Federal Law No. 289-FZ of 31 July 2025 “On Certain Issues of Regulating the Platform Economy in the Russian Federation” will take effect on 1 October 2026. Along with it, four Government resolutions will take effect, including the procedure for checking partners and order pickup point owners. Operators of intermediary digital platforms included in the register will be required, when concluding a contract, to check information about such persons — against a closed list of data and within timeframes that depend on the verification method the operator chooses. We break down who the new rules will affect, exactly what will be checked, and what needs to be ready before 1 October.
What the Law Is and What Exactly Takes Effect on 1 October 2026
The Platform Economy Law — Federal Law No. 289-FZ of 31 July 2025 “On Certain Issues of Regulating the Platform Economy in the Russian Federation” — establishes the legal basis for the platform economy and governs relations between operators of intermediary digital platforms, their partners, users, and other persons in connection with the sale of goods, performance of work, and provision of services (Article 1(1)). The law will take effect in full, with no breakdown by article, on 1 October 2026 (Article 23(1)). Regulatory acts adopted to implement it and establishing mandatory requirements take effect within the timeframes they specify, but no earlier than 90 days after official publication (Article 23(2)).
Four Government resolutions are timed to take effect by 1 October 2026, and we’ll cover all of them below:
- No. 54 of 28 January 2026 — additional criteria under which a platform is recognized as an intermediary and included in the register
- No. 504 of 30 April 2026 — rules for compiling and maintaining the register itself
- No. 768 of 20 June 2026 — the procedure for checking partners and order pickup point owners
- No. 821 of 2 July 2026 — the procedure for checking information in listings for goods, work, and services
Resolution No. 821 has its own separate timeline: it will take effect in full on 1 October 2026, but paragraph 3 — instructing agencies to publish technical requirements for interacting with state information systems — has already been in effect since 1 August 2026, while Section IX of its Rules, on confirming trademark rights in a product listing, won’t take effect until 1 March 2027.
Which Platforms Are Affected: The Register and the Criteria
Why the Requirements Don’t Apply to Every Marketplace
This is the most common distortion on the topic: the requirements of Article 5 of 289-FZ don’t apply to just any platform where goods are sold or services ordered — only to operators of platforms included in the register of intermediary digital platforms.
The law defines an intermediary digital platform as a platform that enables interaction between the operator, partners, and users, provides the technical means to place orders and listings, conclude transactions, and pay for goods in favor of a partner, meets the Government’s additional criteria, and is included in the register of intermediary digital platforms (Article 2(9)). A platform is recognized as an intermediary platform only from the moment it’s included in the register (Article 4(2)).
The requirements of Article 5 of 289-FZ don’t apply to every marketplace — only to operators of platforms included in the register of intermediary digital platforms. A platform that formally fits the definition in Article 2(9) but hasn’t been included in the register carries no obligations under Article 5 — it becomes an intermediary digital platform only from the moment it’s included in the register (Article 4(2)).
The Criteria for Inclusion in the Register
The additional criteria were approved by Government Resolution No. 54. For a platform whose owner or operator is a Russian legal entity or individual entrepreneur (IP), the following must be met simultaneously:
- the average daily number of internet users in Russia visiting the platform — at least 100,000 people over the preceding calendar year
- and at least one of the following two: at least 10,000 persons who completed at least one paid transaction through the platform over the preceding calendar year, or a total value of such transactions of at least ₽50 billion over the preceding calendar year
Both figures are determined from cash register equipment (KKT) data. For a platform with a foreign owner or operator, the criterion is simpler: it’s enough to meet the definition in Article 2(9) and the audience criterion — the same 100,000 users per day.
Who’s Already on the Ministry of Economic Development’s Preliminary List
The register is maintained by an authorized federal executive body, and the rules for compiling and maintaining it were approved by Resolution No. 504, which will also take effect on 1 October 2026. According to the Ministry of Economic Development (Minekonomrazvitiya), the register will be published on the ministry’s website by 2 November 2026. The preliminary list the ministry announced includes 12 platforms: Avito, Delivery Club, Joom, Lamoda, Ozon, Wildberries, Kuper, Magnit Market, Yandex Go, Yandex Eda, Yandex Market, and Yandex Travel. This is the Ministry of Economic Development’s preliminary list, not the register itself, and its composition may change by 1 October 2026.
Who Are Partners, Operators, and Order Pickup Point Owners
The law distinguishes between several roles.
An operator of an intermediary digital platform (Article 2(8)) is a legal entity, a foreign legal entity, a foreign organization without legal-entity status, an individual entrepreneur (IP), a foreign citizen, or a stateless person that provides services organizing interaction between partners and users and is either the platform’s owner or a person with whom the owner has concluded an operating agreement.
A partner (Article 2(4)) is a legal entity, a foreign legal entity, a foreign organization without legal-entity status, an individual entrepreneur (IP), or a natural person paying professional income tax (NPD) who is a seller partner and/or a service partner. A seller partner (Article 2(5)) sells goods to buyer-users; a service partner (Article 2(6)) performs work or provides services for customer-users — the law does not explicitly call a service partner a “seller.”
The owner of an order receiving and pickup point (a “PVZ owner,” Article 2(11)) is a separate role: only a legal entity or an individual entrepreneur (IP) that has concluded a contract with the operator can hold it.
Why “Marketplace Seller” Isn’t the Same as “Partner”
“Marketplace seller” is an everyday simplification. The law covers more than just the sale of goods: service partners performing work or providing services, and PVZ owners, also fall under Article 5. Wherever a rule applies to all of these categories, this article uses the word “partner”; “seller” is used only where the discussion specifically concerns a seller partner.
Who the Operator Must Check, and When
The law specifies precisely the moment the obligation to check arises.
“When concluding a contract with a partner or an order pickup point owner, the operator shall verify information about the person intending to become a partner or an order pickup point owner…” (Article 5(2) of 289-FZ)
Two more provisions add to this: the operator is required to provide the ability to conclude a contract electronically on the platform (Article 5(1)), and access to the platform’s technical capabilities and the personal account is granted on the basis of a contract (Article 6(1)).
289-FZ and the verification Rules don’t impose an obligation to re-check partners and PVZ owners who already have an existing contract — there’s also no periodic re-certification or repeat check when a partner’s information changes. Changes can still reach such partners: if the platform offers to re-conclude the contract under the new rules, the check will become part of that procedure.
What Information Is Checked: Legal Entities, Sole Proprietors, the Self-Employed, and Foreign Companies
The list of information checked is closed and is set out in paragraphs 7–11 of the Rules under Resolution No. 768.
| Applicant category | Information checked |
|---|---|
| A legal entity registered under Russian law | Full and abbreviated (if any) names; address within its place of location; tax ID (INN); primary state registration number (OGRN); tax registration reason code (KPP) |
| An individual entrepreneur (IP) registered under Russian law | Full name, including patronymic if any; primary state registration number for sole proprietors (OGRNIP); tax ID (INN) |
| A foreign legal entity with a branch or representative office accredited in Russia | Full and abbreviated (if any) names; address (location) within Russia; tax ID (INN); tax registration reason code (KPP) |
| A natural person paying professional income tax (NPD) | Full name (if any); tax ID (INN); confirmation of NPD payer status |
| A foreign legal entity or a foreign organization without legal-entity status | Full and abbreviated (if any) names; the organization’s registration number or its equivalent under the law of the country of registration (if any); tax ID or its equivalent (if any) |
The list includes no certificates, no declarations of conformity, no marking codes, and no licenses — that information belongs to a different procedure, covered further below. There’s also no separate list for the order pickup point owner: since under Article 2(11) only a legal entity or an IP can hold that role, it’s checked against the list for that category.
“Natural person” in the Rules doesn’t mean just anyone — it means someone self-employed (samozanyatyy) and paying NPD: this follows from Article 2(4), Article 15 of 289-FZ, and paragraph 10 of the Rules, where a natural person is defined, in the context of the check, as an applicant paying professional income tax.
How the Check Works: Four Methods and Their Timeframes
The operator is required to carry out the check using one of the methods provided for in the Rules, and the operator — not the applicant — decides which method to use (paragraph 2 of the Rules). In general, the procedure looks like this:
The four verification methods provided for in the Rules differ in who they apply to, their timeframes, and the systems used.
| Method | Who it applies to | Timeframe | Provision |
|---|---|---|---|
| State registries and the Federal Tax Service (FNS) service | Russian legal entities, IPs, natural persons paying NPD, foreign legal entities with an accredited branch or representative office | No more than 5 business days from the date the information is received or the date funds are transferred | paragraphs 12, 13, and 15 of the Rules |
| the Unified Identification and Authentication System (ESIA) and other identification systems | Russian legal entities, IPs, natural persons, foreign legal entities with an accredited branch or representative office | 1 calendar day from the date the information is received | paragraphs 22–24 of the Rules |
| The SME Digital Platform | Russian legal entities and IPs that are SMEs, as well as persons treated as equivalent to them | 1 calendar day from the date the information is received | paragraphs 27–29 of the Rules |
| Resources of the country of registration (for foreign applicants) | Foreign legal entities and organizations without legal-entity status | No more than 15 business days; the timeframe is published on the platform | paragraphs 31, 32, and 39 of the Rules |
Checking Against State Registries and the FNS Service
This method uses the Unified State Register of Legal Entities (EGRUL), the Unified State Register of Individual Entrepreneurs (EGRIP), the state register of accredited branches and representative offices of foreign legal entities, and the FNS’s public “Check Professional Income Tax Payer Status” service. The Rules phrase it as a method that “may be applied” — that is, one option among several the operator can choose, not the only possible one.
Checking Through ESIA and Other Identification Systems
Here the operator uses the federal state information system ESIA or another information system or program that meets the requirements of the legislation on information, information technology, and the protection of information. Information is submitted to the operator under this method only with the applicant’s consent (paragraph 25 of the Rules). This is the only method where the law literally names identification and authentication as the method itself, which is why public discussions sometimes call the entire 289-FZ check “seller identification” — even though, in the text of the law, the procedure is called a check of information, and identification and authentication are just one of the methods for carrying it out. For more on how customer identification works in other verification processes, see the article “How Customer Identification Works”.
Checking Through the SME Digital Platform
This method is available to legal entities and IPs that are small and medium-sized businesses (SMEs), as well as persons treated as equivalent to them. It uses a digital platform with a mechanism for targeted matching and remote access to support measures for SMEs and the self-employed, provided the applicant is authenticated on it through ESIA and their profile has been created under Government Resolution No. 2371. The check is considered passed as soon as the applicant’s information is submitted to the operator — the Rules set no additional conditions, making this the simplest of the four methods.
Checking Foreign Companies
For foreign legal entities and organizations without legal-entity status, this is the only method provided for, and the Rules phrase it not as “may be applied” but as “applies.” It uses information resources of the applicant’s country of registration that contain official information and are accessible from Russian territory. The operator itself sets the timeframe, but it may not exceed 15 business days from the date the information is received, and this timeframe must be published on the platform. The operator is additionally required to request information about the country of registration from such an applicant.
How It’s Confirmed That the Applicant Themselves Submitted the Information
The check under the first and fourth methods consists of two stages: confirming that the information was submitted on behalf of this specific applicant, and verifying that the information matches the data in the registries or the resources of the country of registration.
For a check against state registries, the Rules provide for three ways to confirm the fact that the information was submitted (paragraph 16):
- an electronic document bearing the enhanced qualified electronic signature (UKEP) of the legal entity, the foreign legal entity with an accredited branch, the IP, the natural person, or their authorized representatives — a natural person may sign the document with an enhanced unqualified signature (UNEP) if its certificate was issued and is used within the ESIA infrastructure under the procedure established by Resolution No. 2152
- transferring funds to a bank account specified by the operator — to determine the applicant’s tax ID (INN), and for an IP or a natural person, their full name as well; the funds must be returned within 6 business days, or, at the applicant’s choice, may be used by them in further work on the platform; the tax ID and full name are established in accordance with the identification requirements under anti-money-laundering legislation — that is, under 115-FZ, not under the rules of any commercial service
- authorization on the platform through an information system that meets the requirements of Federal Law No. 149-FZ, by a person entitled to act on the applicant’s behalf without a power of attorney
For foreign applicants, there are two ways to confirm (paragraph 35): transferring funds, to be returned within 30 calendar days or used at the applicant’s choice, and authorization through the information system that submitted the information. If the applicant’s country of registration is on the list of states whose financial organizations Russian financial organizations are entitled to delegate identification to under Article 7(1)(5–11) of 115-FZ, the information is established in accordance with the identification requirements.
If the operator has no technical means to confirm that the information was submitted or to verify that it matches the resources of the country of registration, it carries out the check under a procedure that it defines itself and publishes on the platform (paragraphs 41–42) — this is the only place in the Rules where the operator is given its own procedure to define. For what the identification requirements under anti-money-laundering legislation mean and who they apply to, see the article “AML/CFT in Simple Terms.”
What Happens If the Information Doesn’t Pass the Check
Based on the check, the operator makes one of two decisions (paragraph 3 of the Rules): that the check has been passed, if the applicant submitted complete and accurate information, or that it hasn’t been passed, if the information is incomplete and/or its accuracy hasn’t been confirmed, in which case the reasons must be stated.
A decision that the check has been passed is sent no later than the next business day after the check is completed: by posting it on the platform, by email to the applicant, or by another method the applicant chose, subject to the operator’s capabilities (paragraph 4). A decision that the check hasn’t been passed is sent within the same timeframe, but as an electronic document signed by the operator or a person it authorizes with an enhanced qualified electronic signature (paragraph 5).
The main consequence for the applicant: if the decision is that the check hasn’t been passed, the operator may not restrict the applicant from going through it again (paragraph 6). Neither 289-FZ nor the Rules state in so many words that the operator may not conclude a contract with a person who hasn’t passed the check — there’s no direct prohibition of that kind in them. The structure is different: the operator is required to carry out the check when concluding a contract and to make one of the two decisions based on its outcome, while access to the platform is granted on the basis of a contract. The practical takeaway for a partner: a rejection decision bearing a qualified signature and stated reasons is a document that can be relied on when reapplying or in a dispute.
Checking a Partner vs. Checking a Product Listing: Different Procedures
Besides checking partners, 289-FZ introduces a separate procedure — checking the information in a listing for a product, work, or service (Article 7). These are different provisions, different subordinate regulations, and different timeframes.
| What’s being compared | Checking partner information | Checking product listing information |
|---|---|---|
| Legal provision | Article 5 of 289-FZ | Article 7 of 289-FZ |
| Subordinate regulation | Government Resolution No. 768 of 20 June 2026 | Government Resolution No. 821 of 2 July 2026 |
| When it happens | When concluding the contract | When the listing is posted and when changes are made to it |
| What’s checked | Registration information about the applicant — name, address, tax ID, OGRN/OGRNIP, KPP, NPD payer status | Information about the product: permits and licenses, confirmation of conformity, marking, state registration of the product, the partner’s registration in the marking system |
| Transition rule | None | Yes: information in listings posted before 1 October 2026 will be checked within 180 days of the date Resolution No. 821 takes effect |
| Deferred provision | None | Yes: Section IX of the Rules (confirming trademark rights) takes effect on 1 March 2027 |
Checking a partner under Article 5 and checking product listing information under Article 7 are different procedures, with different subordinate regulations and timeframes. The 180-day transition period will apply only to information in product listings posted before 1 October 2026 (Resolution No. 821, paragraph 2), and will not extend to checking partners when a contract is concluded.
It’s worth separately keeping in mind one more date from Resolution No. 821: the Ministry of Health, the Ministry of Agriculture, Roszdravnadzor (the Federal Service for Healthcare Supervision), Rosakkreditatsiya (the Federal Accreditation Service), and the Ministry of Finance, together with the Federal Assay Chamber, have been instructed to publish, in open access, the technical requirements for the platform’s information system to interact with the corresponding state information system by 1 September 2026 — this provision of the resolution has been in effect since 1 August 2026.
The practical takeaway for a seller: passing the check when connecting to the platform says nothing about whether a specific product will be allowed for sale. A company’s registration details and the permitting documents for its product range need to be prepared in parallel, not one after the other.
What Needs to Be Ready by 1 October 2026: For the Platform and for the Seller
For the Platform Operator
- determine whether the platform meets the criteria of Resolution No. 54, and track the appearance of the register
- choose and formalize one of the four verification methods — a management decision that directly affects onboarding time: one calendar day versus five business days
- provide the ability to conclude a contract electronically on the platform (Article 5(1))
- enable receiving information from applicants electronically and communicate the procedure for submitting it in a way that allows confirmation of receipt (paragraph 14 of the Rules)
- set up verification of the electronic signature — its validity, whether it belongs to the signer, and the scope of authority, including handling a natural person’s UNEP issued within the ESIA infrastructure
- if the fund-transfer method is chosen — set up accepting the micropayment, cross-checking the tax ID and full name against the AML/CFT identification requirements, and returning the funds within 6 business days or 30 calendar days
- ensure that a decision of non-passage is issued as an electronic document bearing a UKEP, and that repeat checks are available without restriction
- for foreign applicants — determine and publish on the platform a verification timeframe within 15 business days, and a fallback procedure for when the primary method is technically unavailable
- rebuild the contract with partners and PVZ owners to include the mandatory set of terms under Article 5(4), and ensure that both current and expired contracts are retained for at least three years (Article 5(5))
Part of this preparatory work — for example, receiving and cross-checking documents — lends itself to automation; the general principles of that kind of automation are covered in the article “KYC Automation: How AI Reduces the Share of Manual Review”.
For the Partner or PVZ Owner
- a current extract from EGRUL or EGRIP, and registration details cross-checked against it — name, address, tax ID, OGRN or OGRNIP, KPP
- for the self-employed (samozanyatyy) — active NPD status, which the platform will check through the FNS’s public service
- an electronic signature of the required type, if the platform chooses the UKEP-based method; for a natural person, a UNEP issued within the ESIA infrastructure is also an option
- a verified account, if the platform chooses the ESIA-based method
- for an SME — a user profile created under Resolution No. 2371, if the platform chooses this method
- for a foreign person — information about the country of registration, and readiness for a timeframe of up to 15 business days
- separately and in parallel — permitting documents for the product range, since checking the product listing is a different procedure
Where KYC and KYB Are Useful, and Where They Don’t Replace the Statutory Check
The Rules under Resolution No. 768 set a closed set of verification methods: state registries and the FNS service, ESIA or another information system, the SME support digital platform, and official resources of the country of registration for foreign applicants. A commercial KYC or KYB service is not among the methods provided for — the operator is required to carry out the check using one of the methods the Rules explicitly specify.
This check answers a narrow question: does the applicant exist, and do their registration details match the registry data? It doesn’t answer the questions a platform still has to resolve during onboarding: who stands behind the company, whether the applicant or persons connected to it appear on sanctions or politically exposed person (PEP) lists, whether someone is acting as a front for the legal entity, or whether an uploaded document has been forged. The law doesn’t regulate these tasks, and this is where commercial KYC and KYB solutions apply — as an additional layer on top of the mandatory check, not instead of it.
According to its product page, the NeuroVision KYB platform can search for a company in state and international registries, build the ownership chain, and identify ultimate beneficial owners, run sanctions and PEP screening, and maintain ongoing monitoring of changes, with the system handing a case to a specialist for manual review whenever it isn’t confident. NeuroVision’s KYC solutions cover a similar task for natural persons — a partner’s representatives. For more on building this kind of check for B2B customers, see the article “AML, KYB, and Beneficiary Verification”.
The formula is simple: the check under 289-FZ answers the question “does this person exist, and are its registration details accurate?”; KYC and KYB answer the question “is this person worth working with?” The first is mandatory and strictly defined by the Rules; the second is the platform’s own decision about its risk appetite.
Common Mistakes When Preparing
- assuming the requirements apply to any marketplace without checking the criteria in Resolution No. 54
- conflating the partner check with the product listing check and applying the 180-day period to partners
- assuming the applicant chooses the verification method, when under the Rules it’s the operator who decides
- requesting information from the applicant beyond the closed list and calling it a check under the Rules
- sending a decision of non-passage as a plain letter instead of an electronic document with a UKEP
- failing to state the reasons for non-passage that the Rules explicitly require
- technically or organizationally restricting a repeat attempt to pass the check
- failing to publish the verification timeframe for foreign applicants and the fallback procedure on the platform
- failing to provide for returning the micropayment within the established timeframe
- assuming that connecting a commercial KYC or KYB service on its own satisfies the law’s requirements
The Platform Economy Law, together with four Government resolutions, will take effect on 1 October 2026, but the obligation to check partners will fall not on any marketplace, but only on operators of platforms included in the register of intermediary digital platforms. The check will be tied to concluding a contract rather than to periodic re-certification, and it will be the operator — not the partner or seller themselves — who chooses the verification method. The Rules set a closed list of information to be checked and four verification methods with different timeframes — from one calendar day to fifteen business days. Separately from this, a product-listing check with its own timeframes and transition period will apply, and it’s important not to confuse it with checking a partner. The law won’t eliminate the related onboarding tasks — sanctions screening, beneficial-owner checks, and the fight against forged documents. Platforms will continue to handle these on their own, using commercial KYC and KYB solutions where needed, applied on top of the mandatory check rather than instead of it.
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