Restrictions on market research in Russia

Please note that significant restrictions on market research for foreign organisations and their Russian subsidiaries will come into effect on 1 March 2026.

The government has adopted relevant amendments* to the Federal Law “On the Fundamentals of State Regulation of Trade in the Russian Federation”.

The law prohibits:

• conducting market research in Russia by foreign companies and by Russian companies with more than 20% foreign shareholding, which effectively covers all subsidiaries of foreign entities.

• foreign companies establishing control over “organisers of market research”. The law defines these organisers as entities for which “market research” is the primary type of activity.

Organisers of market research must confirm their compliance with the new requirements by 15 May 2026.

Violation of these restrictions may result in specific liability: alienation of the foreign share to reduce the level of foreign participation to the permitted 20% or less. Any transactions concluded in violation of the law will be deemed void.

Exceptions

The law provides for certain exceptions. In particular, the restrictions do not apply if a company conducts market research for its own or intra-group purposes, and its results are not disclosed to third parties.

Another exception is related to the annual total revenue of the group to which the company belongs. The prohibitions do not apply if the group’s total revenue does not exceed RUB 800m (EUR 8.7m) per calendar year.

Comments

Although the new restrictions apparently will not affect research conducted for intra-group purposes, it is recommended to assess whether they could impact the activities of Russian representative offices and subsidiaries of foreign companies and organisations. Considering preventive measures to mitigate potential risks is also recommended.

Such assessment is particularly recommended for entities whose primary activity in the Unified State Register of Legal Entities (EGRUL) is listed as “market research” (OKVED codes 73.20 and 73.20.1).

*In Russian