A ban on advertising on “banned” websites has been introduced

22 April 2025

On 7 April 2025, the President signed Law No. 72*, which prohibits Russian advertisers from placing adverts on restricted resources. These changes will come into force on 1 September 2025.

From that date, it will be prohibited to place advertisements on the following types of resources:

resources of foreign or international non-governmental organisations whose activities have been deemed “undesirable” in Russia (see the Ministry of Justice list*),
resources of public or religious associations or other organisations that have been liquidated and banned by court decision due to involvement in terrorism or extremism (see the Ministry of Justice list*),
other information resources to which access has been restricted (see Roskomnadzor register*).

Until 1 September 2025, advertisements may still be placed on these resources. However, the related advertising expenses will not be deductible when calculating the profits tax base. This tax amendment has been in force since 1 January 2025, pursuant to Law No. 416*.

From 1 September onwards, both advertisers and advertising distributors may be held liable for placing adverts on the above resources. Under Part 1 of Article 14.3 of the Administrative Code, the following fines apply:

Legal entities: from RUB 100,000 to 500,000,
Officials and individual entrepreneurs: from RUB 4,000 to 20,000,
Individuals: from RUB 2,000 to 2,500.

It is worth noting that the fines may be significantly increased before the amendments come into force, as some deputies have already voiced* such an initiative.

In addition, Law No. 72* introduces two further important amendments to the Law on Advertising.

Firstly, it has been specified that it is advertising distributors who are liable for placing adverts on pages with an audience exceeding 10,000 users if the page is not registered with Roskomnadzor. Previously, the subject of liability for this offence was not clearly defined, causing concern among market participants that advertisers could be penalised.

Secondly, the period for storing information about labelled online advertising in the Unified Internet Advertising Register (ERIR) has been reduced from five to three years.

In light of these amendments, advertisers are encouraged to review their current advertising campaigns. Bloggers and other content creators are advised to shift their Russian audiences to Russian social media platforms.

Advertisers working with agencies should ensure that contracts include clear obligations and guarantees from the agency that adverts will be placed only on “authorised” platforms. Contracts should also include provisions for the immediate removal of adverts in the event of a platform becoming banned. Since advertisers may still be held liable, it is advisable to include a clause requiring the agency to compensate the advertiser for any losses incurred as a result of non-compliance with these obligations.

* In Russian

Authors:

Alisa Mikheeva, Associate

Shermet Kurbanov, Associate

Intellectual Property & Digital Law

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