The Government of the Russian Federation has approved the criteria for classifying digital platforms as intermediary platforms under Federal Law No. 289-FZ of July 31, 2025, “On Certain Issues of Regulating the Platform Economy in the Russian Federation,” which enters into force on October 1, 2026.

The unified register will include platforms that meet both of the following criteria:

an average daily audience of at least 100,000 unique users;

either an annual transaction volume of at least 50 billion rubles or a partner base of no fewer than 10,000 entities.

Foreign platforms may be included in the register based solely on the audience criterion; however, once included, they are required to establish a representative office in Russia (“localization” or onshoring requirement).

The decision on inclusion will be made by the Ministry of Economic Development based on data provided by the Federal Antimonopoly Service (FAS), the Federal Tax Service (FTS), and Mediascope. A platform may also submit a self-application, in which case it is sufficient to verify its user audience metrics.

According to the draft Government Resolution, the register must be finalized by November 2, 2026. Inclusion in the register grants a platform the legal right to engage with self-employed persons. Platforms not listed in the register will be prohibited from contracting with self-employed workers outside of formal employment arrangements.

Registered platforms will also be obliged to:

verify the status of partners through ESIA (Unified System of Identification and Authentication) or official state registries;

notify users of any changes in cooperation terms;

ensure direct communication between buyers and sellers;

implement pre-trial dispute resolution procedures;

and refrain from distorting product ranking algorithms.

Commentary by Danil Sadovsky, Junior Associate, IP/IT practice BBNP:

“For large Russian and international platforms, inclusion in the register will become a mandatory step to preserve the existing business model involving self-employed workers. This will require adapting internal compliance and operational frameworks—from vendor verification processes to the technical implementation of transparent algorithms and pre-litigation dispute-resolution mechanisms. For foreign market participants, the key challenge will be the localization requirement—the obligation to establish a physical presence in Russia through a representative office. At the same time, the turnover threshold of 50 billion rubles may leave outside the regulation several important service-oriented platforms (for example, in education or home-repair sectors), which indicates the need for further refinement of the approach to account for industry-specific factors.”

Source: Draft Government Resolution “On the Procedure for Forming and Maintaining the Register of Intermediary Digital Platforms”; RBC news outlet.