Restrictions and measures of state support for business: the digest for 8-21 December 2025

DRAFT LAWS

Control over a cross-border transfer of personal data will be enhanced

Draft federal law No. 951518-8

Has been passed by the State Duma in the first reading.

Amendments have been drafted to article 12 of Federal Law No. 152-FZ “On personal data” dated 27 July 2006.

Prior to filing a notification with the Russian Federal Service for Supervision of Communications, Information Technology and the Mass Media (abbreviated in Russian as “Roskomnadzor”) that the operator intends to perform a cross-border transfer of personal data, the operator must obtain certain types of information from public authorities of the foreign state or from nationals or legal entities of such foreign state where the data is being transferred. Among these types of information is information about personal data regulation in the state under whose jurisdiction the data is kept.

It has been specified that such information is requested if the country in question is not included in the corresponding list of states with adequate protection of the rights of personal data subjects. An indication that a country is not a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data will no longer be applicable.

LEGISLATION

The following federal laws have been signed:

• extending the Government’s special authorities to establish, among other things, the specific aspects of state control, the permission-based regimes and how regulations should come into effect (No. 463-FZ dated 15 December 2025);

• specifying the rules of how coercive measures should be applied (No. 462-FZ dated 15 December 2025).

The ban has been extended on paying for membership interests in foreign companies without the permission of the Bank of Russia

The Russian President’s Ruling No. 894 dated 8 December 2025

Came into effect on 8 December 2025.

The ban has been extended until 31 December 2026 on carrying out certain transactions with non-residents without the consent of the Central Bank (clause 2(1) of the Russian President’s Ruling No. 126 dated 18 March 2022).

Specifically, the ban concerns a resident paying for a membership interest, for a contribution or for equity units in the property of a non-resident legal entity; or a resident making a contribution to a non-resident under a joint venture agreement.

Restrictions have been extended on closing a number of transactions

The Russian President’s Ruling No. 897 dated 8 December 2025

Came into effect on 8 December 2025.

The ban on closing certain transactions with shares of/membership interests in strategic enterprises and joint stock companies has been extended until 31 December 2027 (clause 1 of Ruling No. 520 dated 5 August 2022).