Earlier, we wrote about the new law “on landing” foreign IT companies, under which some of them must open a representative office, branch or separate legal entity in Russia starting January 1, 2022. Based on this law, on November 22, Roskomnadzor published a list of such companies, which currently includes Google, Apple, Meta Platforms (aka Facebook), Twitter, TikTok, Telegram, Zoom, Likeme, Viber, Discord, Pinterest, Spotify and Twitch.

The main criterion for being included in this list is the resource having over daily 500,000 visitors. In addition, the relevant Internet resource or its foreign owner must fall under at least one of the following conditions:

• The resource provides or disseminates information in Russian, in state languages of the Russian republics or other languages of the peoples of Russia;
• The resource disseminates advertisements aimed at Russian consumers;
• The foreign entity processes data on users located on Russian territory;
• The foreign entity receives money from Russian individuals and legal entities.

Therefore, the list is expected to be expanded to cover foreign online stores and other social media.

Be aware that the Roskomnadzor web site has information on IT companies fulfilling their obligations to open a representative office, register a personal account and post an electronic feedback form on their web resources. In addition, Roskomnadzor will post information on “inducement measures” taken against foreign companies, including bans on advertising or displaying by search engines, restrictions on access to web resources and money transfers, etc.

So far, none of the listed companies have fulfilled the said obligations. However, we anticipate that they will begin to do so in the coming weeks in order to retain their income from Russian users.

We are monitoring the list updates and will keep you informed about all changes related to the landing of IT companies!

Our experts will be glad to discuss the adopted amendments with you, to assist in analyzing your business in terms of the need to comply with these requirements and to give recommendation on how to comply with them.