On 1 October 2026, Federal Law No. 289-FZ dated 31 July 2025, On Certain Matters Relating to the Regulation of the Platform Economy in the Russian Federation, will enter into force. It introduces uniform rules governing intermediary digital platforms, their partners, owners of order collection and delivery points, and users.
By summer 2026, the principal package of implementing regulations had been adopted. These regulations establish the criteria for classifying services as intermediary digital platforms, the rules for maintaining the relevant register, procedures for verifying partners and product listings, and the threshold for prolonged engagement of a self-employed contractor for the benefit of a single customer.
The key question for businesses is therefore no longer what new obligations will arise. It is which internal processes must be restructured before 1 October. The seven areas below require practical preparation.
1. Determine whether the service falls within the new law
The law applies not only to conventional online marketplaces. A service may qualify as an intermediary digital platform where it facilitates interaction between partners and users for the purpose of entering into transactions, selling goods, performing work, or providing services.
Depending on the actual business model, the new rules may apply to service aggregators, delivery services, taxi platforms, travel and hotel platforms, education and consulting services, and other digital intermediaries.
Government Resolution No. 54 dated 28 January 2026 approved additional criteria for classifying a digital platform as an intermediary digital platform. The rules for establishing and maintaining the dedicated register are set out in Government Resolution No. 504 dated 30 April 2026.
A company cannot rely solely on how the service is described in marketing materials. It must assess the operator’s actual role: who places offers, where the transaction is concluded, how payments are processed, who sets the rules of interaction, and who can restrict partners’ access.
2. Redesign the verification of sellers and service providers
From 1 October, platform operators must verify persons seeking to become platform partners. Verification will be carried out using state information systems and registers, including the Unified State Register of Legal Entities, the Unified State Register of Individual Entrepreneurs, Federal Tax Service data, and identification systems. The verification rules were approved by Government Resolution No. 768 dated 20 June 2026.
The general verification period may be up to five business days. Small and medium-sized enterprises will have access to an expedited procedure using data from the SME.RF digital platform, with verification taking up to one calendar day. A special procedure applies to foreign organisations without a Russian representative office, with a verification period of up to 15 business days.
Platforms will need to integrate verification into partner onboarding, define the required information, establish procedures for repeat checks, and determine how discrepancies will be handled. Sellers and service providers should check the accuracy of their data in state registers in advance: a technical error in the corporate or individual entrepreneur register, or in a self-employed person’s status, may prevent access to the platform.
3. Integrate verification of product, work, and service listings
Government Resolution No. 821 dated 2 July 2026 establishes the procedure for verifying information contained in product, work, and service listings. A transitional period applies to listings published before 1 October 2026: operators must complete their verification within 180 days.
Depending on the category of the offer, the platform must verify information on state registration, licences, certificates and declarations of conformity, mandatory labelling, manufacturers, and other required particulars.
For operators, this is no longer merely an interface issue. They must determine which checks will be automated, when manual review is required, what happens when a state register is unavailable, and how a partner may correct an error or challenge a refusal to publish a listing.
Sellers should review their documents and existing listings in advance. After 1 October, the approach of listing a product first and gathering supporting documents later will create a direct risk of interrupted sales.
4. Rewrite platform agreements and rules
Law No. 289-FZ imposes mandatory requirements on agreements between operators, partners, and owners of order collection and delivery points. Technical modifications to the service alone will therefore be insufficient.
Before 1 October, businesses should review provisions on commissions and deductions, settlements, discounts, amendments to cooperation terms, suspension of personal accounts, restrictions on listings, liability measures, and termination.
It is particularly important to align contractual language with the platform’s actual operation. If the terms provide for one notification procedure while the interface or algorithm operates differently, that inconsistency is likely to become a source of disputes.
The grounds for legally significant decisions must be defined in advance and communicated to the partner. A general reference to the platform’s right to change its rules or restrict access will no longer be sufficient.
5. Establish an effective suspension and complaints procedure
The new law requires an internal pre-trial complaints system for partners and owners of order collection and delivery points. It may be used to challenge suspension of a personal account, restrictions on a listing, refusal of access to the platform, and liability measures.
A platform will need to do more than add an online complaint form. It must record the grounds for each decision, preserve the history of actions taken, comply with applicable time limits, and provide for substantive review.
Particular attention should be given to automated suspensions. Even where the initial decision is made by an algorithm, the operator must be able to explain the reasons and arrange human review.
For partners, the new system provides an additional protection mechanism. However, a complaint should be prepared as a legally significant submission, setting out the alleged breach, referring to the relevant contractual provisions, and attaching supporting evidence.
6. Review the operating model for self-employed contractors
Government Resolution No. 760 dated 19 June 2026 establishes the criterion for systematic and prolonged work by one partner-contractor for the benefit of one customer-user.
The criterion is met where a contractor works for the benefit of one customer for more than 60 hours per month over six consecutive months.
This threshold does not, by itself, automatically result in reclassification of the relationship as employment. It is, however, an important indicator of economic dependence and a reason to review the actual operating model. It is also important to note that the criterion was adopted pursuant to Article 17(1)(5) of Law No. 289-FZ, which sets conditions for the lawful engagement of contractors through a platform. Exceeding the threshold therefore means that those conditions are not met, rather than merely attracting increased regulatory scrutiny.
Platforms and customers should assess whether contractors can select assignments independently, whether they are subject to a mandatory schedule, direct managerial control, a fixed workplace, or other features characteristic of employment. The presence of a platform between the parties does not eliminate reclassification risk where, in substance, a self-employed contractor works as a regular employee.
7. Build compliance processes and an evidence trail
From 1 October, platform decisions will be assessed not only by reference to the wording of the terms and conditions, but also by how algorithms, interfaces, moderation, and customer support operate in practice.
Companies should appoint process owners, allocate responsibility among legal, IT, moderation, customer support, and finance teams, and ensure that evidence is retained, including notices, reasons for suspensions, verification results, and complaint-handling records.
Government Resolution No. 820 dated 2 July 2026 approved the framework for federal state supervision in the platform economy, with supervisory authority assigned to the Federal Antimonopoly Service of Russia. Readiness for the new regime must therefore be demonstrated through functioning procedures and documentation, not merely policy statements.
Actions required from platforms
- assess whether the service falls within the definition of an intermediary digital platform and the criteria for inclusion in the register;
- prepare the corporate and technical information required for inclusion in the register;
- integrate mandatory seller and service-provider verification into the onboarding process;
- implement verification of product, work, and service listings;
- review listings published before the new rules take effect;
- revise terms and conditions and agreements with partners and owners of order collection and delivery points;
- clarify the grounds for account suspension, access restrictions, and liability measures;
- establish a fully functioning pre-trial complaints system;
- review settlement procedures, deductions, and discount arrangements;
- assess the operating model for self-employed contractors;
- align contractual documents with the actual logic of algorithms and interfaces;
- train customer support, moderation, legal, and product teams.
Actions required from sellers, service providers, and order collection and delivery points
- verify corporate, individual entrepreneur, SME-register, and self-employed status data;
- update licences, certificates, declarations of conformity, and documents for goods subject to mandatory labelling;
- audit existing product and service listings;
- review updated platform terms and conditions;
- establish an internal procedure for challenging suspensions and deductions;
- retain notices, correspondence, and documents demonstrating compliance;
- assess the actual model for engaging self-employed contractors and the risk of employment reclassification;
- owners of order collection and delivery points should separately review the grounds for penalties, procedures for amending operating standards, and the mechanism for challenging operator decisions.
From 1 October 2026, the platform economy will no longer be governed primarily by the internal rules of digital services themselves.
The principal change is not the introduction of another set of terms and conditions or another register. The law brings key platform processes – partner admission, listing verification, suspensions, complaints, and contractor engagement – within a mandatory legal framework.
Preparation therefore cannot be limited to editorial amendments to legal documents. The new requirements must be embedded in IT systems, algorithms, customer support, moderation, and internal controls.
Companies that begin adapting only after 1 October risk having to revise contracts, modify their products, and resolve partner disputes at the same time. The main implementation work should be completed in advance.
Legal framework
- Federal Law No. 289-FZ dated 31 July 2025, On Certain Matters Relating to the Regulation of the Platform Economy in the Russian Federation.
- Government Resolution No. 54 dated 28 January 2026, On Approval of Additional Criteria for Classifying a Digital Platform as an Intermediary Digital Platform.
- Government Resolution No. 504 dated 30 April 2026, On Approval of the Rules for Establishing and Maintaining the Register of Intermediary Digital Platforms.
- Government Resolution No. 760 dated 19 June 2026, On Approval of the Criterion of Systematic and Prolonged Performance of Work or Provision of Services Referred to in Article 17(1)(5) of the Federal Law On Certain Matters Relating to the Regulation of the Platform Economy in the Russian Federation.
- Government Resolution No. 820 dated 2 July 2026, On Federal State Supervision of Compliance with Requirements in the Platform Economy.
- Government Resolution No. 821 dated 2 July 2026, On the Procedure for Verification by an Operator of an Intermediary Digital Platform of Information Contained in a Product, Work, or Service Listing.
- Government Resolution No. 768 dated 20 June 2026, On Approval of the Rules for Verification by an Operator of an Intermediary Digital Platform of Information Concerning a Person Intending to Become a Partner of an Intermediary Digital Platform or an Owner of an Order Collection and Delivery Point When Entering into an Agreement with Such Partner or Owner (officially published on 26 June 2026).