11:50:00 +0300 Events Date: 28.02.2026

Dmitry Bogdanov to speak on environmental impact fees at Association of European Businesses Committee meeting

Russian version >>

Dmitry Bogdanov, Counsel and Head of Environmental Law at SL LEGAL, will speak at the Committee on Safety, Health, Environment & Security (SHES) of the Association of European Businesses in Russia on the topic: "On Fees for Negative Environmental Impact."

The participants will discuss legal updates on environmental payments.

The programme will also cover the topic of first aid training: practical experience from Saint Gobain and LemanaPro.

Details:
February 27, 2026, Friday
12:00
Format: Online (Zoom)
Regiatration on the AEB website >>
]]> Record number of cases and more international claims: the ICAC sums up 2025 results http://sl.legal/tpost/k4nrk2rv01-record-number-of-cases-and-more-internat http://sl.legal/tpost/k4nrk2rv01-record-number-of-cases-and-more-internat?amp=true Mon, 16 Feb 2026 18:04:00 +0300 Comments Igor Sokolov comments for Pravo.ru

Record number of cases and more international claims: the ICAC sums up 2025 results

Русская версия >>

The International Commercial Arbitration Court at the Chamber of Commerce and Industry of the Russian Federation (ICAC) concluded 2025 with historic figures: 923 new claims, 337 of which were international. This is the second highest result in the institution’s entire history, second only to the indicators of the distant year 1981. The growth compared to 2024 amounted to almost 70%.

Experts explain this not simply by a recovery in business activity, but to a tectonic shift in the contractual practices of Russian businesses.

Igor Sokolov, Senior Associate at the Dispute Resolution of SL LEGAL, explains this as the influence of two factors. First and foremost, this is due to an overall increase in the number of economic disputes, both domestically and internationally. Secondly, companies have started to use ICAC clauses more frequently due to the forced abandonment of other popular European arbitration forums. In international contracts involving Russian parties concluded after 2020, ICAC was often specified as the sole option or as a possible alternative to the Arbitration Institute of the Stockholm Chamber of Commerce (SCC) or the London Court of International Arbitration (LCIA), Sokolov notes.

Colleagues also agree that this is a systemic trend, with Russian parties actively replacing old clauses in favor of friendly jurisdictions and domestic centers – such as ICAC, RSPP, and RAC.

Interestingly, the geography of disputes is changing: 29% of the parties represent Europe, 24% – the Middle East, and 22% – Asia. Partners from China, Turkey, the UAE, and Belarus most frequently litigate at ICAC. However, as Igor Sokolov summarises, “...the quantitative growth of cases has not yet led to qualitative changes. The most expensive claims still rarely end up at ICAC.” In most cases, the claim amount ranged from USD 10,000 to USD 200,000.

A detailed review of the statistics and expert comments can be found via the link >>.
]]> The CASE by Legal Insight: Our сase in the Top-3 contractual disputes of 2025 http://sl.legal/tpost/uoi03vuzj1-the-case-by-legal-insight-our-sase-in-th http://sl.legal/tpost/uoi03vuzj1-the-case-by-legal-insight-our-sase-in-th?amp=true Thu, 12 Feb 2026 09:00:00 +0300 News Best Cases of 2025.

The CASE by Legal Insight: Our сase in the Top-3 contractual disputes of 2025

Русская версия >>

The Legal Insight magazine has published the results of its annual study – “The CASE by Legal Insight. Best Cases of 2025”, which highlights the most impactful legal cases of the year and their influence on the Russian legal landscape.

The case concerning the refusal to recognise an event as an insured occurrence – in which we represented the Russian National Reinsurance Company as a third party in the OEMK v. SOGAZ dispute – received high praise from experts and was ranked second in the study.

To be included, a case must demonstrate significance for society, the economy, and the development of law.

SL LEGAL project team:

  • Leonid Zubarev, Partner, Project Lead
  • Alla Ryashentseva, Senior Associate
  • Igor Sokolov, Senior Associate
Contacts:
]]> Leonid Zubarev to speak at the XIV International Insurance Brokers Conference http://sl.legal/tpost/vlpaufoa21-leonid-zubarev-to-speak-at-the-xiv-inter http://sl.legal/tpost/vlpaufoa21-leonid-zubarev-to-speak-at-the-xiv-inter?amp=true Wed, 11 Feb 2026 11:08:00 +0300 Events Date: 18.02.2026

Leonid Zubarev to speak at the XIV International Insurance Brokers Conference

Russian version >>

XIV International Insurance Brokers Conference

Leonid Zubarev, Partner and Head of Insurance at SL LEGAL, will speak at the annual insurance brokers conference.

Leonid will take part in the final panel discussion titled "Cyber Insurance: Basic Minimum or Luxurious Maximum?" alongside colleagues from the following companies: Ingosstrakh, Rosgosstrakh, Sberbank Insurance, GSK Yugoria, Remind, and RK Insurance Broker.

The speakers will address issues related to product promotion, transparency in claims settlement, and how legislative regulation is catching up with real-world cyber threats.

Other conference topics include:

  • Insurance of investment projects
  • Exclusion of VAT from insurance compensation
  • Why traditional insurance cannot withstand the demands of marketplaces
  • Specifics of how Russian youth perceive insurance

Details:
18 February 2026, Wednesday
10:00 AM – 5:00 PM
Swissotel Krasnye Holmy
Organizer: Professional Insurance Brokers Association (PIBA)
Details and registration via the link >>.
]]> 2025: Legislative developments impacting the pharmaceutical and medical device industries http://sl.legal/tpost/2025-legislative-developments-ls-en http://sl.legal/tpost/2025-legislative-developments-ls-en?amp=true Mon, 09 Feb 2026 15:49:00 +0300 Publication Thought leadership material prepared by our Life Sciences practice.

2025: Legislative developments impacting the pharmaceutical and medical device industries

Русская версия >>

In 2025, the healthcare industry faced not only massive regulatory changes, but also the development of several important trends in court and administrative practice.

The main regulatory topics were the expiration of the deadline for aligning local registration dossiers with the Eurasian Economic Union (the EEU) requirements and the legislative amendments to preserve the local dossiers which had not been updated by the deadline (31 December 2025).

The reform of the national regime in public procurement also had a significant impact on the industry. This reform was the result of the government’s policy of technological independence that includes, inter alia, supporting Russian companies from the life sciences industry and encouraging local production of medical products.

On a separate track, the lawmaker began addressing long-standing industry issues: integration of dietary supplements and unified clinical protocols into medical practice, restructuring payments in clinical trials, etc.
Court practice, in turn, tried to balance the interests of innovative and generic companies, alternating between defending originators and supporting generic manufacturers.
Sanctions and counter-sanctions issues also remained relevant. Both the European Union (the EU) and Russia introduced various restrictive measures in the past year. However, compared to 2024 and 2023, their impact on the industry was quite limited.

To help you navigate your journey through the changing regulatory environment, we have prepared this annual review of the key legal developments in the life sciences industry. We hope you will find this review helpful.
Downloads

| PDF in English >> | PDF in Russian >>

Authors

]]> Key amendments to Russia’s consumer protection law – new safeguards for businesses http://sl.legal/tpost/7v6rlmip91-key-amendments-to-russias-consumer-prote http://sl.legal/tpost/7v6rlmip91-key-amendments-to-russias-consumer-prote?amp=true Thu, 05 Feb 2026 15:35:00 +0300 Publication These changes mitigate business liability to consumers in certain situations and limit abusive practices.

Key amendments to Russia’s consumer protection law – new safeguards for businesses

Русская версия >>

Amendments* to the Consumer Protection Law* took effect on 1 February 2026. These changes mitigate business liability to consumers in certain situations and limit abusive practices.

Key changes

Limitation of the amount of penalties for late satisfaction of consumer demands

The penalty for the late satisfaction of consumer demands (1% of the goods price for each day of delay) can now not exceed the price paid for the acquired goods. Furthermore, the court has the right to reduce the penalty if it is clearly disproportionate to the consequences of the violation.

New grounds for refusal to impose a fine

The Consumer Protection Law provides for an additional penalty for late compliance with consumer’s claims – a fine equal to 50% of the amount awarded to the consumer by the court (usually including the cost of the goods, damages, and penalties). The fine applies to the producer, seller, importer, and service provider.

In accordance with the Amendments, the fine does not apply if:

  • the defendant was unable to comply with the claim due to the consumer's own fault (e.g., refusing to provide the goods for a required expert examination to determine the cause of the breakdown).
  • the defendant lost the opportunity to voluntarily comply with the consumer’s claim (e.g., if the consumer destroyed the goods).
  • the defendant failed to comply with the consumer’s claim due to a breach of obligations by the defendant’s counterparty (supply of necessary goods, works or services) – except in cases where the defendant acted in bad faith or unreasonably in selecting the counterparty.
  • before going to court, the consumer and the defendant concluded a mediation agreement – except in cases where this agreement was not fulfilled due to the fault of the defendant.

Limitation on the amount of damages for the return of technically complex goods

When returning, for example, a car due to its non-conforming quality, the consumer may additionally claim damages in the amount of the difference between the price they paid and the current market price of a similar goods.

According to the amendments, when determining the current price, the court must consider the degree of wear and the year of manufacture of comparable goods.

However, if it is established that the seller intentionally misled the consumer regarding the product’s characteristics (the actual characteristics are significantly worse than those described in the contract), the price limitation rule does not apply. The seller will compensate for damages based on the cost of a new goods.

Restriction on the assignment of claims for penalties and fines payment

A consumer may assign to a third party the right to claim penalties and fines for late satisfaction of a claim only after a court decision ordering the recovery of these amounts from the defendant has entered into force. Any early assignment is null and void.

Why this is important

The amendments limit the free room for “consumer extremism”, where the Consumer Protection Law is used for abuse rather than to address violations and provide fair compensation. Limiting the amount of damages and the penalty, along with the possibility of its reduction, prevents unjust enrichment in situations where prompt satisfaction of a consumer’s claim is not objectively possible (e.g., due to logistics constraints). The new grounds for denying the fine pursue the same goal.

The amendments also encourage consumers to protect their rights themselves, rather than assign them to third parties not involved in the consumer relations.

Recommendation

Companies in the B2C segment should update their internal procedures for handling consumer’s claims in light of these changes. It is important that the amendments do not completely release manufacturers and sellers from the liability for violating consumers’ rights.

* In Russian
Authors:
]]> Russian subsidiary may appeal court rulings issued against its foreign parent company if those rulings affect rights of the subsidiary and violate the law http://sl.legal/tpost/n9ag3u36u1-russian-subsidiary-may-appeal-court-ruli http://sl.legal/tpost/n9ag3u36u1-russian-subsidiary-may-appeal-court-ruli?amp=true Mon, 02 Feb 2026 14:39:00 +0300 Publication Assets of Russian subsidiaries can be seized in claims filed in Russia against foreign parent companies.

Russian subsidiary may appeal court rulings issued against its foreign parent company if those rulings affect rights of the subsidiary and violate the law

Русская версия >>

Case background

A Russian court was hearing a bankruptcy case* concerning a company registered in the British Virgin Islands (the “Foreign Company”). The bankruptcy proceedings were initiated based on a court ruling ordering the Foreign Company to pay a debt to a creditor in Russia (the “Ruling”).

In the bankruptcy case, the court imposed interim measures against the Foreign Company’s Russian subsidiary (the “Russian Company”). The interim measures included the seizure of the Foreign Company’s majority stake and a prohibition on the Russian Company disposing of its real estate.

The Russian Company attempted to challenge the Ruling to prove that there were no grounds for declaring the Foreign Company bankrupt in Russia. The lower courts, however, held that the Russian Company had no right to seek a review of the Ruling. They emphasised that as a separate legal entity, it was not liable for the obligations of the Foreign Company, and the Russian bankruptcy law did not grant it the right to appeal the Ruling.

Position of the Supreme Court of the Russian Federation

The Russian Supreme Court disagreed with this approach. It held that, the Russian Company should have the opportunity to present arguments and evidence concerning the existence of the Foreign Company’s debt. One of the ways to exercise this opportunity is to appeal the Ruling.

When considering such an appeal, the courts should proceed from presumptions that the Ruling substantially affects the rights of the Russian Company. They should also examine the Russian Company’s substantiated and convincing arguments that the Ruling violates the law.

On these grounds, the Russian Supreme Court cancelled the previously adopted rulings and remanded the issue for reconsideration to the court of appeal.

Why this is important

Assets of Russian subsidiaries, as well as shares in them, can be seized in claims filed in Russia against foreign parent companies. Often, these claims are heard without the participation of the Russian subsidiaries, while legislation contains no provisions expressly granting subsidiaries the right to appeal in such cases.

The new position of the Russian Supreme Court partially fills this gap and can be used to justify an appeal by a subsidiary. Although this position was formulated in a bankruptcy context, it may potentially be extended to other types of disputes. When appealing, the subsidiary company will need to substantiate (1) the unlawfulness of the court ruling and (2) the violation of the subsidiary’s rights and legitimate interests by that ruling.

* In Russian
Authors:
]]> Vsevolod Tyupa at the Pharma Committee meeting of Kammer Russland http://sl.legal/tpost/djmdrsy6x1-vsevolod-tyupa-at-the-pharma-committee-m http://sl.legal/tpost/djmdrsy6x1-vsevolod-tyupa-at-the-pharma-committee-m?amp=true Tue, 27 Jan 2026 17:32:00 +0300 Events Date: 05.02.2026

Vsevolod Tyupa at the Pharma Committee meeting of Kammer Russland

Русская версия >>

On 5 February 2026, Vsevolod Tyupa, Partner, Head of the Pharmaceutical and Healthcare at SL LEGAL, will participate in the first meeting of the year of the Pharmaceutical and Healthcare Committee of the Russian-German Chamber of Commerce.

As co-chair of the committee, Vsevolod will present an analysis of the main industry changes in 2025.

The meeting will also discuss EU sanctions and their impact on Special Economic Zones (SEZs).

Details:
5 February 2026, Thursday
Time: 10:00 AM – 12:00 PM
Format: Hybrid
The meeting will be held in Russian, without translation

For registration please contact Evgenia Frolova, frolowa@kammer.ru
]]> Yulia Smourova at the Tax Committee meeting of Kammer Russland http://sl.legal/tpost/lmy910byj1-yulia-smourova-at-the-tax-committee-meet http://sl.legal/tpost/lmy910byj1-yulia-smourova-at-the-tax-committee-meet?amp=true Mon, 26 Jan 2026 17:25:00 +0300 Events Date: 28.01.2026

Yulia Smourova at the Tax Committee meeting of Kammer Russland

Русская версия >>

Yulia Smourova, Partner, Co-Head of Tax at SL LEGAL, will speak at the meeting of the Tax and Financial Reporting Committee of Kammer Russland.

Yulia will speak on developments in currency regulation.

The meeting will also discuss the following topics:

  • New VAT 22% and its transitional period
  • Social insurance contributions for directors
  • Russian Supreme Court ruling on circumvention of anti-sanctions regulation
  • German withholding tax practice

Details:
28 January 2026, Wednesday
Start: 9:30 AM
Format: Hybrid

For registration please contact Yulia Shchukina, Shchukina@kammer.ru
]]> Implementation of new EPR Rules for importers delayed until 2028 http://sl.legal/tpost/x54igehgy1-implementation-of-new-epr-rules-for-impo http://sl.legal/tpost/x54igehgy1-implementation-of-new-epr-rules-for-impo?amp=true Thu, 22 Jan 2026 18:04:00 +0300 Publication Alert prepared by our Environmental law practice.

Implementation of new EPR Rules for importers delayed until 2028

Русская версия >>

On 31 December 2025, a Federal Law* came into force, which postponed the introduction of key new requirements for importers of goods from non-EAEU countries until 1 January 2028. These requirements pertain to new rules under the Extended Producer Responsibility (EPR) framework, namely:

  • Advance payment of the environmental fee (prior to customs clearance); and
  • Submission of a report on the weight of imported goods separately for each consignment.

Consequently, the term of the experiment to test the new mechanism for specific categories of imported goods has also been extended until this date.

It is important to note that the rules for conducting the experiment during its extended period have not yet been established. Therefore, importers of goods covered by the experiment currently pay the environmental fee and submit reports according to the general procedure - by 15 April of the year following the reporting period.

New rules for conducting the experiment are to be adopted within 2026.

These rules may include the following changes:

  • Revision of the list of goods subject to the experiment;
  • Introduction of a deferral of up to 90 calendar days from the date of import for payment of the environmental fee and submission of the report on the weight of imported goods; and
  • Removal of the suretyship agreement from the list of available methods for securing the environmental fee payment in case of failure to independently fulfil waste disposal obligations.

We recommend that all importers closely monitor the development and approval status of the new experimental rules. This will allow them to prepare in advance to comply with the established requirements should the goods they import fall under these rules.

* In Russian

Author:

]]> SL LEGAL promotes Yulia Smourova to partner and Co-Head of Tax http://sl.legal/tpost/49l9nuph61-sl-legal-promotes-yulia-smourova-to-part http://sl.legal/tpost/49l9nuph61-sl-legal-promotes-yulia-smourova-to-part?amp=true Wed, 21 Jan 2026 11:00:00 +0300 News Firm's new promotion.

SL LEGAL promotes Yulia Smourova to partner and Co-Head of Tax

Русская версия >>

SL LEGAL is pleased to announce the promotion of Yulia Smourova to Partner and Co-Head of the firm’s Tax Practice.
Yulia is a renowned expert with over 20 years of experience in tax law, currency regulation, and private capital management.

She provides comprehensive legal support to Russian and international companies, banks, and private individuals on currency regulation matters — from advisory services to representation in pre-trial and court proceedings.

Yulia heads the Expert Group on Currency Control at the Russian-German Chamber of Commerce. Prior to joining the firm in 2006, she worked Moscow Directorate of the Federal Tax Service of Russia.

Yulia has been individually recognised by leading industry rankings, including Pravo-300, Rossiyskaya Gazeta, and Wealth Navigator Awards.
“Yulia’s promotion to Partner is a logical step in the development of our tax team, which we have been steadily building over recent years,” commented Hayk Safaryan, Tax Partner at SL LEGAL. “Her strong reputation, leadership skills, and extensive experience will be key as she focuses on building the team's strategic depth, enhancing its capabilities, and expanding our capacity to provide comprehensive support for both corporate and private clients.”

Contacts:

E yulia.smourova@sl-legal.ru
T +7 495 134 22 00
]]> Restrictions on market research in Russia http://sl.legal/tpost/m5260x51t1-restrictions-on-market-research-in-russi http://sl.legal/tpost/m5260x51t1-restrictions-on-market-research-in-russi?amp=true Fri, 16 Jan 2026 17:00:00 +0300 Publication Effective 1 March 2026, significant restrictions on market research will be imposed on foreign companies.

Restrictions on market research in Russia

Русская версия | Japanese version | Chinese version

Please note that significant restrictions on market research for foreign organisations and their Russian subsidiaries will come into effect on 1 March 2026.

The government has adopted relevant amendments* to the Federal Law “On the Fundamentals of State Regulation of Trade in the Russian Federation”.

The law prohibits:

  • conducting market research in Russia by foreign companies and by Russian companies with more than 20% foreign shareholding, which effectively covers all subsidiaries of foreign entities.
  • foreign companies establishing control over “organisers of market research”. The law defines these organisers as entities for which “market research” is the primary type of activity.

Organisers of market research must confirm their compliance with the new requirements by 15 May 2026.

Violation of these restrictions may result in specific liability: alienation of the foreign share to reduce the level of foreign participation to the permitted 20% or less. Any transactions concluded in violation of the law will be deemed void.

Exceptions

The law provides for certain exceptions. In particular, the restrictions do not apply if a company conducts market research for its own or intra-group purposes, and its results are not disclosed to third parties.

Another exception is related to the annual total revenue of the group to which the company belongs. The prohibitions do not apply if the group’s total revenue does not exceed RUB 800m (EUR 8.7m) per calendar year.

Comments

Although the new restrictions apparently will not affect research conducted for intra-group purposes, it is recommended to assess whether they could impact the activities of Russian representative offices and subsidiaries of foreign companies and organisations. Considering preventive measures to mitigate potential risks is also recommended.

Such assessment is particularly recommended for entities whose primary activity in the Unified State Register of Legal Entities (EGRUL) is listed as “market research” (OKVED codes 73.20 and 73.20.1).

*In Russian

Authors:

]]> Expanding arbitration capabilities: a key institution gains accreditation in Russia http://sl.legal/tpost/42asihs911-expanding-arbitration-capabilities-a-key http://sl.legal/tpost/42asihs911-expanding-arbitration-capabilities-a-key?amp=true Wed, 14 Jan 2026 10:41:00 +0300 Publication DIAC accredited as a permanent arbitral institution in Russia.

Expanding arbitration capabilities: a key institution gains accreditation in Russia

Русская версия >>

A leading international arbitration centre based in Dubai (DIAC) has been officially accredited by the Russian Ministry of Justice as a permanent arbitral institution. This opens new prospects for DIAC, an arbitration centre widely recognised within the Russian business community.

Practical significance

Russian courts will no longer require parties to prove DIAC’s status as the permanent arbitral institution. This will simplify the enforcement in Russia of arbitral awards rendered under DIAC’s auspices abroad.

The new status also expands the range of disputes DIAC can administer in Russia:

  • Arbitration of corporate disputes: DIAC will be able to administer certain corporate disputes, for example, those concerning ownership rights to shares and stakes in the charter capital of Russian companies. To broaden the scope of corporate disputes it can administer, the institution will need to develop specialised rules.
  • Support for ad hoc arbitration: DIAC will be able to support arbitration proceedings conducted in Russia outside of permanent institutions.
  • Procurement disputes: DIAC will be able to administer proceedings arising from the procurement activities of certain organisations, including those with state participation.

Important

Even with its new status, DIAC will only be able to handle international commercial disputes. To administer cases where all parties are Russian residents, the establishment of a branch in Russia is required.

* In Russian
For further information

Our firm is closely monitoring these developments. Our team, which includes recognised arbitrators and experts for both Russian and international proceedings, is consistently ranked among the top practitioners in dispute resolution and arbitration by major Russian legal directories like Expert RA, Pravo-300, and Rossiyskaya Gazeta. If you have any questions regarding DIAC’s new status or require assistance with a related arbitration matter, our experts are ready to assist.
Authors:
]]> Acquisition of Outlet Village Belaya Dacha and Outlet Village Pulkovo named 5th largest real estate deal in Russia for 2025 http://sl.legal/tpost/ytgpntjap1-acquisition-of-outlet-village-belaya-dac http://sl.legal/tpost/ytgpntjap1-acquisition-of-outlet-village-belaya-dac?amp=true Wed, 14 Jan 2026 10:00:00 +0300 Deals Ranked by RBC, a leading Russian business media group.

Acquisition of Outlet Village Belaya Dacha and Outlet Village Pulkovo named 5th largest real estate deal in Russia for 2025

Русская версия >>

The acquisition of Outlet Village Belaya Dacha and Outlet Village Pulkovo, a transaction on which the SL LEGAL team advised, has been named by RBC, a leading Russian business media group, as one of the five largest real estate deals in Russia for 2025.

The deal was also ranked second specifically within the retail real estate segment.

Led by partner Artashes Oganov, the SL LEGAL team provided comprehensive legal support to the purchaser, investment holding Kama Сapital, on all aspects of the transaction.

The core advisory team consisted of:
  • Anastasia Chapurina, Senior Associate, Corporate/M&A
  • Anastasia Dukhina, Senior Associate, Corporate/M&A

Outlet Village Belaya Dacha (37,200 sq. m) is a unique shopping complex in Russia, country's pioneering retail reat real estate of this format. The asset was sold by a consortium comprising the international fund Hines and the Russian Belaya Dacha Group.

Outlet Village Pulkovo (35,500 sq. m) is the largest outlet center in Russia's Northwestern Federal District. The seller of this asset was the international fund Hines.

In autumn 2025, the deal was also recognised in the annual M&A ranking published by Kommersant publishing house.
Contacts:
]]> Personal data regulation in 2025: key takeaways http://sl.legal/tpost/sbx310ku71-personal-data-regulation-in-2025-key-tak http://sl.legal/tpost/sbx310ku71-personal-data-regulation-in-2025-key-tak?amp=true Mon, 12 Jan 2026 18:39:00 +0300 Comments Commentary for Pravo.ru

Personal data regulation in 2025: key takeaways

Русская версия >>

Shermet Kurbanov, Senior Associate and Co-head of Intellectual Property and Digital Law at SL LEGAL, commented for the special Pravo.ru Year in Review issue on key developments in privacy regulation in Russia in 2025. These are:

  • Stricter data localisation requirements. Since 1 July 2025, companies are now prohibited from storing the personal data of Russian citizens in foreign databases.

This, Shermet explains, will require many organisations to conduct thorough legal and technical audits of their existing processes – particularly those relying on cloud infrastructure or foreign-based service providers.

  • Further uncertainty raises from a potential revision of the list of “adequate” jurisdictions for cross-border data transfers. A bill currently under review in the State Duma seeks to tighten the criteria for adequacy, reflecting concerns that some listed countries do not, in practice, guarantee sufficient protection for data subjects’ rights.

Shermet warns that if these proposals move forward, businesses with international operations or foreign partners will need to account for this when reviewing existing and assessing new cross-border data transfer procedures.

  • A major legislative shift this year has been the introduction of stricter liability for violations in personal data processing. The amendments have established new administrative offenses – such as failing to notify regulators about processing activities and data breaches –and have also significantly increased fines for existing violations. For example, under the general provision (Art. 13.11(1) of the Administrative Code), the maximum penalty has risen to RUB 300,000 (EUR 3,300).

From a business perspective, the most impactful changes relate to breaches involving special categories of data and biometric information. Unlike other types of personal data, there is no “progressive” penalty scale for these categories. This means even a first-time breach can result in fines ranging from RUB 10 to 20m (EUR 109k – EUR 218k).

According to Shermet, these heightened risks have made data security and internal control a top priority for management – highlighting that merely formal compliance measures are no longer sufficient.

  • Fines for breaches of “ordinary” personal data have also risen sharply. A repeat incident involving 10,000 identifiers or the data of at least 1,000 individuals now carries a turnover-based fine of up to 3% of annual revenue – capped between RUB 20m and RUB 500m (EUR 218k – EUR 5.4m).

Shermet points out that whether a company can benefit from mitigating circumstances depends largely on whether it has established documented incident response procedures and robust data protection measures in place.

For the full analysis of these and other developments in personal data regulation, see the special Pravo.ru Year in Review issue via the link >> (available in Russian).
Contacts:
]]> Season's Greetings from SL LEGAL! http://sl.legal/tpost/seasonsgreetings http://sl.legal/tpost/seasonsgreetings?amp=true Sun, 28 Dec 2025 20:00:00 +0300 News Season's Greetings from the SL LEGAL team.

Season's Greetings from SL LEGAL!

Русская версия >>

Dear Friends,

As we approach the New Year, it's that special time to dream big and believe that eveyrthing is possible. Our wish for you in 2026 is that your most ambitious professional goals and your most cherished personal dreams all find their way to you.

To help get you into the festive spirit, our team has put together a little creative video filled with our very warmest wishes for you.

We hope you enjoy it.

Wishing you a joyful and prosperous New Year!

Yours sincerely,
SL LEGAL team
]]> Pravo.ru: international digest for November http://sl.legal/tpost/i89gf9bgm1-pravoru-international-digest-for-novembe http://sl.legal/tpost/i89gf9bgm1-pravoru-international-digest-for-novembe?amp=true Fri, 19 Dec 2025 11:22:00 +0300 Comments Comment for Pravo.ru

Pravo.ru: international digest for November

Русская версия >>

This November, courts refused to grant anti-action injunctions to the parties in several cases. For example, the Moscow District Court denied "Peresvet" Bank's request for an anti-suit injunction against proceedings in Cyprus, as two companies associated with Russia are involved in the case, one of which, Fonds Rusnano Capital S.A., has state participation (case No. A40-139350/2025).

The Court of Cassation pointed out that there is no evidence that the bank is under the sanctions, although its sole shareholder is subject to EU and US restrictions. In addition, it has not been proven that the bank has difficulties accessing justice in Cyprus: the dispute in the District Court of Nicosia has been ongoing since 2014, but "Peresvet" has only now decided to seek an anti-suit injunction. All this, according to the Moscow District Court, indicates attempts to delay the proceedings. Moreover, the court ruled that the application for an anti-suit injunction was aimed at preventing the state-owned enterprise's subsidiary from recovering its losses.
Igor Sokolov, Senior Associate of Dispute Resolution at SL LEGAL, comments:
This cassation ruling demonstrates a departure from the widespread practice of issuing anti-claim injunctions at the request of virtually any Russian company directly or indirectly affected by foreign sanctions. However, the circumstances of the case and its participants make the logic behind this exceptional ruling understandable.

This ruling is unlikely to be a ‘turning point’ for the majority of cases. However, it may indicate the need for a thorough assessment of all the circumstances of a foreign dispute, its subject matter and the parties involved. Issuing an anti-suit injunction at the request of any Russian entity does not always serve the purposes of this institution.
The full digest (In Russian) is available here.
Contacts:
]]> Protection of patent holders from unfair competition on the pharmaceutical market http://sl.legal/tpost/185ozs56i1-protection-of-patent-holders-from-unfair http://sl.legal/tpost/185ozs56i1-protection-of-patent-holders-from-unfair?amp=true Mon, 20 Oct 2025 22:54:00 +0300 Publication How to prove patent infringement in generic drugs before FAS.

Protection of patent holders from unfair competition on the pharmaceutical market

Русская версия >>

Federal Law dated 26.07.2006 No. 135-FZ “On Protection of Competition” (the “Law”) prohibits unfair competition, i. e. actions that are aimed at obtaining business advantages in contravention of the common norms of doing business and may cause damages to competitors. Specifically, Article 14.5 of the Law prohibits unfair competition by using someone else’s intellectual property.

Over the past few years, the number of complaints on unfair competition submitted to the Federal Antitrust Service (the “FAS”) by originator pharmaceutical companies has increased significantly. These complaints typically ask for recognition of the circulation of generic drugs prior to the expiry of patent protection for the original product as an act of unfair competition.

A considerable number of such complaints have been satisfied. Manufacturers and distributors of generics were ordered to cease circulation of the respective products and pay significant fines. Moreover, FAS issued official public letters prohibiting the purchase of the concerned generics through public procurement procedures. As a result, many originator companies considered the complaints on unfair competition as effective and resource-saving way of protecting patent rights (especially compared to the traditional court litigation).

Subsequently, some generic companies succeeded in challenging FAS’s decisions in court. So, to date, the prospects of unfair competition complaints by patent holders and their partners are clouded.

This document provides a brief overview of the enforcement practice of FAS and the courts regarding the recognition of the circulation of generics as unfair competition, arguments of the parties in such disputes, and approach of the courts and FAS to the arguments of originator companies and generic market players.
Authors:
Downloads
| PDF in English >> | PDF in Russian >>
]]> SL LEGAL ranked by Kommersant Deals of the Year 2025 http://sl.legal/tpost/xj8dgx1me1-sl-legal-ranked-by-kommersant-deals-of-t http://sl.legal/tpost/xj8dgx1me1-sl-legal-ranked-by-kommersant-deals-of-t?amp=true Tue, 30 Sep 2025 14:00:00 +0300 News Our M&A team’s project was recognised among the landmark deals of 2025.

SL LEGAL ranked by Kommersant Deals of the Year 2025

Русская версия >>

Kommersant, Russia’s leading business media outlet, has published its annual Deals of the Year ranking.

In this special issue, Kommersant highlighted the most important transactions that reflect the capital flows in 2025.

Among the landmark deals, the ranking recognised a project handled by the SL LEGAL M&A team, led by practice head Artashes Oganov:

  • Advising the Russian investment holding Kama Capital on the acquisition of two landmark outlet centers in Russia - Outlet Village Belaya Dacha (Moscow) and Outlet Village Pulkovo (St. Petersburg).

Congratulations to our colleagues, our sincere thanks to our clients for their trust, and to the Kommersant editorial board for this high recognition!

Read more (in Russian) >>
Contacts:
Artashes Oganov
Partner, Head of Corporate/M&A
artashes.oganov@sl-legal.ru
+7 495 134 22 00

]]> SL LEGAL is among the leaders in the Russian Private Equity market http://sl.legal/tpost/s5d1vlf7d1-sl-legal-is-among-the-leaders-in-the-rus http://sl.legal/tpost/s5d1vlf7d1-sl-legal-is-among-the-leaders-in-the-rus?amp=true Mon, 29 Sep 2025 11:59:00 +0300 News The team recognised at the Russia PE&VC Awards 2025.

SL LEGAL is among the leaders in the Russian Private Equity market

Русская версия >>

On 25 September, at the annual professional conference “XVII Russian Private Equity Congress and XIII Venture Investors Forum”, the Russia PE&VC Awards 2025 ceremony was held, recognising outstanding achievements in the private equity and venture capital markets.

This year, SL LEGAL became an award winner for the first time, earning the third place.

Launched in 2012, the Award has been celebrating key achievements in Russia’s private equity and venture capital market. It is organised by PREQVECA, a leading information and analytics platform, together with Cbonds Congress, a well-established organiser of financial market conferences.

Learn more about the results (in Russian) >>

We sincerely thank our clients for entrusting us with landmark projects, congratulate the winners and organisers on their excellent results, and are truly proud of our team!

Contacts:
Artashes Oganov
Partner
Head of Corporate / M&A
artashes.oganov@sl-legal.ru
]]> Digital Law Digest http://sl.legal/tpost/a891bfumj1-digital-law-digest http://sl.legal/tpost/a891bfumj1-digital-law-digest?amp=true Thu, 04 Sep 2025 09:31:00 +0300 News Publication The most relevant updates and trends shaping the digital legal landscape.

Digital Law Digest

Русская версия >>

We are pleased to present the new issue of our Digital Law Digest, covering the key developments in the field, for Q2 2025. This issue brings together the most relevant updates and trends shaping the digital legal landscape – from evolving regulations on personal data and new approaches to artificial intelligence, to strengthened rules in advertising, and other noteworthy digital initiatives.

We hope this Digest will serve as a useful guide to navigating the fast-changing environment of digital law. Should you have any questions, or wish to discuss how these developments may affect your business, our team will be glad to assist.
Authors:
Downloads
| PDF in English >> | PDF in Russian >>
]]> LLC participants will be able to restrict or completely cancel pre-emptive rights http://sl.legal/tpost/n7076es7r1-llc-participants-will-be-able-to-restric http://sl.legal/tpost/n7076es7r1-llc-participants-will-be-able-to-restric?amp=true Wed, 03 Sep 2025 10:00:00 +0300 News Publication Now, a company can specify in its charter the refusal to apply the pre-emptive rights provisions for participants.

LLC participants will be able to restrict or completely cancel pre-emptive rights

Русская версия >>

On 7 July 2025, Law No. 185* and Law No. 186* were passed, amending the Russian Civil Code and the Law on Limited Liability Companies (LLCs). Amendments to the Civil Code came into effect on 18 July 2025, while changes to the specialised law took effect on 1 September 2025.

The novelty changes the procedure for exercising pre-emptive rights to purchase a share in an LLC. Now, a company can specify in its charter the refusal to apply the pre-emptive rights provisions for all or certain participants. This means that when one of the participants sells their share, only some of the remaining participants or none of them will be able to exercise their pre-emptive rights. Previously, the Law on LLCs allowed only changes to the procedure for exercising such rights when selling shares to a third party, but all participants in the LLC had pre-emptive rights, and it was impossible to fully exclude them.

Starting from 1 September, LLCs can determine the procedure for applying and exercising pre-emptive rights in the following ways:

  • Directly name in the charter the participants to whom the pre-emptive right will not apply, or

  • Specify criteria that would exclude application of the pre-emptive rights to a participant (e.g., ownership of more than 25% of shares or ownership of shares for more than 10 years, etc.), or

  • Establish that these rights do not apply to all participants, or

  • Make the exercise of pre-emptive rights by one, several, or all participants conditional upon certain circumstances and/or timeframes.

Such changes to the charter can only be made by unanimous decision of all LLC participants, and such conditions can only be excluded by a qualified majority of at least two-thirds of the votes. The corresponding decisions of the general meeting of participants must be notarised.

It is important to note that decisions made by the general meeting to include and/or exclude other provisions related to pre-emptive rights from the charter (for example, fixing the right to purchase a share at a predetermined price or allowing participants to purchase not the entire share offered for sale) do not require notarisation but must be made with the same number of votes.

At the same time, provisions of the charter that exclude pre-emptive rights from applying to a particular participant (or apply them conditionally) do not automatically extend to a new owner of that participant’s share.

A participant wishing to sell their share is entitled to request a list of participants to whom pre-emptive rights apply, and the company must provide this list within five working days from the receipt of the request. In other words, if pre-emptive rights are not granted to all participants by the charter, participants without these rights are not entitled to receive information about the planned sale of shares.

Comments

In our view, the need for such changes in the regulation of pre-emptive rights has long been awaited in practice. They allow for more flexible structuring of corporate relations in LLCs and are to eliminate legal uncertainty that arose from the position* of the Russian Supreme Court in the “Yana Tormysh” case. In its ruling on this case the Supreme Court emphasised that the principle of dispositiveness underlies the legislative regulation of LLC activities, meaning that the provisions of the legislation on pre-emptive rights to purchase shares can be modified or completely cancelled by making changes to the company’s charter, whereas a literal interpretation of the Law on LLCs to some extent contradicted this position.

At the same time, before making changes to the charter, companies are advised to analyse the need to modify their existing procedure for exercising pre-emptive rights, as well as the consequences of introducing one model or another (full refusal, conditional exercise, special procedure for certain participants, etc.), so that the changes do not create unnecessary difficulties in dealing with shares or infringe upon the interests of minority shareholders, but rather contribute to more effective interaction between participants and, ultimately, enhance the company’s investment attractiveness.

* In Russian
Authors
Downloads
| PDF in English >> | PDF in Russian >>
]]> Changes to Russian corporate laws: legalisation of “matryoshka” companies and new rules for sole shareholder decisions http://sl.legal/tpost/gntmuk05m1-changes-to-russian-corporate-laws-legali http://sl.legal/tpost/gntmuk05m1-changes-to-russian-corporate-laws-legali?amp=true Wed, 27 Aug 2025 10:00:00 +0300 News This August 2025, several small but significant amendments to Russian corporate legislation came into effect.

Changes to Russian corporate laws: legalisation of “matryoshka” companies and new rules for sole shareholder decisions

Русская версия >>

On 1 August 2025, several small but significant amendments to Russian corporate legislation came into effect.

Lifting the ban on "matryoshka" companies

One of the most notable changes was the regulatory reform of the so-called “matryoshka” companies. The relevant federal laws have amended both the Russian Civil Code* (the “Civil Code”) and the laws* on business entities. The amendments provide for the lifting of the ban on a business company (both LLC and JSC) with a sole participant/shareholder owning 100% of shares in the charter capital of another company. In other words, as of 1 August, it is now legitimate to have a shareholding structure where entity “A” owns 100% of company “B,” which in turn owns 100% of company “C,” and so on.

The revoked ban was introduced during the development of the Civil Code to combat the opacity of the “matryoshka” ownership structure and minimise the associated risks of asset withdrawal, tax violations and the possibility of ultimate beneficiaries evading responsibility to creditors.

In recent years, however, the relevance of the ban has diminished. Government agencies have expanded their legal and technical tools for tracing ownership chains and detecting potential violations. As a result, the statutory prohibition had become a technical obstacle to forming vertical holding structures and consolidating ownership in the hands of a single owner. In practice, even in fully transparent businesses, companies were forced to introduce an additional (often intra-group) participant or shareholder with a nominal share solely to meet formal legal requirements.

Under current conditions, “matryoshka” structures may serve as an effective corporate and business tool. In particular:

  1. Under the conditions of sanctions restrictions, they may help both Russian and foreign entities adapt their ownership structure more quickly and flexibly to new restrictions, thereby managing sanctions risks more effectively;
  2. They simplify the sale of individual companies outside the group or the intra-group transfer of entities, as there is no need to account for a nominal minority participant’s pre-emptive rights, fewer documents are required, and the registration process for transferring 100% of the shares becomes more straightforward, with no risk of shares being transferred to the buyer at different times;
  3. They offer a convenient way for holding companies to launch new projects, where the parent company or one of its subsidiaries sets up a separate entity for a new product; and
  4. They streamline governance, allowing for quicker decision-making.

Thus, the amendments are designed to simplify business operations and increase its adaptability and resilience to modern realities, particularly in light of the constantly evolving geopolitical environment.

New rules for formalising decisions of a sole shareholder

In addition, on 1 August, a new provision of Article 47 of the Law on Joint-Stock Companies came into force, governing the formalisation of corporate decisions in JSCs with a sole shareholder. Such decisions no longer require certification by notary or registrar, as has been the case until now, but can be made in simple written form (unless the charter specifically requires a certain form of certification).

On the one hand, the amendment is intended to resolve a long-standing practical dispute about the need to certify the decisions of a sole shareholder.

Previously, there were two opposing views on the matter. One view, supported by the Bank of Russia in its Letter of 25 November 2015 No. 06-52/10054, held that the rules in sub-paragraph 2, paragraph 3, Article 67.1 of the Civil Code apply only to resolutions of the general meeting of shareholders in non-public JSCs and do not apply to decisions of a sole shareholder. The other view relied on the interpretation of the Civil Code whereby, if the sole shareholder exercises the powers of the general meeting (as a corporate body), the formal requirements applicable to general meeting resolutions should also apply to their decisions.

On the other hand, given the absence of corresponding changes in sub-paragraph 2, paragraph 3, Article 67.1 of the Civil Code, and the Supreme Court’s position* that a sole shareholder’s decision not certified in the prescribed manner is void, there remains a risk that a decision made under the new provision of the Law on JSCs could still be invalidated.

In this regard, until further clarifications are issued by the Bank of Russia or the Civil Code is amended, we still recommend having sole shareholder decisions certified by a registrar or a notary.

* In Russian
Authors
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| PDF in English >> | PDF in Russian >>
]]> SL LEGAL recognised among the leading law firms in Russia for private client services http://sl.legal/tpost/6h6iosu111-sl-legal-recognised-among-the-leading-la http://sl.legal/tpost/6h6iosu111-sl-legal-recognised-among-the-leading-la?amp=true Mon, 25 Aug 2025 15:00:00 +0300 News SL LEGAL Private Client Practice recognised in four key areas.

SL LEGAL recognised among the leading law firms in Russia for private client services

Русская версия >>

WEALTH Navigator magazine has published the first results of its new ranking of law firms specialising in HNW clients advisory – WEALTH Navigator Legal.

SL LEGAL Private Client Practice has been recognised in four key areas:

  • Personal taxation and wealth planning
  • Transactions with assets, securities. Investments
  • Structuring of international holdings and assets
  • Support with cross-border financial operations and interaction with international banks

The ranking is based on comprehensive research and a detailed assessment of firms providing legal support to private clients in matters of wealth structuring, succession, investment, and cross-border transactions. Its goal is to highlight the most reliable and effective providers of legal services in this highly specialised segment.

WEALTH Navigator continues the tradition of SPEAR’S Russia, which has built a strong reputation over 14 years as an authoritative source in the field of private banking and wealth management.

The full ranking results (in Russian) >>

Contacts:
Yulia Smourova
Counsel
Head of Private Clients
yulia.smourova@sl-legal.ru
]]> The Russian Supreme Court has prepared a review of practice in cases involving the recovery of damages from company directors http://sl.legal/tpost/tk7z7ezhg1-the-russian-supreme-court-has-prepared-a http://sl.legal/tpost/tk7z7ezhg1-the-russian-supreme-court-has-prepared-a?amp=true Thu, 21 Aug 2025 16:40:00 +0300 News Publication We have analysed the Review and prepared a summary for you.

The Russian Supreme Court has prepared a review of practice in cases involving the recovery of damages from company directors

Русская версия >>

On 30 July 2025, the Supreme Court published a Review* of the Practice of Arbitrazh Courts’ Consideration of Cases on Corporate Disputes Related to the Application of Article 53.1 of the Russian Civil Code (the “Review”). This article gives a company the opportunity to recover damages from its director caused during exercise of the managerial powers.

The 48-page Review summarises court practice on conflict of interest, director’s remuneration, use of company assets for own needs, grounds for director’s liability, approval of transactions, liability of a “shadow director”, limitation of director’s liability by an agreement (indemnity), and application of limitation periods in claims against company directors.

We have analysed the Review and prepared a summary for you.

Conflict of interest

  • If a director has not disclosed a conflict of interest in relation to a loss-making transaction, it is presumed that the company’s losses are attributable to the director’s actions (paragraph 1). If, on the other hand, the director has disclosed an interest in the transaction, it is presumed that the director acted in the company’s interests in making the transaction (paragraph 2).

  • A conflict of interest between the director and the organisation may be proven with evidence of both formal and actual affiliation (paragraph 3).

Remuneration of a director

  • A director may not increase his/her remuneration at his/her discretion. Such remuneration may be recovered as damages (paragraph 4).

  • If a director withdraws funds from the company under the guise of increased payments in favour of subordinates (bonuses, dismissal compensation), he/she is obliged to compensate for these losses (clause 8).

Utilisation of company assets

  • A company may recover damages (including lost profits) caused by the use of its assets for the personal benefit of a director or third parties (paragraph 5). The minimum amount of damages is equal to the amount of profit gained by those persons (paragraph 6).

  • A director is entitled to spend company funds on himself/herself and others if the expenditure is intended to protect the interests of the company. Lawyers hired by the company for defence may also defend the director and other employees of the firm (paragraph 7). In such a situation, the bills paid by the firm for the defence of the director and employees do not qualify as damages and cannot be recovered from the director.

Grounds of liability

  • A change in the company’s development plans and the appointment of a new director following a change of ownership does not indicate that the actions of a previous director were wrong. If his/her actions were consistent with ordinary business risk, he/she is not liable for adverse consequences in connection with his/her decisions and transactions (paragraph 9).

  • A director is responsible for the reasonableness of his/her endeavours to manage the company, but cannot be held individually responsible for its success. The failure of the company to achieve specific targets (e.g. sales and revenue) does not represent a basis for a director’s liability. He/she is also exempt from liability for actions designed to minimise damage to the company’s interests (paragraph 10).

  • A director must put in place a management system to ensure due diligence in selecting and vetting counterparties. If there is no such system, the director is liable for losses incurred by the company due to breach of contracts by unreliable counterparties (paragraph 12).

  • The obligation to form the company’s assets rests with its members. Therefore, the director is not liable for losses caused by the insufficiency of the company’s assets and the inability to raise additional finance (paragraph 13).

  • Bringing a company to public law liability (administrative, tax) does not in itself create an obligation for the director to compensate the company for losses. Such a duty arises when the director fails to observe the principles of reasonableness and good faith in his activities (paragraphs 14 and 15).

Approval of transactions and claims against a director

  • The execution of a major transaction without corporate approval does not in itself give rise to a claim for damages against a director if his/her actions were in the interests of the company (paragraph 20).

  • A member of a company may approve a transaction by his/her tacit behaviour. Such approval is evidenced by the fact that there was no objection to the way the company is managed – but only if the company’s participants have full knowledge of the state of affairs. This approval remains valid even in the event of a change of ownership of the company (paragraph 16).

  • A director may not rely on the approval of a transaction if such approval was invalid due to formal irregularities, for example, in the absence of a quorum (paragraph 17). An approval obtained by a director based on incomplete or concealed information is also invalid (paragraph 18). If approval is obtained from a company participant interested in the making of a transaction, it will not protect the director either (paragraph 19).

Liability of a “shadow” director

  • A person who de-facto manages the day-to-day operations of a company is liable for losses as a formal director. The de-facto authority is confirmed by a set of facts: active participation of the “shadow director” (instructions to departments of the company, preparation of draft contracts and agreeing their terms, use of electronic signature) and ousting of the formal director from management (paragraph 22). A participant of the company acting to its detriment in its own interests will be liable on similar principles (paragraph 21).

Limitation of liability agreement (indemnity)

  • The law prohibits limiting the liability of a director of a public company for bad faith and unreasonable behaviour. In other types of companies, it is not possible to limit a director’s liability for acting in bad faith. Therefore, an agreement to eliminate or restrict a director’s liability is null and void regardless of the form in which it is drawn up, including if it is set out in a resolution of a shareholders’ meeting or the company’s charter (clause 23).

Limitation period for claims against a director

  • Where a director has concealed information about a transaction that creates a conflict of interest, the limitation period starts to run from the date on which the company (its members) had a real opportunity to learn about the transaction and the inconsistency of its terms with the interests of the company (paragraph 24).

  • As a rule, the approval of annual financial statements by a member (shareholder) of a company does not start the limitation period for a claim against a director in respect of a loss-making transaction made in the reporting period. However, the limitation period may begin to run in a situation where the information submitted for approval of the annual accounts could have been used to infer a change in the company’s financial position and, consequently, the occurrence of losses, or where the accounts themselves were obviously distorted (paragraph 25).

  • At the same time, a change in the composition of the company’s participants (shareholders) does not change the limitation period for a claim against a director for damages (paragraph 26).

Conclusion

The review not only elaborates on the courts’ approaches to holding directors liable for company losses and consolidates case law but also underscores the need to strike a balance between protecting businesses from misconduct and shielding acting-in-good-faith directors from unjustified liability, which is a key principle for Russian corporate governance.

* In Russian


Contacts:
]]> National regime in public procurements after the 2025 reform http://sl.legal/tpost/5bvzcrryx1-national-regime-in-public-procurements-a http://sl.legal/tpost/5bvzcrryx1-national-regime-in-public-procurements-a?amp=true Thu, 14 Aug 2025 14:11:00 +0300 News Publication Government taking active measures to improve sustainability of drug supply.

National regime in public procurements after the 2025 reform

Русская версия >>

Although there is no acute product shortage on the Russian market of drugs and medical devices, the legislator and the Government have been taking active measures to improve sustainability of drug supply for several years. One of the courses of such measures is the stimulation of local production of pharmaceutical and medical products.

As part of this policy, at the end of 2024, amendments were made to the Federal Law No. 44-FZ “On the Contract System for Procurement of Goods, Works, and Services for State and Municipal Needs” (“Federal Law No. 44”) and the Federal Law No. 223-FZ “On Procurement of Goods, Works and Services by Certain Types of Legal Entities” (“Federal Law No. 223”) (collectively – the “Laws”).

As a general rule, when procured in accordance with the Laws, goods of foreign origin are granted the national regime under which such goods enjoy equal conditions with goods of Russian origin.

However, to support Russian production, the Government may establish exemptions from the national regime. Until 2025, these were scattered in a number of legal acts and included, among others, the well-known “third one out[1]” rule.

The above-mentioned amendments have consolidated the exemptions from the national regime in Article 14 of the Federal Law No. 44 and Articles 3, 3.1-4 of the Federal Law No. 223, as well as in the Government Decree No. 1875 of 23 December 2024 (the “Decree”).
Types of exemptions from the national regime
The Laws establish three types of exemptions from the national regime:

  • Prohibition – any bid offering goods of foreign origin is rejected.
  • Restriction – all bids offering goods of foreign origin are rejected if there is at least one bid which offers goods of Russian origin (the “second one out” rule).

The similar “third one out” rule, which previously applied to certain medical devices (for example, bandages and microscopes) and to drugs from the EDL[2], has been abolished.

  • Preference – a bidder who has offered to supply goods of Russian origin benefits from a 15% price preference (i.e. a reduction in price offer for the sole purpose of determining the winner; in the event of winning the contract is concluded at the price offered by the winner).

For the purposes of applying the exemptions, goods from the Eurasian Economic Union (“EAEU”) are equated with Russian goods.
Applying the exemptions to medical devices
The applicability of the exemptions from the national regime to medical devices (the “MDs”) is described in the table below:
Restriction
Prohibition
Preference
Previously it applied only to certain types of radioelectronic products. Now it applies to dozens of types of MDs listed in Annex No. 2 to the Decree.
Applies to vacuum tubes for blood samples, certain medical furniture, ventilators and medical masks (Annex No. 1 to the Decree).
MDs localised in the EAEU and not included in Annexes No. 1 and No. 2 to the Decree enjoy a 15% price preference over foreign products.
In addition, for MDs from Annex No. 3 to the Decree, a mandatory minimum share of procured goods of Russian origin is stipulated. In particular, it is set for medical gauze (90%), rubber and latex surgical gloves (20%), devices based on the use of α-, β- or γ-radiation (45%), computer tomographs (30%), fluoroscopic and radiographic devices (75%).
Applying the exemptions to drugs
Drugs are specified in item 433 of the list of goods (Annex No. 2 to the Decree) which under clause 1 of the Decree are subject to the restriction. At the same time, paragraph “p”, clause 4 of the Decree specifies that the established restriction applies only to the procurement of EDL drugs. In other words, the restriction does not apply to the procurement of drugs that are not included in the EDL[3].

Preference is applied to drugs from the EDL considering the degree of their localisation.
EDL drugs
Restriction (clause 1 of the Decree)
Preference (paragraph “у”, clause 4 of the Decree)
Application of the “second one out” rule in procurements involving drugs originating from the EAEU. Bids with drugs from countries that are not members of the EAEU are rejected.
Drugs localised in the EAEU through the full cycle (including the synthesis of the active pharmaceutical ingredient) enjoy a 15% price preference over drugs with incomplete localisation in the EAEU.
In the original version of the Decree, not only the restriction, but also the preference applied only to EDL drugs. The antitrust authority even started to form a corresponding practice[4]. This came as a surprise to many companies in the industry, as previously, before the Decree was adopted, the preference was applied to all localised drugs regardless of their presence in the EDL.

In June 2025, the reference to the preference was deleted from the clause of the Decree stating that the restriction and preference apply only to EDL drugs. On the one hand, this can be interpreted as a return of the applicability of the preference to localised drugs that are not included in the EDL. On the other hand, due to the lack of changes in some other clauses of the Decree[5], it is still difficult to expect the antitrust authority to adopt such an interpretation in practice. Especially considering that in July 2025, the Ministry of Industry and Trade pointed its view that preference should apply only to EDL drugs[6].

Some drugs from the EDL are also included in the List of Strategically Important Drugs, the production of which must be guaranteed within the territory of the Russian Federation, approved by the Russian Government Order No. 1141-р dated 6 July 2010 (the “SID List”)[7]. At present, the procurement of drugs from the SID List is carried out on the same terms and conditions as procurement of EDL drugs[8], but from

1 September 2025 they will be subject to a restriction based on the degree of localisation:
Drugs from the SID List
Restriction (clause 1 of the Decree)
Restriction (paragraph “ф”, clause 4 of the Decree)
Application of the “second one out” rule in procurements involving drugs originating from the EAEU. Bids with drugs from countries that are not members of the EAEU are rejected. Note: The restriction applies because currently all drugs from the SID List are included in the EDL.
If at least one bid is submitted for supply of a drug fully localised in the EAEU, bids with incomplete localisation are rejected. Note: If a drug is included in the SID List after 01.01.2025, this restriction does not apply to it until 1 September of the second year after the year of such inclusion (paragraph “ж”, clause 10 of the Decree).
Procurement of drugs and MDs that are not produced in Russia
Added as a result of the national regime reform, Article 33(1.1) of the Federal Law No. 44 requires that when describing the goods subject to procurement for which exemptions from national regime are established, the characteristics of the goods of Russian origin must be specified. Compliance with this requirement caused difficulties for public customers who have a need for drugs and MDs that are not produced in Russia[9]. This requirement also contradicted the established court practice, according to which medical organisations have the right to establish requirements for goods taking into account their own needs and based on the specifics of their activities[10].

It is likely that the radical nature of this rule and its inconsistency with the established positions of the courts caused the antitrust authority's relatively “soft” stance towards its compliance. For example, one of the decisions of antitrust authority notes[11]:

“... the requirement to specify the characteristics of goods of Russian origin in the description of the object of procurement prevails over the customer's need for goods of foreign origin if there is production of such goods in the territory of the Russian Federation ...”.

In another decision[12], the antitrust authority upheld a customer who had specified characteristics of catheters that were not manufactured in the EAEU. The customer explained that neither in the Register of Russian Industrial Products (the “RRIP”) nor in the State Register of MDs it may find catheters that fully meet its needs.

Finally, the Government took notice of this difficulty by amending the Decree[13] in June 2025 to include special provisions for the procurement of goods not produced in Russia:
when procuring goods from items 1 to 433 of Annex No. 2 to the Decree (goods to which the restriction applies, including drugs and certain MDs)[14], the customer shall:
  • notify the Ministry of Industry and Trade of the absence of goods with the required characteristics in the RRIP before commencing the procurement;
  • declare in a procurement documentation the fact of such absence;
  • include in the description of the object of procurement a copy of the notification sent to the Ministry of Industry and Trade.
when procuring goods not included in the above items and items 1 to 145 of Annex No. 1 to the Decree (currently only software MDs can fall under this rule)[15], the customer shall
  • declare in a procurement documentation the fact that goods with the required characteristics are not manufactured in Russia.

Thus, a customer planning to procure foreign drugs and MDs covered by national regime exemptions is expected not only to take a reasonable approach to describing the characteristics of the foreign goods, but also to be sure that such goods do not exist in the RRIP or that there is no production of such goods in Russia (depending on the position of the goods in the Annexes to the Decree). In the latter case, it may be especially problematic for the customer to draw up the procurement documentation, as the declaration of complete absence of the production is only possible in case of in-depth knowledge of the particular industry sector.

Among other things, the above declaration should encourage customers to be more careful with the justification of the required characteristics of the goods to be procured, because now the potential bidders and the supervisory authority will immediately see that the need for specific characteristics is the reason for the procurement of foreign goods.

Considering that, references to the needs of medical practice may help to justify the customer’s desire to procure the foreign goods with some specific characteristics.

For example, in a dispute[16] over the procurement of immunoglobulin in packages of a size which are not produced in the EAEU, the antitrust authority agreed with the customer who justified its need for such packages by arguing that doses are calculated on an individual basis and the required size prevents the occurrence of adverse events that could cause the need for additional medication and complications of the patient's condition.

In another case, the argument was that Russian catheters had absolute contraindications to use, which were absent in the foreign MD described by the customer[17].

The fact that the product specifications set out in the procurement documentation are met by several manufacturers — even if foreign — may also support the position of the customer[18]. This may serve as evidence that the customer has no intention to violate the law or to restrict competition in procurement.
Authors
Downloads
PDF in English >> | PDF in Russian >>
References
[1] If at least two bids are submitted for the supply of products originating from the EAEU, all bids offering products from non-EAEU countries shall be rejected.
[2] The Essential Drugs List approved by the Russian Government Order No. 2406-р dated 12 October 2019.
[3] See, for example: Decision of the Krasnodar Office of the FAS of Russia dated 19 February 2025, No. 023/06/14-712/2025.
[4] Decision of the North Ossetian Office of the FAS of Russia dated 14 April 2025, No. 015/06/105-299/2025.
[5] See, for example: paragraph “б” of clause 4 of the Decree.
[6] Materials of conference “Public Procurements Perm-2025”.
[7] All of them are included in the EDL.
[8] See, for example: Decision of the Lipetsk Office of the FAS of Russia dated 3 April 2025, No. 048/06/106-325/2025.
[9] Federal Law No. 223 does not contain a similar requirement; therefore, the issue described does not arise in procurements conducted under this Law.
[10] Paragraph 1 of the Review of Judicial Practice approved by the Presidium of the Supreme Court of the Russian Federation on 28 June 2017.
[11] Decision of the Primorsky Office of the FAS of Russia dated 6 June 2025, No. 025/06/105-543/2025.
[12] Decision of the Samara Office of the FAS of Russia dated 13 February 2025, on complaint No. 30-14833-25/4.
[13] Strictly speaking, the amendment to the Decree does not resolve the issue of compliance with Article 33(1.1) of Federal Law-44. However, it might be assumed that, in practice, no liability will arise for non-compliance with Article 33(1.1) of Federal Law No. 44 if the provisions of the Decree are followed.
[14] Including any medicinal products.
[15] In particular, all medical devices subject to the prohibition are included in the relevant positions of Annex No. 1.
[16] Decision of the Moscow Office of the FAS of Russia dated 18 March 2025, No. 077/06/106-3190/2025.
[17] Decision of the Tyumen Office of the FAS of Russia dated 23 April 2025, No. 072/06/44/55/2025.
[18] Decision of the Khabarovsk Office of the FAS of Russia dated 18 February 2025, No. 7-1/36, No. 027/06/105-233/2025.
]]> Compensation for intellectual property rights infringement: new procedure and additional opportunities for rightsholders http://sl.legal/tpost/54eea6o4n1-compensation-for-intellectual-property-r http://sl.legal/tpost/54eea6o4n1-compensation-for-intellectual-property-r?amp=true Mon, 04 Aug 2025 15:54:00 +0300 News Amendments to the Russian Civil Code come into force on 4 January 2026.

Compensation for intellectual property rights infringement: new procedure and additional opportunities for rightsholders

On 7 July 2025, Federal Law No. 214* was adopted, introducing amendments to Part IV of the Russian Civil Code. The new provisions will come into force on 4 January 2026.
The amendments relate to changes in the procedure for claiming and calculating compensation for infringement of exclusive rights to intellectual property (“IP”).
Key amendments:
1) Court’s right to change the method of compensation calculation
The court may now use its discretion to change the method of calculating compensation applied by the claimant if such is deemed inappropriate. Previously, this option was unavailable based on Para. 59 of the Plenum of the Supreme Court of the Russian Federation Resolution No. 10 dated 23 April 2019.
2) Increased limits for fixed-sum compensation
The maximum compensation for copyright, related rights, patent rights, and trademark infringement has been doubled – from RUB 5m to 10m (from EUR 55,000 to 110,000).
For patent rights infringement, the minimum amount of compensation has risen from RUB 10,000 to 50,000 (from EUR 110 to 550).
3) Amended procedure for calculating compensation in case of multiple infringements
When a single counterfeit product infringes on several IP objects simultaneously, the court may adjust the amount of compensation based on the specific circumstances and severity of the infringement.
Methods of compensation calculation
General rules of calculation
Fixed amount
From RUB 10,000–50,000 (ca. EUR 110-550) (per specific IP object) up to RUB 10–20m (ca. EUR 110,000-220,000)
Counterfeit product’s value multiplier
Between one time and two times the value of the counterfeit product
Licence fee multiplier
More than the highest applicable licence fee, but not exceeding twice that amount
4) Use of an IP object by different means for one economic purpose constitutes a single infringement
Previously codified in Para. 56 of the Plenum of the Supreme Court Resolution No. 10 dated 23 April 2019, this rule is now formally enshrined in law.
5) New procedure for compensation to co-rightsholders
Previously, each co- rightsholder could only claim their proportional share of the compensation. Under the new rules, a single co-rightsholder is entitled to claim the full compensation amount, which is later to be distributed among all co-rightsholders.
6) Absence of fault may reduce compensation for entrepreneurs
According to the Russian Civil Code, entrepreneurs are generally liable regardless of fault. The amendments allow courts to reduce compensation if it is established that the infringer did not know and could not have known that their actions constituted an infringement:
  • For fixed-sum compensation – from RUB 10,000 to 500,000 (from ca. EUR 110 to 5,500).
  • For compensation based on the counterfeit product’s value or licence fee multipliers– from onefold to twofold of the respective value.
7) Joint and several liability within a chain of infringers
The new mechanism concerns the recovery of compensation from several persons for infringements relating to the same counterfeit product, for example, in the chain “counterfeit producer” – “distributor” – “retailer”.
It will be possible to jointly recover compensation from the infringers if holding them liable separately could result in unjust enrichment on the part of the copyright holder.
As a general rule, the compensation paid by one infringer may be recovered from other infringers, pro rata their “involvement”. If it is impossible to determine the degree of each infringer’s participation, it is presumed that the involvement was equal.
8) Certain infringements now compensated by fixed amounts only
  • Circumvention of technological protection measures (Art. 1299 of the Civil Code) – from RUB 10,000 to 5m (from ca. EUR 110 to 55,000).
  • Alteration/removal of the author information (Art. 1300 of the Civil Code) – from RUB 1,000 to 100,000 (from ca. EUR 110 to 1,100).
  • Infringement of rights to geographical indications or appellations of origin (Art. 1537 of the Civil Code) – from RUB 10,000 to 5m (from ca. EUR 110 to 55,000).
In addition to these amendments, it is noteworthy that citing a source that lacks the author information no longer constitutes an infringement – provided that such citation contains the source of the borrowed piece, and that such source did not contain such information. This rule applies for the cases of free use without remuneration.
Comments
These changes are intended to strengthen the position of rights holders while maintaining a balance between their interests and the public interest.
We recommend you take these changes into account while using third-party IP and protecting yours.
* In Russian

Authors
]]> Pravo.ru: international digest for July http://sl.legal/tpost/pinumn25d1-pravoru-international-digest-for-july http://sl.legal/tpost/pinumn25d1-pravoru-international-digest-for-july?amp=true Sat, 02 Aug 2025 16:00:00 +0300 Comments Review of the 18th sanctions package and solidarity in anti-suit injunctions.

Pravo.ru: international digest for July

In July, the EU approved its 18th package of sanctions. The most debated innovation is the right to deny enforcement of investment arbitration awards and to claim damages arising from them. At the same time, Russian courts are developing new approaches to sanctions-related disputes: frozen assets cannot be recovered until the regulator refuses to issue a license. There are also changes in case law on anti-suit injunctions — they are now granted not just to one firm but to an entire corporate group. According to lawyers, this reflects a trend toward solidarity.

Case

The Arbitrazh Court of St. Petersburg and the Leningrad Region refused to recognise a judgment of the Stuttgart Land Court (Landgericht) (Case No. А56-49800/2024). The request came from the German company Viavi Solution Deutschland GmbH, to which the Russian company Vilcom SPB owed more than $160,000. This was already the second round of proceedings: last October, the same court granted the German company’s request. However, the Arbitrazh Court of the North-Western District disagreed with that ruling. The cassation court recalled that there is no treaty between Russia and Germany on the recognition of foreign judgments, and Germany is included in the list of unfriendly states. Recognition is still possible under the principle of reciprocity. Therefore, the court asked the claimant to provide evidence that Russian courts’ decisions in similar cases had been enforced in Germany over the past three years. Viavi Solution failed to do so, and upon reconsideration, the St. Petersburg court refused to recognise and enforce the German judgment.

Comment
In this case, the court’s approach fully corresponds to the strict wording of Article 241 of the Arbitrazh Procedure Code, says Igor Sokolov, Senior Associate in the Dispute Resolution practice at SL LEGAL. According to this article, recognition and enforcement of a foreign judgment requires either an international treaty or a specific clause in a law. Russian courts rarely recognise foreign judgments based solely on reciprocity or international comity. Another nuance here is that these principles are not enshrined in law, and courts interpret them differently.
In such cases, a foreign counterparty still has the option to enforce the judgment in another jurisdiction or retry the case in Russia. However, this is not suitable for all disputes.

There are numerous examples of foreign creditors chasing the assets of Russian companies abroad. But this strategy makes sense only for large claims, as it requires significant resources and time. For smaller claims, it may be more practical to re-litigate the matter in Russia — provided the limitation period has not expired and the claim itself is strong and well-documented.

Read more in the full article via the link*.

* In Russian
Contacts:
]]> SEAMLESS Legal and SL LEGAL have completed their restructuring http://sl.legal/tpost/sizv0s9lj1-seamless-legal-and-sl-legal-have-complet http://sl.legal/tpost/sizv0s9lj1-seamless-legal-and-sl-legal-have-complet?amp=true Fri, 01 Aug 2025 16:00:00 +0300 News Team of partners and counsels based in Moscow will carry on serving their clients in Russia and beyond under the brand of SL LEGAL.

SEAMLESS Legal and SL LEGAL have completed their restructuring

SEAMLESS Legal, an independent law firm successor to CMS Russia, announces completion of the restructuring of its operations.

As a result, a team of partners and counsels based in Moscow will carry on serving their clients in Russia and beyond under the brand of SL LEGAL.

For its part, SEAMLESS Legal will remain dedicated to supporting its clients through its Moscow representative office under the SEAMLESS Legal brand and will continue developing Middle East market through its headquarters in Abu Dhabi (UAE).

SEAMLESS Legal and SL LEGAL remain “best friends” and will continue collaborating in various ways to provide the most efficient client service.
Contacts:
press@sl-legal.ru
]]> Life sciences sector in Russia: regulatory landscape for 2025 http://sl.legal/tpost/ydnbxfte51-life-sciences-sector-in-russia-regulator http://sl.legal/tpost/ydnbxfte51-life-sciences-sector-in-russia-regulator?amp=true Mon, 31 Mar 2025 15:57:00 +0300 Publication In the geopolitical environment after 2022, foreign companies in Russia have tried to balance between maintaining their market share and dealing with sanction pressures.

Life sciences sector in Russia: regulatory landscape for 2025

In the geopolitical environment after 2022, foreign companies in Russia have tried to balance between maintaining their market share and dealing with sanction pressures. Some succeed, some fall into the trap of overcompliance, and others (mostly Western) give up and cease their Russian operations.

The situation in the life sciences industry remains relatively stable. There has been no avalanche of pharmaceutical or medical device companies exiting Russia. Most market players continue to operate in the country, while Asian and local companies are assessing opportunities to take over market share vacated by Western companies.

The authorities form the regulatory landscape that encourages Russian and foreign companies to create local production, preserves “soft” launch options for unauthorised products, balances the interests of generic and innovator companies, and unifies the requirements across the Eurasian Economic Union (EEU), which comprises Russia, Belarus, Kazakhstan, Armenia and Kyrgyzstan.

Incentives for local producers

The public procurement market is of importance for pharmaceutical and medical device companies in Russia since the most significant part of local medical institutions is state-owned. Locally made (produced within the EEU) medicines and medical devices enjoy preferences in public tenders, and from 2025, such preferences have become more significant.

When procuring medicines from an essential drug list (EDL) or medical devices from a government list, clinics should reject any bids to supply foreign products if there is at least one bid offering products that originates from the EEU (the “second out rule”). Additionally, EDL medicines having full cycle production within the EEU enjoy a 15% pricing privilege over the ones with partial localisation of production.

This means that, for bidding purposes, the price of fully localised medicine has a 15% discount, but if the bidder wins, the contract is concluded at the offered price. The same applies to most medical devices with a slight modification: it applies to devices originating from the EEU over those that are foreign. These factors, together with further described features of the EEU single market, force some companies to consider Russia as an advantageous logistics and manufacturing hub for the CIS region.

EEU single market

Treaties among EEU states stipulate a common market for circulation of medicines and medical devices, potentially with a unified regulatory landscape (not all legal requirements across member countries are unified, but most are).

The main benefit of a unified regulatory landscape is the common market authorisation procedure that medical devices may, and medicines must, pass through. Once the product is authorised for the EEU market, it may be sold in any EEU member states at the marketing authorisation holder’s discretion.

Unauthorised products

Generally, medicines and medical devices must obtain a marketing authorisation before being sold. Usually, it is a long and complex procedure. For companies wanting to “test” the Russian market, the legislation provides an option of importing unregistered medicines and medical devices on a named-patient basis. Such supplies are possible with permission from the healthcare authority, granted on the decision of a council of physicians who prescribe an unauthorised product for a particular patient. This mechanism is powered with significant state financing through the governmental charity fund “Circle of Kindness”.

Innovator vs generic

The Russian legal system seeks to balance the interests of producers of original and generic medicines, trying to ensure both the proper protection of intellectual property rights and the availability of medical care to the wider public (not possible without the availability of inexpensive generics). Courts and the Federal Antitrust Service (FAS) typically support innovators in patent infringement cases. For instance, in 2024, the FAS deemed the early market launch of generics for several well-known innovator medicines to be unfair competition. The total fine for companies indicted exceeded RUB1 billion (USD10.9 million).

The regulator also strives to prevent shortages of medicine. If supplies of innovator medicines do not satisfy demand, the government (unilaterally) or the courts (after a fair trial) may grant compulsory licences to generic manufacturers or importers.

Even though only a few compulsory licences have been granted, the availability of this mechanism motivates both parties. Innovators should ensure uninterrupted supply of their products, while generics manufacturers should keep their products ready for launch, knowing that at some point they may seek a compulsory licence and take significant market share.

Originally published in Asia Business Law Journal.
Contacts:
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