On 29 December 2025, Federal Law No. 562-FZ “On Amendments to Articles 3.5 and 19.8 of the Code of Administrative Offences of the Russian Federation” (the “Law”) was adopted.

The Law increases the amount of administrative fines for violations of the procedure for obtaining clearance from the Federal Antimonopoly Service of Russia (FAS Russia) for economic concentration transactions, including transactions involving the acquisition of shares (participatory interests), assets of commercial organisations, and other transactions requiring prior approval from the Russian antimonopoly authorities.

It should be recalled that administrative liability arises where an application for prior approval from FAS Russia is not submitted, where inaccurate information is provided, or where other requirements regarding the procedure and deadlines for filing such applications are violated.

Under the new rules, the maximum fine for legal entities has been doubled from RUB 500,000 to RUB 1 million. For individuals, the maximum fine has increased from RUB 2,500 to RUB 50,000, while for officials it has increased from RUB 20,000 to RUB 100,000.

Overall, these changes were expected. From 1 January 2025, the state fee for the review of applications by antimonopoly authorities was increased to RUB 400,000. Following this change, representatives of FAS Russia repeatedly expressed the view that corresponding amendments to the Code of Administrative Offences were required to proportionally increase fines for failure to obtain merger clearance.

Key Takeaways for Businesses

In light of the increased liability for violations of the procedure for obtaining clearance from FAS Russia, companies and their officers should exercise increased caution when planning and implementing transactions subject to prior antimonopoly approval. Particular importance should be given to ensuring the completeness and accuracy of submitted information, as well as compliance with the established procedure for filing applications.

Co-authored by Ksenia Voloshchenko, Associate in Antitrust & Regulatory.