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Strengthening control over the activities of payment agents

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Pepeliaev Group advises that on 1 October 2023 amendmentsFederal Law No. 298-FZ “On amending the Federal Law “On the activities of accepting payments of individuals carried out by payment agents” and certain items of the legislation of the Russian Federation” dated 10 July 2023.
 to Federal Law No. 103-FZ “On activities carried out by payment agents involving the receipt of payment from individuals” came into forceFederal Law No. 103-FZ “On activities carried out by payment agents involving the receipt of payment from individuals” dated 3 June 2009.

The purpose of the adoption of the law is to control the activities of payment agents, including in socially significant segments of payment services. According to the authors who developed the draft law, increasing the transparency of the payment acceptance market and monitoring the activities of its participants are necessary measures to stabilise the payment services marketExplanatory note to draft law No. 46071-8.

What does it mean?

In the legal field, the activities of payment acceptance operators (payment agents) will be subject to regulation and supervision by the Bank of Russia: in order to become a payment acceptance operator, a legal entity will be required to send an application to the Bank of Russia in the prescribed form for information about that entity to be entered in the appropriate register. It will also have to meet a number of requirements for its corporate structure and management bodies. The application form and the procedure for its submission for inclusion in the relevant register should be determined by the Bank of Russia in the near futureIn accordance with the plan for drafting of the Bank of Russia’s regulations, the adoption of relevant regulation is planned for Q4 of 2023: https://www.cbr.ru/project_na/.

Legal entities that are carrying out the activities of payment agents as at 1 October 2023 have the right to continue carrying out such activities without being included in the register until 1 October 2024. Other persons who want to become payment acceptance operators have the right to do so only after the Bank of Russia has included information about them in the relevant register.


A self-regulating organisation is being created for payment acceptance operators. A payment agent is obliged to join a self-regulating organisation within 90 days after the Bank of Russia enters information about it in the register. It is assumed that such an organisation will monitor the activities of its members. The Bank of Russia will also monitor the activities of payment acceptance operators.

As part of its supervision activities, the Bank of Russia will monitor whether payment agents comply with both the requirements of Law No. 103-FZFederal Law No. 103-FZ “On activities carried out by payment agents involving the receipt of payment from individuals” dated 3 June 2009 and the regulations of the Bank of Russia issued within its powers.


In general, the legislature’s tendency to strengthen control over the payment segment of the financial market owes to the growing demand for increased transparency of payment services, which was noted by the regulator back in 2020The Central Bank supported the strengthening of control over payment agents.
. The adopted amendments to some extent put the status of payment agents on an equal footing with bank payment agents in terms of maintaining registers, requirements for accepting payments, restrictions on collecting funds from special bank accounts and monitoring their activities.

The amendments introduced extend to payment agents some of the approaches traditionally applied to non-credit financial institutions in terms of requirements for their ownership structure and management bodies.

What to think about and what to do

The transition period is in force until 1 October 2024. Certain provisions relating to control over activities will take effect at a later date.

Current payment acceptance operators need to make sure before the specified date that the structure of their management bodies and the composition of members or shareholders comply with the requirements of the law, while particular officers meet the qualification requirements. Compliance with these and other established requirements will allow a payment agent to carry out (continue) its activities having registered in the relevant registry.

Help from your adviser

Pepeliaev Group’s lawyers have vast experience in advising on matters relating to the application of legislation on activities of payment agents, and on combating the legalisation (laundering) of the proceeds of crime and the financing of terrorism.

We are ready to provide comprehensive legal support to participants of the payment services market with respect to issues of organising internal procedures in compliance with the law requirements, amending internal compliance policies, and to provide legal assistance with regard to inclusion in the register of payment acceptance operators. 

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