Russia's platform economy law from October 1, 2026: what it means for importers

What is the platform economy law, and when does it take effect?#

The “marketplace law” is the informal name for Federal Law No. 289-FZ of July 31, 2025, “On Certain Issues of Regulating the Platform Economy in the Russian Federation.” It takes effect in its entirety on October 1, 2026. Federal Law No. 290-FZ of July 31, 2025, and Federal Law No. 295-FZ of August 4, 2026, take effect on the same day, except for Part 3 of Article 14.69 of the KoAP, which takes effect on January 1, 2027.

Law No. 289-FZ has no phased rollout: Article 23 brings it into force on a single date, while secondary legislation containing mandatory requirements takes effect on the dates set by that legislation itself, but no earlier than ninety days after the day of its official publication. Law No. 290-FZ amends three acts: the Law of the Russian Federation “On Consumer Rights Protection,” Federal Law No. 381-FZ of December 28, 2009, “On the Fundamentals of State Regulation of Trade Activities in the Russian Federation,” and Federal Law No. 236-FZ of July 1, 2021. Law No. 295-FZ adds Articles 14.69–14.71 to Chapter 14 of the KoAP; Article 14.71 concerns appraisers.

What takes effect, and when:

• Federal Law No. 289-FZ of July 31, 2025 — from October 1, 2026.
• Federal Law No. 290-FZ of July 31, 2025 — from October 1, 2026.
• Federal Law No. 295-FZ of August 4, 2026 — from October 1, 2026; Part 3 of Article 14.69 of the KoAP — from January 1, 2027.
• Russian Government Decree No. 54 of January 28, 2026 (additional criteria for intermediary platforms) — from October 1, 2026, until October 1, 2032.
• Russian Government Decree No. 504 of April 30, 2026 (register of platforms) — from October 1, 2026, until October 1, 2032; the register is to be posted by November 2, 2026.
• Russian Government Decree No. 514 of May 6, 2026 (measures taken by Roskomnadzor, the Federal Service for Supervision of Communications, Information Technology and Mass Media, against foreign operators) — from October 1, 2026.
• Russian Government Decrees No. 766 (information for the tax authorities) and No. 768 (verification of a prospective partner) of June 20, 2026 — from October 1, 2026; Decree No. 768 remains in force through October 1, 2032.
• Russian Government Decree No. 820 of July 2, 2026 (state control) — from October 1, 2026.
• Russian Government Decree No. 821 of July 2, 2026 (listing verification) — “upon the expiry of 90 days after the day of its official publication”; it was published on July 2, 2026, so the date of October 1, 2026, is calculated and does not appear in the act; paragraph 3 applies from August 1, 2026, and Section IX of the Rules (trademarks) from March 1, 2027; paragraph 1, which approves the Verification Rules, the list of state information systems, and the Rules for interaction with their operators, remains in force through October 1, 2032.

The “Legislation of Russia” database (pravo.gov.ru) holds only the original version of Law No. 289-FZ: it has not been amended to date.

What will change for importers selling on marketplaces from October 1, 2026?#

There are two main changes. First, the operator of an intermediary digital platform checks the information in the product listing and does not allow the listing to be posted until the partner has posted information on conformity assessment, state registration, or labeling; the check is made against state registers and the labeling system in the manner established by the Government of the Russian Federation. Second, the seller itself is prohibited from posting an offer to sell such goods without valid documents or labeling. In addition, the seller gains the procedural safeguards of Federal Law No. 289-FZ of July 31, 2025: consent to seller-funded discounts, notice periods, a reasoned notice of any restrictions, and a pre-trial complaint.

Table 1. What changes for an importer acting as a seller. The operator's obligations apply to a platform from the date it is entered in the register of intermediary digital platforms.

Law No. 289-FZ does not set the amount of the operator's fee or the payment deadline: the contract sets only how the fee is determined, how settlements are made (including how the payment deadline is determined), and how discounts are set. Nothing in the platform economy acts requires a goods declaration (DT) to be presented to the operator — for details, see Does a marketplace need your customs declaration, and why does it ask for the CN FEA code?

Does the law apply to importers and foreign suppliers selling through a marketplace?#

An importer that sells goods as a legal entity or an individual entrepreneur and has entered into a contract with the operator of an intermediary digital platform is a partner acting as a seller within the meaning of Federal Law No. 289-FZ of July 31, 2025, “On Certain Issues of Regulating the Platform Economy in the Russian Federation”; a foreign supplier can also be a partner directly.

Under the definition in Law No. 289-FZ, a partner may be a legal entity, a foreign legal entity, a foreign organization without legal entity status, an individual entrepreneur, or an individual — including a foreign national or a stateless person — who pays professional income tax (NPD). Individuals entering into non-business transactions with each other are excluded from the definition. The law does not apply to relations connected with “the distribution exclusively of goods and services belonging to the owners of information resources.” For partners that are foreign persons acting on a lawful basis, the law applies to the extent that it does not conflict with the law of the Eurasian Economic Union and the international treaties of the Russian Federation; the operator indicates in the product listing that the offer comes from a foreign partner.

Obligations come in two layers. The operator's obligations are set by Law No. 289-FZ, and its administrative liability by Article 14.69 of the KoAP as amended by Federal Law No. 295-FZ of August 4, 2026. The ban on the seller is set out in Article 11¹ of Federal Law No. 381-FZ of December 28, 2009, as amended by Federal Law No. 290-FZ of July 31, 2025, and the seller's liability in Article 14.70 of the KoAP. For details, see What liability does a seller face for a listing without a certificate, SGR, or labeling?

Table 2. Who can be a partner of an intermediary digital platform.

When do the new rules start applying to Wildberries, Ozon, Yandex Market, and other platforms?#

This section will go out of date faster than the rest. A digital platform qualifies as an intermediary platform from the moment it is entered in the register of intermediary digital platforms, and it is the operator of such a platform that bears the obligations under Federal Law No. 289-FZ of July 31, 2025. The register is maintained by the Ministry of Economic Development of the Russian Federation; the date of entry is the date on which the entry is posted in the register on the ministry's official website. The ministry is required to compile and post the register by November 2, 2026.

How a platform gets into the register:

1. The ministry requests information from the Federal Antimonopoly Service (FAS) on its analysis of the state of competition and from the Federal Tax Service on the number of persons with paid transactions and the total value of those transactions; a reply is due within 14 calendar days. The platform owner may also file an application on its own initiative.
2. Within 5 business days of receiving this information, the ministry decides whether the platform meets the criteria; if it has sent a follow-up request to FAS and the Federal Tax Service, the period is suspended until the reply is received, but for no more than 14 calendar days.
3. The owner is notified of a decision that the platform meets the criteria no later than one business day after it is made and then has 5 business days to send a reasoned objection.
4. The entry is posted in the register no earlier than the 10th and no later than the 15th business day from the date the notice of the decision was sent or, if the owner filed an objection, from the date of the notice refusing to reverse the decision.

The criteria for an intermediary platform are set out in clause 9 of Article 2 of Law No. 289-FZ: the platform provides the technical means to place orders and product listings, enter into transactions, and pay the partner for goods. Quantitative criteria were set by Russian Government Decree No. 54 of January 28, 2026: an average of at least 100,000 daily users located in Russia over the preceding calendar year, plus one of two further indicators — at least 10,000 persons with transactions paid for through the platform, or a total value of such transactions of at least RUB 50 billion (both indicators are calculated from data on the use of cash register equipment, KKT). Exception: if the platform owner, or a person operating the platform under a contract with the owner, is a foreign person, only the criterion of 100,000 users per day applies, and the indicators for the number of persons and the value of transactions do not. Until an entry appears in the register, it cannot be said that any particular platform meets the criteria.

How to check a platform. The register is maintained on the official website of the Russian Ministry of Economic Development. The website publishes the entry number, the date of and grounds for inclusion, the platform name, the domain name, information about the operator, and the dates on which the entry was amended or the platform was removed from the register; whether the platform meets the statutory and additional criteria is not published. There is no obligation to post the register before October 1, 2026: Decree No. 504 takes effect on October 1, 2026, and the deadline for posting the register is November 2, 2026. On July 16, 2026, the Ministry of Economic Development announced that the register is scheduled to launch on October 1, 2026, and named a preliminary list of 12 platforms it plans to include: Avito, Delivery Club, Joom, Lamoda, Ozon, Wildberries, Kuper, Magnit Market, Yandex Go, Yandex Eats, Yandex Market, and Yandex Travel; platforms that are not on the list but meet the criteria may apply to the ministry for inclusion on their own initiative. The preliminary list is no substitute for an entry in the register: a platform becomes intermediary only from the date the entry about it is posted in the register. The ban on posting offers without documents is imposed on the business entity and applies to publicly available offers, “including” those on a platform; as worded, the provision does not make the ban conditional on the platform being entered in the register.

What is not yet clear. The period for re-checking previously posted listings runs from the date Russian Government Decree No. 821 of July 2, 2026, takes effect, while intermediary platform status arises only upon entry in the register, which is to be posted by November 2, 2026. There is no official guidance yet on how these periods relate to each other.

Which documents for imported goods will a marketplace check in the product listing?#

If goods are subject to mandatory conformity assessment, state registration (a state registration certificate, SGR), or mandatory labeling with means of identification, the operator of an intermediary digital platform does not allow the product listing to be posted until the partner has added to it a link to the relevant register entry or information on compliance with labeling requirements. The requirement that the entry have the status “valid” (“действует”) is established by Russian Government Decree No. 821 of July 2, 2026.

The check has two stages. First, the operator asks the partner for the 10-digit code under the EAEU Commodity Nomenclature of Foreign Economic Activity (CN FEA, Russian: TN VED) and/or the 9-digit code under the All-Russian Classifier of Products by Economic Activity (OKPD2) and uses them to determine whether special checks are needed; if they are not, the operator may admit the listing without them. The check is carried out within 3 business days of the date the partner provides the information. If any special check fails to produce a positive result, the operator decides that the listing cannot be posted and notifies the partner, stating the reasons, within one business day after the day on which the check was completed; the partner may correct the information and have it checked again, and the operator may not restrict such repeat checks. As a general rule, the information is kept up to date by checking it at least once every 10 business days from the date the listing was posted. Exception: this check is not carried out for information from registers that themselves notify the operator of changes within 3 calendar days; in that case, a special check is carried out within 3 business days of the date of the notification. Operators check listings posted before October 1, 2026, within 180 days of the date Decree No. 821 takes effect. The role of the CN FEA EAEU code is explained in Does a marketplace need your customs declaration, and why does it ask for the CN FEA code?

Certificates and declarations of conformity under TR CU and TR EAEU

The partner adds to the listing a link to the entry for the certificate of conformity and/or declaration of conformity in the register of issued certificates of conformity and registered declarations of conformity or in the EAEU Unified Register; without this link, the listing is not admitted. The special check is passed if all of the following conditions are met: the OKPD2 and CN FEA EAEU codes in the listing match the codes in the register entry for the document (if the entry states codes); the status of the document is “valid”; and, for a document issued by a certification body of another EAEU member state, the website of the national accreditation body contains no information on the suspension or termination of its validity in Russia. If the result is positive, the operator itself carries over the following from the register into the listing: information about the manufacturer, the product group (if any), information about the object of certification (declaration), the start date and the end date (if any) of the document's validity period, and a link to the register entry; for a document issued (registered) in Russia, a link to the entry in the Russian register of certificates of conformity and declarations of conformity.

Practical recommendation from Senateks (not a legal requirement): the details of the document must match the actual goods and manufacturer. Which document the goods need is determined by the technical regulation: mandatory conformity assessment is carried out only in the cases it provides for, and the forms and schemes of assessment are set only by the technical regulation.

SGR, dietary supplements, and other registered products

For goods subject to state registration, the partner adds to the listing a link to the certificate's entry in the unified register of state registration certificates for products; without it, the operator does not admit the listing. For such products, as well as for dietary supplements (biologically active food supplements), the check is passed if the certificate number and date of issue match the data in the EAEU unified register of certificates, the link leads to the register entry, and the status of the certificate is “valid.” Medicinal products are checked against the state register of medicines and the EAEU unified register, medical devices against the state register of medical devices and the EAEU unified register, and pesticides and agrochemicals against the Register of Pesticides and Agrochemicals.

Mandatory labeling

For goods subject to mandatory labeling with means of identification, the check is passed if two conditions are met: first, the partner is registered — under the INN established when its information was verified — as a participant in the circulation of goods in the state information system for monitoring the circulation of goods subject to mandatory labeling with means of identification (the labeling system); second, the listing contains information on compliance with labeling requirements, including the product code from the National Catalog of labeled goods subsystem. Without this information, or if the partner is not registered, the operator does not admit the listing. For medicinal products, the system for monitoring the movement of medicinal products is used; for jewelry and other articles made of precious metals and precious stones, the state integrated information system for monitoring their circulation. (This system is commonly known as Chestny ZNAK; the term is not used in Law No. 289-FZ or in Russian Government Decree No. 821 of July 2, 2026.)

The permits, licenses, and certificates under subclause (a) of clause 1 of Part 1 of Article 7 of Law No. 289-FZ relate to the performance of work and the provision of services, not to goods.

We will determine which permit or approval your goods need and arrange for it to be issued → Certificates and declarations of conformity (TR CU / TR EAEU); state registration certificates (SGR).

Does a marketplace need your customs declaration, and why does it ask for the CN FEA code?#

The texts of Federal Law No. 289-FZ of July 31, 2025, “On Certain Issues of Regulating the Platform Economy in the Russian Federation,” Federal Laws No. 290-FZ of July 31, 2025, and No. 295-FZ of August 4, 2026, and the Russian Government decrees adopted under them contain no requirement to present a goods declaration (DT) to the operator or to confirm that the goods were imported lawfully. The operator is, however, required to ask the partner for the 10-digit CN FEA EAEU code and/or the 9-digit OKPD2 code: the set of special checks for the listing depends on these codes.

Where customs data and the listing check overlap:

• the partner provides the CN FEA EAEU and/or OKPD2 codes, and the operator posts them in the listing together with the name of the goods, work, or services under the OKPD2 code and the name of the heading under the CN FEA EAEU code;
• based on the codes, the operator determines which special checks are needed and, if none are, may admit the listing without a special check;
• the codes in the listing are checked against the codes in the register entry for the certificate of conformity and/or declaration of conformity, if the entry states codes.

What the acts do not contain: any requirement to show the goods declaration, to confirm lawful import, or to check the listing against the goods declaration. At the same time, Law No. 289-FZ requires the contract to set out requirements for the partner, so it cannot be said that a platform has no right to request customs documents; the platforms' offer agreements were not analyzed for this article. What happens when a listing fails a check is covered in Which documents for imported goods will a marketplace check in the product listing?

Practical recommendation from Senateks (not a legal requirement): state the same CN FEA EAEU code in the goods declaration, in the permit or approval, and in the listing, and resolve any discrepancies before the listing is posted.

Find the right CN FEA EAEU code → Advice on goods classification (CN FEA codes); declare the import → Declaring goods: import, export, and transit.

How will a marketplace verify the seller and a foreign supplier?#

When entering into a contract, the operator of an intermediary digital platform verifies information about the person who intends to become a partner — against the Unified State Register of Legal Entities (EGRUL) and the Unified State Register of Individual Entrepreneurs (EGRIP), through the Unified Identification and Authentication System (ESIA), or by other methods established by the Government of the Russian Federation. The procedure is set by Russian Government Decree No. 768 of June 20, 2026: the operator chooses the verification method. The Rules contain a separate section for foreign legal entities and foreign organizations that are not legal entities. The operator may also verify a foreign legal entity that has a branch or representative office accredited in Russia in other ways — against state registers or through the identification and authentication system; a foreign person with neither is verified only under the separate section.

There are three ways to confirm that the information was submitted by the applicant itself: an electronic document signed with a qualified electronic signature (an individual paying NPD may also sign it with a non-qualified electronic signature whose certificate was created and is used within the Gosuslugi public services infrastructure); a money transfer to the operator's account, which is refunded within 6 business days or, at the applicant's choice, credited toward its future activity on the platform; and authorization through an information system. For a foreign legal entity or foreign organization, there are two methods: a money transfer (refunded within 30 calendar days or credited) and authorization. If these methods are not technically possible, or the information cannot be checked against the official resources of the country of registration that are accessible from Russia, the operator verifies the information under its own procedure published on the platform. The operator sends its decision within one business day following the day the verification is completed — stating the reasons if it refuses — and may not restrict the applicant's right to go through verification again.

Table 3. Verification of information about a prospective partner.

Verification through ESIA or another identification system takes one calendar day; so does verification of a small or medium-sized business under a separate section of the Rules. For a foreign legal entity or foreign organization without a branch in Russia, the period is set by the operator itself — no more than 15 business days. Practical takeaway from Senateks (not a legal requirement): the information you give the platform must match EGRUL or EGRIP, or the verification will not be considered passed; the INN established during verification is later used in the labeling check. With the partner's consent, the operator sends the tax authority information about the contract; about the partner; about consent to (or withdrawal of consent to) price reductions at the partner's expense and about a ban on such reductions; and about the reconciliation statement — within 2 business days of the date of consent and within 3 business days of the date the information changes.

What is not yet clear. Decree No. 768 contains no transitional provisions for contracts entered into before October 1, 2026. There is no official guidance yet on whether existing sellers must go through verification again.

What liability does a seller face for a listing without a certificate, SGR, or labeling?#

From October 1, 2026, a business entity engaged in trade, including a partner selling on an intermediary digital platform, is prohibited from publicly posting — including on such a platform — offers to sell goods withdrawn from circulation, goods without mandatory labeling, and goods without valid certificates of conformity, declarations of conformity, and/or state registration certificates. The ban is set out in Article 11¹ of Federal Law No. 381-FZ of December 28, 2009, “On the Fundamentals of State Regulation of Trade Activities in the Russian Federation,” as amended by Federal Law No. 290-FZ of July 31, 2025, and liability for breaching it in Article 14.70 of the KoAP as amended by Federal Law No. 295-FZ of August 4, 2026.

Goods a seller is prohibited from offering (Article 11¹ of Law No. 381-FZ):

• goods withdrawn from circulation;
• pesticides and agrochemicals, dietary supplements, medicinal products, and medical devices that have not undergone state registration, if registration is mandatory for them;
• goods without the labeling required by Law No. 381-FZ or by the legislation on the circulation of medicines or on precious metals and precious stones;
• goods without valid certificates of conformity, declarations of conformity, and/or state registration certificates, if the goods are subject to mandatory conformity assessment.

The provision contains no exception for a seller's own online store; there is no official guidance yet on whether it applies to a seller's own website. The fine under Part 1 of Article 14.70 of the KoAP ranges from RUB 5,000 to RUB 30,000 for officials and from RUB 30,000 to RUB 70,000 for legal entities. For a repeat offense (Part 2 of the same article), it is from RUB 10,000 to RUB 50,000 and from RUB 70,000 to RUB 200,000, respectively. Under the note to the article, foreign nationals or stateless persons who are platform partners, as well as individuals paying NPD, are liable as officials. Cases under Article 14.70 of the KoAP are heard by the federal state supervisory authority for consumer rights protection, Rospotrebnadzor. Compliance with the requirements for posting offers is assessed as part of state control (supervision) under Part 4 of Article 16 of Law No. 381-FZ as amended by Law No. 290-FZ.

Article 14.69 of the KoAP applies to the operator of an intermediary digital platform: cases under Parts 1 and 3 are heard by Rospotrebnadzor and cases under Parts 2 and 4–12 by FAS, and Part 3 (the product listing) takes effect on January 1, 2027. The consequences come at two levels: the operator does not allow the listing to be posted and stops displaying a listing that is already posted if the partner has changed the information subject to checking (until a new check is completed) or if the periodic check to keep the information up to date, or the check triggered by a register's notice of changed information, did not produce a positive result (paragraphs 4 and 15 of the Rules under Decree No. 821); the seller, in turn, may be held administratively liable.

Table 4. Who is liable for a listing without documents or labeling.

Permits and approvals for goods are obtained before an offer is posted → Certificates and declarations of conformity (TR CU / TR EAEU); state registration certificates (SGR).

What does the law change in your contract with a marketplace: discounts, fees, and notices?#

Federal Law No. 289-FZ of July 31, 2025, “On Certain Issues of Regulating the Platform Economy in the Russian Federation,” sets neither the amount of the intermediary digital platform operator's fee nor the payment deadline: it requires the contract to provide for, among other things, the procedure for determining the amount of the operator's fee, the settlement procedure (including how the payment deadline is determined), the procedure for setting discounts, and an exhaustive list of liability measures. What the law does introduce are procedures: the seller's consent to price reductions at its expense, notice periods for changes to the contract, a reconciliation statement, and equal terms of access to paid services that affect search results.

Table 5. The seller's contract with a marketplace: what the law establishes.

The general rule on discounts: the operator gives at least five business days' notice of its intention to reduce the price at the partner's expense and obtains consent in the form set by the contract. Exception: if the partner has set a minimum price, consent is deemed to have been obtained and no notice is required, but the goods may not be sold below that price. Notice of a unilateral change to the contract is sent at least forty-five days in advance if the liability measures change, the operator's fee increases, or the procedure for determining the fee or the terms of acceptance, storage, delivery, handover, dispatch, and/or return of goods change; in other cases, at least fifteen days in advance. Exceptions: if the change improves the partner's position or brings the material terms of the contract into line with the law, the operator need not observe these periods but must still notify the partner within the period provided for by the contract; Article 12 does not apply to changes to the contract made on the basis of a court decision that has entered into legal force. The operator provides the reconciliation statement within seven business days of the date of the request and updates it at least once a month. This article does not describe the offer agreements or promotion mechanics of specific platforms.

Contract with a marketplace: we will review the offer agreement, the terms of seller-funded discounts, and notices of fee changes.

What should you do if a marketplace removes your listing or restricts your seller account?#

From October 1, 2026 (for a specific platform, from the date it is entered in the register of intermediary digital platforms), the operator of an intermediary digital platform may restrict or stop the display of a product listing on three grounds: to ensure compliance with legal requirements for posting offers, to enforce a court decision that has entered into legal force or a decision of a public authority, and on grounds set out in the contract. It may restrict access to the seller account to ensure compliance with the law, on grounds set out in the contract, and where there are signs of unlawful access by third parties; contractual grounds must comply with antimonopoly law. These measures are permitted only with a reasoned notice in electronic form specifying the provisions of the contract and/or the law that were breached, sent no later than three days in advance; the notice is sent on the day the measures are applied if they are taken to ensure compliance with the law, to enforce a decision of a court or public authority, or to stop unlawful access.

A generalized example based on the text of the law: a listing is removed to ensure compliance with legal requirements because it lacks a link to the register entry for the permit or approval. If access to the account is restricted to ensure compliance with the law or on contractual grounds, the operator must keep access open to the sections containing the contract and the reconciliation statement and to the section for filing a complaint. The operator must lift the measures within 48 hours of learning that the circumstances have been remedied. If the partner has not remedied the circumstances within ninety days of the day it learned of the restriction, the operator may delete the account. Before going to court, the seller must file a complaint through the pre-trial complaint handling (dispute resolution) system: electronically, with documents indicating that the operator's actions were unjustified. A reply is due no later than fifteen days after the date of filing; if the complaint is found to be justified, the measures are lifted within 48 hours. The pre-trial procedure does not apply if the measure was taken to enforce a decision of a court or public authority.

Steps to take when a listing is removed or an account is restricted:

1. Obtain a reasoned notice specifying the provisions of the contract and/or the law that were breached.
2. Remedy the cause, or gather documents showing that the operator's actions were unjustified.
3. File a complaint through the platform's pre-trial complaint handling (dispute resolution) system.
4. If necessary, apply to the supervisory authority or go to court.

What Senateks recommends attaching to a complaint about a listing (the law does not specify what the complaint must include): links to the register entries for certificates of conformity, declarations of conformity, and state registration certificates; confirmation of registration in the labeling system; and the justification for the CN FEA EAEU code.

State control (supervision) in the platform economy is exercised by FAS; its scope covers Articles 5, 6, 9–14, 16, and 17 of Law No. 289-FZ, which includes, among other things, restrictions on listings and pre-trial complaints. Scheduled control (supervisory) activities are not carried out; the grounds for unscheduled ones are listed in the Regulation approved by Decree No. 820 and include information about harm caused, a prosecutor's demand, and a match with risk indicators. The list of risk indicators is approved by FAS; it has not been approved yet. The requirements for product listings (Article 7 of Law No. 289-FZ) fall outside the scope of FAS control: they are supervised by Rospotrebnadzor. The pre-trial appeal procedure in the Regulation is addressed to controlled persons, that is, those whose obligations FAS checks, not to sellers filing complaints. The Russian Government has not yet set additional requirements for the pre-trial complaint handling system. The outcome of a complaint or dispute is not predetermined.

Dispute with a marketplace: a removed listing, a restricted account, a complaint to FAS — we will review your situation. If the cause is a missing or invalid permit or approval → Certificates and declarations of conformity (TR CU / TR EAEU); state registration certificates (SGR).

What should an importer check before and after October 1, 2026?#

This checklist contains practical recommendations from Senateks, not a list of legal obligations; most items cite the provision they are based on.

Before posting or updating a listing:

• use the CN FEA EAEU and OKPD2 codes to determine whether special checks are needed (Rules under Decree No. 821, para. 6);
• find the entries for certificates, declarations of conformity, and SGRs; check the SGR number and date of issue, the “valid” status, and, for certificates and declarations, that the OKPD2 and CN FEA EAEU codes match the register (Rules under Decree No. 821, paras. 26, 29, 32); check the manufacturer and the validity period of the certificate or declaration in advance, since the operator will carry them over from the register into the listing (Rules under Decree No. 821, para. 33);
• for documents from another EAEU state, check on the website of the national accreditation body that they have not been suspended or terminated (Rules under Decree No. 821, para. 32);
• check that the CN FEA EAEU and OKPD2 codes match across the DT, the permits and approvals, and the listing (recommendation);
• for goods subject to labeling, check that the seller is registered in the labeling system under its INN, and check the National Catalog code (Rules under Decree No. 821, para. 35);
• check the EGRUL or EGRIP information against the platform account and prepare an electronic signature (Rules under Decree No. 768, paras. 15, 16, 20);
• for a foreign partner, prepare the registration number and INN, or their equivalents under the law of the country of registration (Rules under Decree No. 768, para. 11);
• choose a discount setting: consent, a minimum price, or a full ban (Law No. 289-FZ, Art. 9, Pts. 1–4);
• put together a set of documents for a possible complaint: links to register entries and confirmation of registration in the labeling system (Law No. 289-FZ, Art. 14, Pt. 2).

After October 1, 2026, monitor:

• the register of intermediary digital platforms on the website of the Russian Ministry of Economic Development, which is to be posted by November 2, 2026 (Decree No. 504, para. 3);
• the platform's notices of changes to the contract and new versions of the offer agreement (Law No. 289-FZ, Art. 12; Art. 5, Pt. 5);
• the format of information for the tax authorities (Rules under Decree No. 766, para. 5) and the FAS list of risk indicators (Regulation under Decree No. 820, para. 23), neither of which exists yet;
• the agencies' technical requirements for interaction with state systems: paragraph 3 of Decree No. 821 required the Ministry of Health, the Ministry of Agriculture, Roszdravnadzor (Federal Service for Surveillance in Healthcare), Rosaccreditation (Federal Service for Accreditation), and the Ministry of Finance (jointly with the Federal Assay Chamber) to post them by September 1, 2026; Rosaccreditation, the Ministry of Health, and Roszdravnadzor have posted their requirements, while those of the Ministry of Agriculture and the Ministry of Finance (jointly with the Federal Assay Chamber) should be monitored on their official websites;
• the Russian Government act on requirements for displaying information on the price of goods in the listing (Law No. 289-FZ, Art. 7, Pt. 5), which has not been issued yet; other requirements for the product listing and its posting are partly set by the Rules under Decree No. 821 themselves (para. 1 of the Rules; for example, Section IX on trademarks);
• future dates: Part 3 of Article 14.69 of the KoAP applies from January 1, 2027; Section IX of the Rules under Decree No. 821 on trademarks applies from March 1, 2027 — have the number and date of the entry in the State Register of Trademarks ready for it.

This checklist does not guarantee that a listing will pass the platform's check; the terms of offer agreements were not analyzed. After October 1, 2026, a follow-up article will be published: “What changed on October 1, 2026, and what to do.”

Senateks services related to this article:

• Import and declaration of goods
• Certificates and declarations of conformity (TR CU / TR EAEU), SGR
• Advice on goods classification (CN FEA codes)
• Delivery from the border to marketplace warehouses

Frequently asked questions#

Sources#

• Federal Law No. 289-FZ of July 31, 2025 — http://publication.pravo.gov.ru/document/0001202507310020 (in Russian; accessed September 18, 2026)
• Federal Law No. 290-FZ of July 31, 2025 — http://publication.pravo.gov.ru/document/0001202507310021 (in Russian; accessed September 18, 2026)
• Federal Law No. 295-FZ of August 4, 2026 — http://publication.pravo.gov.ru/document/0001202608040039 (in Russian; accessed September 18, 2026)
• Russian Government Decree No. 54 of January 28, 2026 — http://publication.pravo.gov.ru/document/0001202601290037 (in Russian; accessed September 18, 2026)
• Russian Government Decree No. 504 of April 30, 2026 — http://publication.pravo.gov.ru/document/0001202605060021 (in Russian; accessed September 18, 2026)
• Russian Government Decree No. 514 of May 6, 2026 — http://publication.pravo.gov.ru/document/0001202605060025 (in Russian; accessed September 18, 2026)
• Russian Government Decree No. 766 of June 20, 2026 — http://publication.pravo.gov.ru/document/0001202606260092 (in Russian; accessed September 18, 2026)
• Russian Government Decree No. 768 of June 20, 2026 — http://publication.pravo.gov.ru/document/0001202606260095 (in Russian; accessed September 18, 2026)
• Russian Government Decree No. 820 of July 2, 2026 — http://publication.pravo.gov.ru/document/0001202607020016 (in Russian; accessed September 18, 2026)
• Russian Government Decree No. 821 of July 2, 2026 — http://publication.pravo.gov.ru/document/0001202607020011 (in Russian; accessed September 18, 2026)
• Federal Law No. 289-FZ of July 31, 2025, in the “Legislation of Russia” database — http://pravo.gov.ru/proxy/ips/?docbody=&nd=607604930 (in Russian; accessed September 18, 2026)
• Federal Law No. 184-FZ of December 27, 2002, “On Technical Regulation,” in the “Legislation of Russia” database — http://pravo.gov.ru/proxy/ips/?docbody=&nd=102079587 (in Russian; accessed September 18, 2026)
• Law of the Russian Federation No. 2300-I of February 7, 1992, “On Consumer Rights Protection,” in the “Legislation of Russia” database — http://pravo.gov.ru/proxy/ips/?docbody=&nd=102014512 (in Russian; accessed September 18, 2026)
• Federal Law No. 381-FZ of December 28, 2009, “On the Fundamentals of State Regulation of Trade Activities in the Russian Federation,” in the “Legislation of Russia” database — http://pravo.gov.ru/proxy/ips/?docbody=&nd=102135141 (in Russian; accessed September 18, 2026)
• Rosaccreditation. Technical requirements for providing information from state information systems (registers) for verifying product listings — https://fsa.gov.ru/documents/26793/ (in Russian; accessed September 18, 2026)
• Ministry of Health of Russia. Description of technical requirements for interaction between the information system of an intermediary digital platform and a state information system (register) — https://minzdrav.gov.ru/documents/9892-opisanie-tehnicheskih-trebovaniy-k-vzaimodeystviyu-informatsionnoy-sistemy-posrednicheskoy-tsifrovoy-platformy-s-gosudarstvennoy-informatsionnoy-sistemoy-reestrom (in Russian; accessed September 24, 2026)
• Roszdravnadzor. Technical requirements for interaction between the information system of an intermediary digital platform (marketplace) and a state information system (AIS Roszdravnadzor) — https://roszdravnadzor.gov.ru/opendata/documents/90704 (in Russian; accessed September 24, 2026)

This article is based on the texts of regulatory legal acts and does not constitute legal advice.