Relevant national-level laws and regulations affecting civil society include:

• Constitution of the Russian Federation (adopted by popular vote on December12, 1993, with amendments approved by all-Russian vote on July 1, 2020).
• Civil Code of the Russian Federation, Part I, Federal Law No. 51-FZ, November 30, 1994 as amended.
• Civil Code of the Russian Federation, Part II, Federal Law No. 14-FZ, January 26, 1996, as amended.
• Criminal Code of the Russian Federation, July 13, 1996 No. 63-FZ as amended
• Code of Administrative Penalties, December 30, 2001 No. 195-FZ, as amended
• Tax Code of the Russian Federation, Part II, Federal Law No. 118-FZ, August 5, 2000, as amended. [Excerpts]
• Federal Law No. 7-FZ, “On Non-Commercial Organizations,” January 12, 1996, as amended (NCO Law).
• Federal Law No. 135-FZ, “On Charitable Activities and Charitable Organizations,” August 11, 1995, as amended (Charities Law).
• Federal Law No. 82-FZ, “On Public Associations,” May 19, 1995, as amended (Law on Public Associations).
• Federal Law No. 95-FZ, “On Gratuitous Assistance,” May 4, 1999, as amended (Law on Gratuitous Assistance).
• Federal Law No. 54-FZ “On Assemblies, Meetings, Demonstrations, Marches and Picketing,” July 19, 2004, as amended.
• Federal Law No. 275-FZ, “On the Procedure of Establishment and Use of Endowments of Non-commercial Organizations,” December 30, 2006.
• Order of the Ministry of Justice of Russia dd. November 30, 2012 № 223 “On Procedure of Maintaining Registry of Non-commercial Organizations, Performing Functions of Foreign Agent.”
• Federal law No. 139-FZ “On Amendments to Federal Law On Protecting Children from Information Harmful to Their Health and Development and Certain Legislative Acts of the Russian Federation”, July 28, 2012.
• Federal Law No. 121-FZ “On Introducing Amendments to Certain Legislative Acts of the Russian Federation Regarding the Regulation of Activities of Non-commercial Organizations, Performing the Functions of Foreign Agents,” July 20, 2012
• Federal Law No.149-FZ “On Information, Information Technologies and Information Protection,” as amended on July 30, 2012.
• Federal Law No. 272-FZ “On Measures of Influence of Persons, Relating to Violation of Human Rights, Rights and Freedoms of Citizens of the Russian Federation,” December 28, 2012
• Federal Law No. 212-FZ of July 21, 2014, on the Basics of Public Control in the Russian Federation.
• Federal Law No. 327-FZ of November 4, 2014 on Patronage of Arts.
• Federal Law No. 67-FZ of March 30, 2015, Amendments to Certain Legislative Acts of the Russian Federation in Terms of Ensuring the Reliability of Information to be Submitted for State Registration of Legal Entities and Individual Entrepreneurs.
• Federal Law No.304-FZ of March 30, 2015 on Amendments to Articles 4.5 and 23.1 of the Code of Administrative Offenses of the Russian Federation.
• Federal Law No. 76-FZ of March 30, 2016, Amending Federal Law on Freedom of Conscience and Religious Associations and Other Legislative Acts of the Russian Federation.
• Federal law No. 287-FZ of July 3, 2016, on Amending Federal Law on Non-Commercial Organizations in terms of Establishing the Status of Non-Commercial Organization – Provider of Public Benefit Services.
• Federal Law No. 375-FZ of July 6, 2016 on Making Changes into the Criminal Code of the Russian Federation and into the Criminal Procedural Code of the Russian Federation in Part Establishing Additional Measures On Counteracting Terrorism and Ensuring Public Safety introduced changes to 1) the Criminal Code, 2) the Criminal Procedural Code of the Russian Federation and 3) the Federal Law dated July 27, 2006 #153-ФЗ On Introducing Changes into Separate Legislative Acts of the Russian Federation in Relating to Adoption of the Federal Law On Ratification of Convention of the Council of Europe On Prevention of Terrorism and On Federal Law On Counteracting Terrorism. (This is known as part of the “Yarovaya Package”).
• Federal Law No. 374-FZ dated July 6, 2016 On Making Changes into the Federal Law on Counteracting Terrorism and Separate Legal Acts of the Russian Federation in Part Establishing Additional Measures On Counteracting Terrorism and Ensuring Public Safety introduced changes into 18 laws, including: 1) Federal Law On Counteracting Terrorism; 2) Federal Law On Federal Security Service; 3) Federal Law On Executive Investigative Activity; 4) Federal Law On External Intelligence; 5) Federal Law on Procedure of Exiting the Russian Federation and Entering into the Russian Federation; 6) Federal Law On Weapons; 7) Air Code of the Russian Federation; 8) Federal Law On Freedom of Conscience and on Religious Associations; 8) Federal Law On Post Communication; 10) Federal Law On Counteracting Legalization (Laundering) of Income, Received by Illegal Means, and of Financing of Terrorism; 11) Code of the Russian Federation On Administrative Offenses; 12) Federal Law On Transport-Expedition Activity; 13) Federal Law On Communication; 14) Housing Code of the Russian Federation; 15) Federal Law on Information, Informational Technologies, and On Protection of Information; 16) Federal Law On Transport Safety; 17) Federal Law On the Territorial Jurisdiction of District (Naval) Military Courts ; and 18) Federal Law On the Security of the Fuel and Energy Complex. (This is known as part of the “Yarovaya Package”).
• Federal Law No. 179-FZ of June 2, 2016 on Amendments to Article 8 of the Federal Law on Public Associations and Article 2 of the Federal Law on Noncommercial Organizations (new definition of “political activity”, which is relevant because “conducting political activity” is one of the criteria for an NCO to be qualified as an organization carrying out the functions of a foreign agent under Russia’s Law on NCOs).
• Federal Law No. 487-FZ of December 12, 2016 on Amendments to Articles 4 and 8 of Federal law on Civic Chamber of the Russian Federation (returning the order of formation of the Civic Chamber that existed before 2014).
• Federal Law No. 287-FZ of July 3, 2016 on Amending Federal Law on NCOs in Terms of Establishing the Status of NCO–Provider of Public Benefit Services (PBS) (entered into force on January 1, 2017).
• Federal Law No. 449-FZ of December 19, 2016 on Amendments to Article 31-1 of the Federal Law on NCOs (in Terms of Specification of Measures of Support of Socially Oriented NCOs–PBS by the Public Authorities and Local Self-Government) (entered into force on January 1, 2017).
• Federal Law No. 27-FZ of March 7, 2017, on Amendments to the Federal Law on the Prosecutor General’s Office of the Russian Federation (entered into force on March 17, 2017).
• Federal Law No. 64-FZ of April 3, 2017, on Amendments to Certain Legislative Acts of the Russian Federation Improving the State Policy in Combating Corruption (entered into force on April 15, 2017).
• Federal Law No. 35-FZ of March 28, 2017, on Amendments to Part 3 of Article 3.1 of the Federal law No. 272-FZ of December 2, 2012, on Measures of Influence on Persons Involved in Violations of Fundamental Rights and Freedoms of the Person, Rights and Freedoms of Citizens of the Russian Federation (entered into force on April 8, 2017).
• Federal law No. 64-FZ of April 3, 2017, on Amendments to Certain Legislative Acts of the Russian Federation Improving the State Policy in Combating Corruption (entered into force on April 15, 2017).
• Federal law No. 107-FZ of June 7, 2017, on Amendments to Certain Legislative Acts of the Russian Federation Related to Improvement of Legislation on Public Events (entered into force on June 18, 2017).
• Federal Law No. 320-FZ of November 14, 2017, on Amendments to Article 31-4 of the Federal Law on Non-Commercial Organizations. This law refers to assessment of the quality of public utility services by regional authorities and is aimed at simplifying the process for obtaining conclusions by government bodies, which are necessary for inclusion in the registry of NCO-providers of public benefit services.
• Federal Law No. 327-FZ of November 25, 2017, on Amendments to Articles10.4 and 15.3 of the Federal law on Information, Information Technologies and Protection of Information and Article 6 of the Law of the Russian Federation on Mass Media. The law is aimed, first of all, at expanding the list of reasons for extrajudicial restriction of access to information resources on the internet. Secondly, the law introduces recognition of foreign media as “foreign agents.”
• Federal Law No. 404-FZ of December 20, 2017, on Amendments to Article 8 of the Federal Law on Public Associations refers to expanding competence of the supreme governing body of a public association, other than the general meeting of members. The new powers include (which previously belonged to the general meeting of members): approving the annual report and accounting (financial) statements of the public association; making decisions on the establishment of other legal entities, on the participation of the public association in other legal entities, on establishing branches and on opening representative offices; and approving an audit organization or an individual auditor. This allows large public associations to not convene a general meeting of members to approve the above issues, but at the same time it can negatively affect the members’ rights, if members do not participate in certain decision making directly.
• Federal Law No.15-FZ of February 5, 2018, on Amendments to Certain Legislative Acts on Volunteering introduces several regulatory changes: the law (1) equates the terms “dobrovolets” and “volonter” in existing legislation; (b) introduces new definitions of “voluntary (volunteer) organization” and “the organizer of voluntary (volunteer) activities”; (c) defines the powers of government bodies in the sphere of volunteerism; and (d) provides support to volunteers’ activities.
• Federal Law No.98-FZ of April 23, 2018, on Amendments to Part Two of the Tax Code establishes procedures for providing a tax exemption for volunteers and “dobrovolets” from income tax when they work within service provider agreements; receive compensation in the form of reimbursement of their expenses and income in kind for uniforms and clothing, hiring premises, and travel expenses; and for the payment of medical insurance contributions for volunteers working in places with health risks. At the same time, property or funds received by NCOs as grants of the President of the Russian Federation will also not be taken into account when determining the tax base for corporate income tax.
• Federal Law No. 260-FZ of July 29, 2018, on Amendments to Articles 132 and 32 of the Federal Law on Non-Commercial Organizations in terms of improving the legal regulation of the activities of structural units of foreign non-commercial non-governmental organizations.
• Federal Law No. 230-FZ of July 29, 2018, on Amendments to the Tax Code of the Russian Federation in terms of registering with the tax authorities of the structural units of international organizations and foreign non-commercial non-governmental organizations, representations of foreign religious organizations.
• Federal Law No. 303-FZ of August 3, 2018, on Amendments to Certain Legislative Acts of the Russian Federation on Taxes and Fees provides for the extension of a lower rate (20% instead of commonly applicable 30%) for insurance (a mandatory payment due to the governmental bodies calculated based on salaries paid by an organization to its employees) for NCOs until either 2024.
• Federal Law No. 362-FZ of October 11, 2018, on Amending Article 5 of the Federal law on Anti-Corruption Expertise of Normative Legal Acts and Drafts of Normative Legal Acts. The law limits the number of categories of individuals and legal entities able to obtain official status as an independent expert accredited by the MoJ. In particular, the law establishes a ban on accrediting international and foreign organizations, as well as NCOs performing the functions of a foreign agent (FA), as independent experts. According to the Russian law, all drafts of legal acts require special anti-corruption expert review conducted by independent experts, before they are adopted. The government and parliament are required to consider results of such expert reviews before adopting legislation. The ban on accreditation for international and foreign organizations, as well as NCOs recognized as FAs, reduces the number of points of view and, accordingly, affects the overall objectivity of the anti-corruption expert review.
• Federal Law No. 367-FZ of October 11, 2018, on Amendments to Articles 5 and 10 of the Federal Law on Meetings, Rallies, Processions and Pickets entered into force on October 22, 2018. According to the law, the organizer of a public event is obligated to inform citizens and provide a written notification to the government about the cancellation of a public event no later than one day prior to its scheduled date. This requirement may be difficult to fulfill, as there are many instances when organizers of public events are forced to cancel the event due to last minute disruptions not dependent on the organizers, such as denial of premise rental an hour before the meeting.
• Federal Law No. 377-FZ of October 30, 2018, on Amendments to the Code of Administrative Offenses entered into force on November 11, 2018. The Code of Administrative Offenses is supplemented by Article 20.23, which provides for administrative liability for the organizer of a public event not fulfilling its obligations to inform citizens and government bodies about a decision to cancel the public event, as well as for filing a notification for holding a public event without indicating its purpose.
• Federal Law No. 426-FZ of November 27, 2018, on Amendments to Articles 219 and 286.1 of Part Two of the Tax Code of the Russian Federation entered into force on January 1, 2019. The law provides tax incentives for individuals and legal entities to support state and municipal (governmental) institutions carrying out cultural activities. According to the previous law, individuals could receive a refund of paid income tax, in the amount of donations valued at up to 13% from the total amount of 25% of taxable income, if the donations’ recipients are government institutions carrying out cultural activities or NCOs (funds/foundations), if donations were made to form endowments designated to support the above-mentioned government institutions. The law grants authority to the Russian regions to establish categories of government institutions carrying out cultural activities and NCOs (funds/foundations) if donations were made to form endowments designated to support the above-mentioned government institutions. For such donations, individuals may receive a higher refund of paid income tax, in the amount of donations valued at up to 13% from the total amount of 30% of taxable income. The law also grants Russian regions with authority to provide legal entities the right to reduce their income tax by deducting the amount of a donation from the legal entity’s taxable income, if donations to NCOs are made with the purpose of forming an endowment to support state institutions carrying out cultural activities. Such NCO-recipients shall be identified by authorities of Russian regions. Unfortunately, donors supporting non-state cultural institutions or other NCOs will not benefit from this law.
• Federal Law No. 469-FZ of December 18, 2018, on Amendments to the Federal Law on Objects of Cultural Heritage (Monuments of History and Culture) of the Peoples of the Russian Federation. The law grants volunteers the right to carry out certain types of work on the preservation of cultural heritage objects included in the corresponding register. According to the previous legislation, objects of cultural heritage are protected by the state, and only certified specialists can be involved in their restoration. The new law permits volunteers to carry out certain types of work that do not require special certification. The law does not provide details regarding such work. The law entered into force on December 29, 2018, the Russian government expected to adopt the relevant implementing regulation.
• Federal Law No. 553-FZ of December 27, 2018, on Amending the Article 3 of the Federal Law on Special Assessment of Working Conditions came into force on January 8, 2019. According to the law, the procedure for special assessment of working conditions, established by law, does not apply to religious organizations.
• Federal Law No. 555-FZ of December 27, 2018, on Amendments to Part 1 of Article 3-1 of the Federal Law on Measures to Influence Persons Involved in Violations of Fundamental Human Rights and Freedoms, the Rights and Freedoms of Citizens of the Russian Federation entered into force on January 8, 2019. The law expands the list of grounds for recognizing the activities of a foreign or international non-governmental organization as “undesirable” in the territory of Russia. Thus, in addition to threatening the foundations of the constitutional system of the Russian Federation, the country’s defense capability, or the security of the state, a foreign or international non-governmental organization may be deemed “undesirable” if it “facilitates or hinders the nomination of candidates, lists of candidates, the election of registered candidates, the initiative of holding a referendum and holding a referendum, the achievement of a certain result in elections, referendum, as well as in other forms (except for participation in election campaigns, referendum campaigns as foreign (international) observers).”
• Federal Law No. 557-FZ of December 27, 2018, on Amending Article 20.2 of the Code of Administrative Offenses of the Russian Federation entered into force on January 8, 2019. The law establishes administrative liability for the involvement of minors in unauthorized public events.
• Federal Law No. 31-FZ of March 18, 2019, on Amendments to Article 15-3 of the Federal Law on Information, Information Technologies and Information Protection. The law aims to curb the dissemination, under the guise of reliable messages, of unreliable, socially significant information that creates a threat to harm to life and (or) the health of citizens, property, the threat of mass disturbance of public order and (or) public security, or the threat of interference with the functioning or termination of the functioning of life support objects, transport or social infrastructure, credit institutions, energy facilities, industry and communications. For such information, the existing procedure for restricting access to information disseminated in violation of the law will be applied. Courts will issue such decisions on the basis of protocols prepared by the police. The law also provides that in cases when the specified unreliable, socially significant information is disseminated by the online publications, the editors of such online publications must delete the information upon receipt of an order from the authorized federal executive body (Roskomnadzor). Restricting access to the entire publication is allowed in cases if the editors fail to delete unreliable, socially significant information.
• Federal Law No. 27-FZ of March 18, 2019, on Amendments to the Code of Administrative Offenses  amended the CoAO, establishing administrative responsibility for disseminating in the media or in information and telecommunication networks deliberately unreliable, socially important information under the guise of reliable messages that creates the threat of harm to life and (or) the health of citizens, property, the threat of mass public disorder and (or) public safety or the threat of interfering with the functioning or interruption of the operation of life-support objects, transport or social infrastructure, credit institutions, energy facilities, industry or communications, as well as for the dissemination of information leading to the onset of the above-mentioned consequences (new parts 9-11 of Article 13.15 of the CoAO). At the same time, within 24 hours of initiating administrative cases under the newly introduced norms, the police should report to the prosecution authorities. The function of the prosecution authorities in this case is not entirely clear. As a sanction for these administrative offenses, the fine for citizens is 30 thousand -100 thousand rubles with or without confiscation of the subject of an administrative offense; for officials – 60 thousand-200 thousand rubles; and for legal entities – 200 thousand -500 thousand rubles with or without confiscation of the subject of an administrative offense. Print media circulation will likely also be regarded as the “subject of an administrative offense.” The vagueness of the wording creates the risks of arbitrary application of administrative norms in practice.
• Federal Law No. 30-FZ of March 18, 2019, on Amendments to the Federal Law on Information, Information Technologies and Information Protection. The law establishes a procedure for restricting access to information, expressed in an indecent form, which offends human dignity and public morality, or expresses obvious disrespect for society, the state, official state symbols of the Russian Federation, its Constitution, or authorities exercising state power in the Russian Federation. If such information is found, the Prosecutor General or his deputies submit a request to Roskomnadzor to take measures to remove this information and restrict access to information resources that disseminate the information if it is not deleted.
• Federal Law No. 28-FZ of March 18, 2019, on Amendments to the Code of Administrative Offenses establishes administrative responsibility for the distribution in information and telecommunication networks, including on the internet, of information which offends human dignity and public morality, or expresses obvious disrespect for society, the state, official state symbols of the Russian Federation, its Constitution, or authorities exercising state power in the Russian Federation, if these actions do not constitute a criminal offense. The penalty is a fine in the amount of 30 thousand-100 thousand rubles. The vagueness of the wording creates the arbitrary application of administrative norms in practice.
• Federal Law No. 34-FZ of March 18, 2019, No. 34-FZ on Amendments to Parts One, Two, and Article 1124 of Parts Three of the Civil Code of the Russian Federation came into force on October 1, 2019. The goal of this law is to establish several basic provisions in civil law, which would allow the legislature to regulate digital financial assets (commonly referred to as “tokens” and “cryptocurrency”). It provides conditions for concluding and executing digital transactions. In fact, these new assets are created and employed by users of information and telecommunication networks, including Russian citizens or legal entities, but were not recognized by Russian legislation before. The draft law submitted to the State Duma underwent many changes during its consideration. Although the law is not directly related to NCOs, it is important for all legal entities, as it provides for the possibility of conducting transactions using digital financial assets, which is unusual for NCOs, since many people lack electronic means of identification (electronic signature).
• Federal Law No. 112-FZ of April 23, 2014, on Amendments to the Federal Law on Counteraction to Legalization (Laundering) of Incomes Obtained in a Criminal Way, and Terrorism Financing and Article 13 of the Federal Law on Audit Activities established a new obligation for auditors to notify Rosfinmonitoring of any suspicions that persons audited by them violate legislation on counteracting legalization (laundering) of proceeds. However, this law was not actually applied until the publication of Methodological Recommendations posted online by Rosfinmonitoring on November 23, 2018 (Information Letter No. 56 of 11/23/2018 on These methodical recommendations “are based on legislation in the field of combating the laundering of proceeds from crime and the financing of terrorism at the time of their publication. In case of changes in the requirements of the legislation, the methodological recommendations are applied in the part that does not contradict the newly adopted regulatory legal acts.” In defining risks, these recommendations include, in particular, clients’ risks of money laundering and financing terrorism within: “9.2.1) charity, activities of public and religious organizations (associations), foreign non-commercial non-governmental organizations and their representative offices and branches operating in the territory of the Russian Federation, or other type of unregulated non-commercial activity.”
• Federal Law No. 90-FZ of May 1, 2019, on Amendments to the Federal law on Communications and the Federal law on Information, Information Technologies and Information Protection came into force on November 1, 2019. In the media, this law is referred to as the “Law on Sustainable Runet.” Multiple amendments to two Federal laws are written in technical language and are difficult to understand for NCOs. In accordance with the text of the law, the Federal Service for Supervision of Communications, Information Technologies and Mass Communications (Roskomnadzor) provides operators and owners of traffic exchange points with free of charge technical means of countering threats to the stability, security and integrity of the functioning of the internet information and telecommunications network and the public communication network in the territory of the Russian Federation. In addition, in the case of detection of such threats (the list of which will be subsequently determined by the Government of the Russian Federation), the Federal Service assumes the centralized management of the public communication network and / or issues the instructions to ensure functioning of the internet network for operators of communications which are obligatory for execution.
• Order of the MoJ No. 279 of December 6, 2019, amending Order No. 170 of the MoJ of August 16, 2018 exempted NCOs from reporting on funds received from Russian legal entities, when such entities receive funding from foreign sources, if the NCOs received such funds in 2019, thus postponing for another year this reporting requirement. Under the NCO law, NCOs have been required to report on the foreign sources from Russian entities-donors, while at the same time, Russian entities are not required to provide NCOs with this information, making it impossible for NCOs to report about it. Failure to report, however, is punishable with severe penalties.
• Federal law No.432-FZ of December 16, 2019, on Amendments to Certain Legislative Acts of the Russian Federation in order to improve the legislation of the Russian Federation on combating corruption was signed by the President on December 16, 2019. The law allows government and municipal employees, deputies of all levels as well as persons holding public positions to serve as leaders of NCOs (without compensation) without foreign participation, after notifying the government employer in advance. Previously, all these categories of government employees were prohibited from serving in NCOs’ management bodies. The law came into force on December 27, 2019.
• Concept on Support for Development of Charitable Activities for the period up to 2025 was adopted by the Order of the Government of the Russian Federation of November 15, 2019, No. 2705-r. The main directions of promoting charity development in the Concept are the following: promoting the development of charity institutions; promoting the development of charity for individuals and commercial organizations; promoting the development of culture of charity; promoting the development of support for charity in the regions of the Russian Federation; and promoting the development of international activities in the field of charity. One of the main results of the Concept’s implementation should be a change in the legislative regulation of charitable activities, for example: improving regulation of the formation of endowments; enabling charitable organizations to repay a loan using donations, and setting a limit on the amount of interest on a loan that can be paid using donations; ensuring effective prevention and suppression of fraudulent activities conducted under the disguise of collecting charitable donations; removing the need for charities to submit duplicate reports to state authorities; and developing proposals for improving regulation and law enforcement practice in the field of government control over charitable NCOs’ management bodies when making large transactions and transactions with interest. During implementation of the Concept, issues around establishing additional tax benefits and cases of exemption from taxation will be worked out. The Concept also envisions development of a training system for NCOs and a support system for newly created organizations. In the field of the development of international charitable activities, the Concept’s implementers (Government of the Russian Federation) plan to promote the work of Russian charitable organizations abroad and build global cooperation.
• Federal Law No. 407-FZ of December 2, 2019, on Amending Certain Legislative Acts of the Russian Federation with the purpose of establishing a prohibition to act as a founder (member, participant) of a non-commercial organization on persons with respect to whom a decision is adopted to freeze (block) funds or other property in connection with sufficient grounds to suspect them of involvement into terrorist activities. According to this law, individuals having their assets frozen because of terrorism allegations would be banned from being founders, participants, or members of NCOs. These amendments, according to the Government, would help secure the nonprofit sector against abuse for financing terrorist activities. However, the criteria for making a decision on the freezing (blocking) of funds or other property in connection with sufficient reasons to suspect involvement in terrorist activities are not specified, making arbitrary application of the law possible. The law came into force on December 13, 2019.
• Federal Law No. 426-FZ of December 2, 2019, on Amending the Law of the Russian Federation on the Mass Media and the Federal Law on Information, Information Technologies and Protection of Information. The so-called law on “individuals-foreign agents” came into force on December 2, 2019. Additionally, all media recognized as FAs (including individuals recognized as media-FAs) must establish a Russian legal entity by February 1, 2020. The law extended the rules on the activities of foreign mass media performing the functions of a foreign agent (mass media-FA) and (NCO-FA) to individuals and commercial organizations. In accordance with the adopted amendments, in order to recognize an individual as a “mass media-FA,” two characteristics are required: distribution of printed, audio, audio-visual and other messages and materials intended for an unlimited number of persons (including using the Internet information and telecommunications network»); and receipt of funds and (or) other property from foreign states, their state bodies, international and foreign organizations, foreign citizens, stateless persons or persons authorized by them, and (or) from Russian legal entities that receive funds and (or) other property from these sources. The decision to recognize an individual as a mass media-FA is made by the MoJ in consultation with the Ministry of Foreign Affairs. After being recognized as a mass media-FA, an individual is obliged to: establish a Russian legal entity or notify the MoJ of all previously established legal entities within one month from the date of recognition as a “mass media-FA.” Information about these legal entities is also subject to inclusion in the Register of mass media-FAs, and they acquire the status of “Russian legal entity performing the functions of a foreign agent”; label messages and materials distributed in the territory of the Russian Federation indicating that these messages and materials are created and/o) distributed by a “mass media-FA”; and comply with the requirements of the NCO law in the part that must be determined by a special act of the MoJ to be issued in accordance with this law. The obligation to establish a legal entity forces an individual to incur financial costs associated with its registration (legal services, payment of state duty), and opening and maintaining a bank account. The legislative procedure for notifying of an individual on recognition of their status as a “mass media-FA” by the MoJ is not fixed in the law. In fact, all individuals are at risk of administrative penalties (a fine of 10,000 rubles) if they do not keep track of the Registry of foreign media-FAs and do not learn about their recognition as a “mass media-FA” and accordingly, do not fulfill the requirements of the law on establishing a legal entity and labeling materials. The procedure for removing an individual from the Register of mass media-FAs is also not regulated by the law, as it mentions only the MoJ’s right to include information about an individual in the corresponding Register and to exclude it.
• Federal law No. 443-FZ of December 16, 2019, on Amendments to the Code of Administrative Offenses (CoAO) (on establishing liability for violation of the procedure for the activity of a foreign media outlet). The law provides for imposing fines as high as 5 million rubles for repeated violations of media laws related to FAs.First-time offenses carry smaller penalties:  FAs news outlets will face fines as high as 1 million rubles and individual FAs could be forced to pay as much as 10 thousand rubles. The law came into force on February 1, 2020.
• Law of the Russian Federation on the Amendment to the Constitution of the Russian Federation of March 14, 2020 No. 1-FKZ on Improving the Regulation of Certain Issues of the Organization and Functioning of Public Authority was submitted to the State Duma by the President on January 20, 2020. It provoked a lot of critical comments, as it included such controversial provisions as: on the supremacy of the Russian Constitution over decisions of international bodies, the possibility for the President to stay in power until 2036, and others. The State Duma Council has repeatedly extended the deadline for submitting amendments to the second reading. On March 11, constitutional amendments were approved by the Federation Council. On March 14, the President signed the text of this law. The Constitutional Court of the Russian Federation confirmed the compliance of the law’s provisions with the Constitution. This law should have been approved by the universal vote (nation-wide people’s vote, different from referenda) scheduled for April 22, 2020. Due to the spread of COVID-19, the President repeatedly postponed the vote, that finally took place on July 1, 2020. The law does not contain provisions which would directly affect NCOs’ activities, but is of concern to civil society at large, as it eliminates an opportunity for NCOs to defend human rights by appealing to international institutions.
• Federal law No. 60-FZ of March 18, 2020, on Amendments to Articles 2 and 31-4 of the Federal Law on NCOs established a new basis for including SONCOs in the Register of SONCO-providers of public benefit services – “proper implementation of projects that provide the implementation of activities in one or more priority areas in the sphere of providing public benefit services using grants from the President of the Russian Federation aimed at the development of civil society.” The evaluation of such projects’ results will be carried out by an organization authorized to provide grants from the President of the Russian Federation – the Presidential Grants Fund. Evaluated SONCOs will not need to obtain additional opinions on the quality of services they provided.
• Federal law No. 100-FZ of April 1, 2020, on Introducing Changes to the Criminal Code of the Russian Federation and Articles 31 and 151 of the Criminal Procedure Code of the Russian Federation was adopted by the State Duma on March 31 and signed by the President on April 1. The first group of amendments to the Criminal Code establishes that public dissemination, under the guise of reliable reports of false public interest information, which results by negligence in the infliction of harm to human health, will be punished with a fine in the amount from 700 thousand to 1,5 million rubles or the salary or other income of the convicted person for a period of eighteen months, or correctional labor for a term up to one year, compulsory works for a term up to three years, or imprisonment for the same term. The same act which results by negligence in human death or other grave consequences, shall be punished by a fine in the amount of 1.5 million to 2 million rubles or the salary or other income of the convicted person for a period of eighteen months to three years, or correctional labor for up to two years, or hard labor for a term up to five years, or imprisonment for the same term. The second group of amendments is related to huge penalties for violations of quarantine. Thus, changes increase criminal responsibility over violation of sanitary-epidemic rules: up to three years in prison; if such violation caused accidental death of two and more persons: up to seven years in prison (Article 236 of the Criminal Code).

• Federal law 113-FZ of April 4, 2020, on Amendments to the Federal law on Charitable Activities and Volunteering provides for the definition of the concept of a “box for collecting donations:” “a box for collection of donations – any capacity (including a device) for collection of donations, the right to use of which belongs exclusively to NCOs, whose bylaws provide for the right to carry out charitable activities.” The law also provides for two types of boxes: portable and stationary. Installation and use of stationary boxes are allowed on the basis of an agreement with the owner (user) of the premises, except when they are installed by relevant NCOs during public events organized by them (or their associations) or with written permission from the organizers of a public event. The use of a portable box is allowed during a public event if there is a document from the organizer of the event. Requirements for boxes, and the procedure for their installation and use should be determined by the regulatory act of the Government of the Russian Federation. The adoption of this law improves the NCO legal environment as previously collecting cash donations was not regulated, and therefore, de facto not permitted by law (while the cash collections are not specifically prohibited by law, they would violate multiple other legal rules, subject to penalties). It also sets rules protecting NCOs from abuse by criminals who “fundraise” from the public under the guise of and legitimate NCOs. The law came into force on October 4, 2020.
• Order of the President of the Russian Federation of May 6, 2020, No. 120-rp (on the allocation of funds from the reserve fund of the President of the Russian Federation) in the amount of 3 billion rubles to the fund operating presidential grants for the development of civil society (i.e. through provision of grants to SONCOs) including for the mandatory purchase of personal protective equipment for NCO employees and volunteers. This is one of the measures to support the NCO sector, which the President announced on April 30, 2020. This program started implementation in June, when the Fund for Presidential Grants announced a Special Competition to support SONCOs during the fight against the spread of COVID-19.
• Federal law No. 154-FZ of May 23, 2020, on Amendments to Certain Legislative Acts of the Russian Federation provides for changes in legislation on elections and referendums and basic guarantees of electoral rights and the right to participate in referendums for citizens of the Russian Federation. In addition to letting voters cast their ballot by mail or via the internet, elections candidates will now be allowed to collect voter signatures through the government services portal “Gosuslugi.” This law also provides for banning persons convicted of crimes of average gravity from standing as candidates in any election. The ban is to be active five years after expungement of conviction. The law prohibits persons convicted of involving minors in crimes and inducing them to suicide, kidnapping, obstruction of electoral commissions’ operation and exercise of electoral rights, falsification of voting documents, public calls for extremism and infringement of territorial sovereignty, fraud, money laundering and repeated violation of the order of organizing and holding rallies from running for election. Previously, such a ban was applied to grave crimes’ convicts.
• Federal Law No. 163-FZ of May 25, 2020, on Amending Certain Legislative Acts of the Russian Federation. This law provides, in particular, for increasing the maximum level of compensation for bank deposits for citizens in some cases up to 10,000,000 rubles and expanding the list of legal entities that can claim compensation for deposits, including SONCOs. Deposits placed by certain types of NCOs (or in their favor) are protected by insurance in accordance with this Federal law. Before the adoption of this law, SONCOs practically could not receive funds if the bank where they made deposits lost its license. However, these positive measures will not apply to NCO-FAs.
• Federal Law No. 172-FZ of June 8, 2020, on Amendments to Part Two of the Tax Code of the Russian Federation that provides, in particular, for: SONCOs included in the MoED’s Registry of SONCOs are fully exempt from social insurance payments and taxes for the second quarter of 2020 (excluding VAT); and funds that businesses send to NCOs and religious associations, within 1% of revenue, can be attributed to non-operating expenses, reducing profit tax due” (this incentive was adopted for the first time, as donors in the Russian Federation have never enjoyed any benefits in connection with their donations, and the president has always refused to accept them before, suspecting the business only of tax fraud).
• Federal law No.168-FZ of June 8, 2020, on the Unified Federal Information Register Containing Information about the Population of the Russian Federation provides for creation of a single database of personal data of Russians. The unified database of individuals will contain the full name (and change of name), date of birth, gender, citizenship, marital status, as well as details of foreign and Russian passports, diplomas, and other information about education. The Register will contain information about tax and military registration, information from employment records, and information about registration in mandatory insurance systems, including Insurance Number of Individual Ledger Account (СНИЛС) and Individual Taxpayer Number (ИНН). In total, the Register will include 30 types of information about each person in the country. The Federal Tax Service (FTS) will operate the database. Access to information about personal data is limited to FTS employees responsible for the data, but can be requested by state authorities, the Multifunctional Centers for Provision of Public and Municipal Services, the Election Commission, notaries, and directly by the citizen himself, if he needs information about himself or persons who are dependent on him. In particular, intelligence services employees will have access to the database. This can be considered a direct violation of Article 24 of the Constitution, which states that “any use and dissemination of information about the private life of a citizen is carried out with the consent of the citizen.” It also contradicts the Federal Law on Personal Data, according to which the processing of personal data must be stopped and the collected data must be destroyed within 30 days from the date of achieving the purpose of its processing. The majority of experts consider that potential negative consequences of the law include leaks of personal data in the Russian Federation, additional state surveillance, and the Unified Register’s development as a tool for total electronic control.
• Decree of the Government of the Russian Federation of June 11, 2020, No. 847 on the Registry of Non-Commercial Organizations Most Affected by the Deterioration of the Situation as a result of the Spread of Novel Coronavirus Infection. According to the Decree, NCOs are included in the Registry of Non-Commercial Organizations Most Affected by the Deterioration of the Situation as a result of the Spread of Novel Coronavirus Infection(Registry of NCO-victims of the pandemic) based on the following criteria: an NCO is a private educational organization that carries out educational activities on the basis of a license as the main type of activity in accordance with the goals for the achievement of which such an organization was created; an NCO is a charitable organization registered in accordance with the procedure established by the legislation of the Russian Federation and applying reduced social insurance premiums; an NCO is a non-commercial organization (with the exception of state (municipal) institutions) registered in accordance with the procedure established by the legislation of the Russian Federation, carrying out activities in the field of social services for citizens, scientific research and development, education, healthcare, culture, and art in accordance with the constituent documents (the activities of theaters, libraries, museums and archives) and mass sports (with the exception of professional sport) and applying reduced social insurance premiums; and an NCO is included in the list of organizations whose grants received by taxpayers, provided to support science and education, culture and art, are not subject to taxation. The MoED is the authorized body for forming and maintaining the Registry of NCO-victims of the pandemic. The Federal Tax Service and the Federal Service for Supervision in Education and Science provide information about organizations to be included in the Registry.
• Decree of the Government of the Russian Federation No. 906 of June 23, 2020, on the Registry of Socially Oriented Non-Commercial Organizations provides for the procedure for maintaining the Registry of SONCOs that have received grants and subsidies, performed social services, and provided public benefit services since 2017 The Registry is formed by the MoED and is publicly available on the Ministry’s website. The Decree defines the list of information to be included in the Registry, and the terms and procedure for entering it.
• Decree of the Government of the Russian Federation of June 13, 2020, No. 862 on Amendments to Some Acts of the Government of the Russian Federation in terms of establishing the specifics of the implementation of state control (supervision), municipal control in 2020 changed the grounds for conducting state inspections of NCOs as follows: unscheduled inspections of NCOs may be conducted in case of receipt of information about violation of the legislation regulating NCOs’ activities or the presence of signs of extremism in their activities, violation of the electoral legislation, and in case of carrying out the activities of an NCO performing the functions of FA that has not submitted an application for inclusion in the FA Registry. These grounds for unscheduled inspections of NCOs are much broader and vague than grounds for such inspections for businesses.
• Decree of the Government of the Russian Federation of July 2, 2020, No. 976 on Approval of the Rules for the Provision of Subsidies from the Federal Budget in 2020 to Small and Medium-Sized Businesses and Socially Oriented Non-Commercial Organizations for the Prevention of New Coronavirus Infection provides for allocation of subsidies for disinfection of premises, markings, dispensers, masks and gloves. The subsidy is divided into initial and current. The first will amount to 15,000 rubles. The second will be calculated as the product of 6,500 rubles by the number of employees of the organization in May 2020.
• Decree of the President of the Russian Federation of July 7, 2020, No. 441 on Amending the Regulations on the Ministry of Justice of the Russian Federation, approved by the Decree of the President of the Russian Federation of October 13, 2004 No. 1313. According to the Decree, the MoJ establishes the procedure for the formation and maintenance of a Registry of foreign media that perform the functions of a foreign agent (Registry of FM-FAs). The Decree came into force from the day it was signed – July 1, 2020. Earlier, the government gave the MoJ the authority to receive notifications from FM-FAs about the branches they established in the Russian Federation, as well as to establish the procedure for the formation and maintenance of a Registry of FM-FAs and the procedure for applying the provisions of the law on NCOs. New powers are envisaged based on the authority of the MoJ to maintain a Registry of FM-FAs.
• Decree of the Government of the Russian Federation of July 11, 2020, No. 1032 on Amendments to Certain Acts of the Government of the Russian Federation clarified the support measures for SONCOs, as well as NCOs most affected by the COVID-19 pandemic, included in the relevant registries. The amendments are related to the granting of such organizations a deferral for rent and tax payments, as well as insurance premiums.
• Federal law No. 203-FZ on July 13, 2020, on Amendments to Article 21 of the Federal Law on State Registration of Legal Entities and Individual Entrepreneurs  provides for making changes aimed at protecting the rights of workers in relation to their receipt of all due payments upon liquidation of the organization. Before submitting an application for state registration of liquidation, an organization must terminate all employment contracts with employees and make all payments to dismissed workers. The law came into force on July 13, 2020.
• Federal Law No. 189-FZ of July 13, 2020, on the State (Municipal) Social Order for the Provision of State (Municipal) Services in the Social Sphere  provides for an opportunity for legal entities, including SONCOs, to receive budget funds for the provision of social services through participation in the state procurement system. The law covers only education, health care, social protection, employment, physical culture, sports, and tourism. SONCOs conducting activities in these spheres will be able to receive budget funding. The law came into force on September 1, 2020, in selected regions and is valid until 2025.
• Federal law No. 208-FZ of July 13, 2020, on Amendments to the Federal law on Countering the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism in order to improve mandatory control. According to the law banks will be required to report all transactions of entrepreneurs with cash in the amount of 600 thousand rubles or more. The law also introduces mandatory control of postal transfers over 100 thousand rubles; and strengthens control over operations under leasing agreements in the amount of more than 600 thousand rubles.
• Federal law No. 282-FZ of July 31, 2020, on Amendments to the Federal law on Charitable Activities and Volunteerism and the Federal law on the Procedure for Forming and Using the Endowment Capital of Non-Commercial Organizations provides for amendments to legal regulation of endowments. The proposed changes are, in particular, the following: the formation of endowment capital is allowed for charitable foundations; an opportunity for NCO-owners of endowment capital to announce public fundraising for the formation of endowment capital; and the period for collecting donations for the formation of endowment capital is extended, provided that the amount of donations exceeds 1,500,000 rubles during the first year of collecting donations.
• Order of the Ministry of Justice of the Russian Federation of August 31, 2020, No. 190 on Approval of the Requirements for the Form and Timing of Publication of the Report of a Non-Commercial Organization on the Use of Collected Charitable Donations was adopted in order to implement the provisions of Article 16.1 of the Federal Law on Charitable Activities and Volunteering, effective from October 5, 2020, which regulates the use of boxes for collecting donations. The adopted order contains both positive norms (designed to eliminate fraudulent actions in the field of charity) and negative ones (imposing an additional obligation on charitable NCOs to submit reports, for the failure to provide them the law establishes administrative responsibility).
• Decree of the Government of the Russian Federation of September 14, 2020, No. 1419 On Amending the Decree of the Government of the Russian Federation of January 26, 2017 No. 89 established a procedure for the issuance by the Fund, the operator of presidential grants for the development of civil society, of an opinion on the proper implementation of projects for the provision of socially useful services. In particular, the amendments provide that a conclusion on the proper implementation of projects is issued by the Fund based on the results of assessing the results of projects on the basis of a written application of the organization for the issuance of an opinion.
• Order of the Federal Service for Supervision in the Sphere of Communications, Information Technology and Mass Media of September 23, 2020, No. 124 on Approval of the Form indicating that messages and materials have been created and (or) disseminated by a foreign mass media performing the functions of a foreign agent, and (or) a Russian legal entity performing the functions of a foreign agent, requirements for placement and placement procedure such an indication provides for the rules of labeling FM-FAs’ materials. The text of the Order states that messages and materials distributed on the territory of the Russian Federation must be accompanied by an indication that they were created or distributed by FM-FA, or by a Russian legal entity performing such functions. In addition, FM-FAs must indicate the following to their articles – “this message (material) was created and (or) disseminated by a foreign mass media performing the functions of a foreign agent, and (or) a Russian legal entity performing the functions of a foreign agent “. Such a text indication should be placed at the beginning of the article. The draft also states that the font color of the text message should be in contrast to the background. The same requirements apply to mass media disseminating data by means of audiovisual means. However, in their case, the corresponding accompaniment must be published before the start of the broadcast – it must be shown for at least 15 seconds. It is necessary to place such an indication in the center of the screen – it must occupy at least 20% of the screen area. When sounding such accompaniments on the radio, the use of speech acceleration technologies is not allowed, in addition, the volume level should not be lower than the messages themselves. Failure to comply with the form and procedure of marking by a FM-FA entails administrative liability established by article 19.34.1 of the CoAO of the Russian Federation in the form of an administrative fine for officials in the amount of 50 to 200 thousand rubles, for legal entities – from 500 thousand to 5 million rubles.
• Order of the MoJ of September 24, 2020, No. 214 on Approval of the Procedures for Applying to Persons Specified in Parts Three and Seven of Article 6 of the Law No. 2124-1 of December 27, 1991, on the Mass Media, and to a Russian Legal Entity Established by a Foreign Mass Media Performing the functions of a Foreign Agent, the Provisions of the Federal Law of January 12, 1996 No. 7-FZ on Non-Commercial Organizations in accordance with which a FM-FA submits to the MoJ directly, in the form of a postal item with a list of attachments or in the form of electronic documents: a report on its activities, on the personal composition of the governing bodies in the form NOИA001 – once every six months, no later than the 15th day of the month following the end of the half-year (January 15, July 15); a report on the purposes of spending money and use of other property, including those received from foreign sources, and on the actual spending and use of funds and other property received from foreign sources, in form No. OИA001 – quarterly no later than the 15th day of the month following the end of the quarter (January 15, April 15, July 15, October 15); and an auditor’s report on the results of the audit of the annual accounting (financial) statements annually no later than April 15 of the year following the reporting year (except for individuals).
• Order of the MoJ of September 24, 2020, No. 216 on Approval of the Procedure for the Formation and Maintenance of the Registry of Foreign Mass Media Performing the Functions of a Foreign Agent. The Order establishes the rules for the formation and maintenance of the registry of FM-FAs. The formation and maintenance of the registry is carried out by the MoJ. The registry is kept on paper and electronic media. If information on paper does not correspond to information on electronic media, information on paper has priority. The information contained in the registry is open, access to them is provided by posting on the official website of the MoJ of the information contained in the registry on electronic media. There are grounds for making a decision on the inclusion of information in the registry, on excluding information from the registry, requirements for an application for the inclusion of information in the registry.
• Decree of the Government of the Russian Federation of October 1, 2020, No. 1584 on Approval of Requirements for Boxes for Collecting Charitable Donations, the Procedure for Their Installation, Use and Retrieval of Property Collected with their Help was developed in compliance with Federal law No. 113-FZ of April 7, 2020, on Amendments to the Federal law on Charitable Activities and Volunteering.
• Decree of the Government of the Russian Federation of October 1, 2020, No. 1584 on Approval of Requirements for Boxes for Collecting Charitable Donations, the Procedure for Their Installation, Use and Retrieval of Property Collected with their Help was developed in compliance with Federal law of April 7, 2020, No. 113-FZ on Amendments to the Federal law on Charitable Activities and Volunteering. This Decree introduces uniform requirements for the use of donation boxes, it will help to reduce the number of fraudulent actions in the field of collecting charitable donations and will discipline those charitable organizations that previously neglected such obvious rules as sealing a box or drawing up an act on its opening.
• Federal law No. 333-FZ of October 15, 2020, on Amending Article 7 of the Federal Law on General Principles of Organization and Operation of Civic Chambers of the Subjects of the Russian Federation, according to which deputies of all levels cannot be members of civic chambers. This law excludes possible obvious pressure of deputies on other members of regional civic chambers, though in practice regional civic chambers are in the overwhelming majority of cases under a strong influence of local authorities. The law came into force on October 26, 2020.
• Federal Law No. 337-FZ of October 15, 2020, on Amendments to Articled 9 and 10 of the Federal law on Countering Extremist Activity entered into force on April 13, 2021. The law imposes on the MoJ the obligation to approve the procedure for maintaining the list of NCOs in respect of which the court has adopted a final decision on the liquidation or prohibition of activities (as of February 10, 2024, total number of NCOs in this list is 105), as well as the procedure for maintaining the list of public and religious associations whose activities have been suspended due to their implementation of extremist activities. A list of public and religious associations whose activities have been suspended due to their implementation of extremist activities, was also created by the MoJ on October 3, 2019, as of February 10, 2024, it contains no entries.
• Federal Law No. 407-FZ of December 8, 2020, on Amendments to the Labor Code of the Russian Federation regarding the regulation of remote work and the temporary transfer of an employee to remote work at the initiative of the employer in exceptional cases. According to the law, types of remote work defined in the Labor Code are direct remote working, temporary remote working and a combination of these two types of remote working. The amendments also regulate the working time of those employed on home sourcing terms, so they could not be under the necessity to respond to calls or messages of employers around the clock. The changes simplify the registration of remote employees’ work, especially in the context of restrictions related to the spread of coronavirus infection, provide for the regulation of controversial issues related to remote work, and create new opportunities for employees and employers. The law came into force on January 1, 2021.
• Federal Law No. 410-FZ of December 8, 2020, on Amendments to the Code of the Russian Federation on Administrative Offenses entered into force on December 19, 2020. This law amends Article 4.1.1 of the CAO, which earlier provided for the replacement of an administrative fine with a warning only for small and medium-sized businesses, as well as for individual entrepreneurs. This put NCOs in an unequal position with commercial organizations, “which, unlike NCOs, systematically make a profit and have the material opportunity to pay penalties.” The law allows replacing an administrative fine with a warning if the NCO committed an administrative offense for the first time, and if it did not harm the life and health of people, objects of flora and fauna, the environment, property damage and did not lead to other grave consequences. However, there are cases when an administrative fine will be prohibited from being replaced by a warning. For example, it will be impossible when committing such administrative offenses as the distribution by the owner of the audiovisual service of information containing public calls to carry out terrorist activities, materials publicly justifying terrorism, or other materials calling for the implementation of extremist activities or justifying or justifying the need for such activities. An administrative fine will also threaten for propaganda or public display of Nazi paraphernalia or symbols, or paraphernalia or symbols of extremist organizations, as well as other symbols and paraphernalia, propaganda and public display of which are prohibited by law. In addition, it will not be possible to replace the warning with a fine in case of failure to provide information by an NCO-FA, violation of the procedure for the activities of such an organization, as well as for organizing the activities of an NCO-FA in respect of which a decision was made to suspend its activities.
• Federal Law No. 476-FZ of December 29, 2020, on Amendments to Article 5 of the Federal Law on Auditing Activity came into force on January 1, 2021. The government submitted this draft law to the State Duma on November 19, 2019. The Ministry of Finance included an exemption for funds/foundations from the obligation to undergo an annual audit, if the receipt of property and funds during the preceding reporting year does not exceed 3 million rubles (with the exception of endowment funds) into it. This law will save many funds/foundations from a financially costly auditing procedure.
• Federal Law No. 477-FZ of December 29, 2020, on Amendments to the Labor Code of the Russian Federation that came into force on January 1, 2021, is aimed at simplifying the workflow of NCOs in the field of labor relations. It permits small NCOs with up to 35 employees and an annual income of up to 800 million rubles  to draw up fixed-term employment contracts. NCOs with a staff of no more than 15 people and revenue of less than 120 million rubles a year will not need to approve the internal labor regulations, regulations on wages and bonuses.
• Federal Law No. 503-FZ of December 30, 2020, on Amendments to Articles 8 and 11 of the Federal Law on Special Assessment of Working Conditions provides for establishing an indefinite validity of the declaration of conformity of working conditions to state regulatory requirements for labor protection, which will allow employers, after the expiration of the declaration, in cases where working conditions at the declared workplaces have not changed, not to conduct a special assessment of working conditions, which will allow reduce the financial burden on them. At the same time, the implementation of the norms of the law will not lead to a decrease in the objectivity and quality of a special assessment of working conditions and the level of protection of the workers’ right to safe working conditions. This law saves most NCOs from the costly procedure of periodically conducting an expensive special assessment procedure.
• Federal Law No. 481-FZ of December 30, 2020, on Amendments to Certain Legislative Acts of the Russian Federation on terms of establishing additional measures to counter threats to national security came into force on December 30, 2020. Practically, it’s a whole package of laws provides for amendments to: Article 4 of the Law of the Russian Federation of December 27, 1991, 2124-1 on Mass Media; Paragraph five of the first part of Article 22 of the Law of the Russian Federation of July 21, 1993 No. 5485-1 on State Secrets; Federal Law of May 19, 1995 No. 82-FZ on Public Associations; Federal Law of January 12, 1996 No. 7-FZ on Non-Commercial Organizations; Federal Law of December 28, 2012 No. 272-FZ on Measures of Influence on Persons Involved in Violations of Fundamental Human Rights and Freedoms, Rights and Freedoms of Citizens of the Russian Federation (Dima Yakovlev law); and Part 6 of Article 13, Federal Law of July 21, 2014 No. 212-FZ on the Basics of Public Control in the Russian Federation. This law is aimed, in particular, at introducing norms on recognizing individuals as FAs, as well as the emergence of obligations for unregistered public associations to notify the MoJ about the availability of foreign funding for their recognition as FAs by analogy with NCOs-legal entities.
• Federal Law No. 482-FZ of December 30, 2020, on Amendments to the Federal Law on Measures of Influence on Persons Involved in Violations of Fundamental Human Rights and Freedoms, Rights and Freedoms of Citizens of the Russian Federation (so called law on “censorship in internet”) entered into force on January 10, 2021. This law was developed at the request of Roskomnadzor (Russian media watchdog) as a kind of “response mechanism to censorship against Russian citizens and the media.” The law introduces a special status of an “owner of an information resource involved in violations of basic rights and liberties of citizens of the Russian Federation”; the status is to be granted by the Prosecutor General’s Office in consultation with the Ministry of Foreign Affairs. The same measure may be applied to internet resources found to restrict access to information of public character on grounds of nationality, language, or in answer to the introduction of sanctions against the Russian Federation or its citizens. According to the law, Roskomnadzor is empowered to fully or partially restrict access to such resources by technical means.
• Federal LawNo. 497-FZ of December 30, 2020, on Amendments to the Federal Law on Assemblies, Rallies, Demonstrations, Processions and Picketing entered into force on January 10, 2021. The law proposes that mass actions include not only a set of single pickets united by a single plan and a common organization, but also “alternate participation of several persons in such picketing acts”, as well as “mass simultaneous stay and (or) movement of citizens in public places aimed at expressing and forming opinions”. The law also contains a list of bans for journalists covering rallies. In particular, they will not be allowed to use posters and banners, organize the collection of signatures, use “various symbols and other means of public expression of collective or individual opinion” and hide the “distinctive feature of a media representative”.
• Federal Law No. 511-FZ of December 30, 2020, on Amendments to the Code of Administrative Offenses of the Russian Federation entered into force on January 10, 2021. This law is related to so called “law on the censorship in Internet” (Federal Law of December 30, 2020 No. 482-FZ on Amendments to the Federal Law on Measures of Influence on Persons Involved in Violations of Fundamental Human Rights and Freedoms, Rights and Freedoms of Citizens of the Russian Federation) and was submitted as a “response” to blocking Russian official media sources in internet and is targeted primarily against YouTube, Facebook, Twitter. Now, for actions in which the authorities see censorship, the Prosecutor General’s Office, after consultations with the Ministry of Foreign Affairs, will be able to give the information resource the status of “allowing censorship against Russian publications and broadcasters.” This will lead to sanctions: administrative fines, slowdown of Internet traffic and blocking.
• Federal Law No. 525-FZ of December 30, 2020, on Amendments to Article 330-1 of the Criminal Code of the Russian Federation came into force on March 1, 2021. It is related to the Federal Law No. 481-FZ of December 30, 2020, on Amendments to Certain Legislative Acts of the Russian Federation in terms of establishing additional measures to counter threats to national security. The law provides for the amendment of Article 330¹ of the Criminal code (Malicious evasion of obligations provided for by the legislation of the Russian Federation in connection with the recognition of a person as performing the functions of a foreign agent) and establishes criminal liability of natural persons, NCOs and media recognized as  FAs for violation of their obligations. It proposes the following punishment: a fine in the amount of up to 300 thousand rubles  or in the amount of the wage or salary, or any other income of the convicted person for a period of up to two years, or by compulsory works for a term of up to 480 hours, or by corrective labor for a term of up to two years, or by imprisonment for the same term. If a person was already punished for the violation in accordance with the CAO, he/she shall be punishable by a fine in the amount of up to 300 thousand rubles or in the amount of the wage or salary, or any other income of the convicted person for a period of up to two years, or by compulsory works for a term of up to 480 hours, or by compulsory labor for a term of up to five years, or by imprisonment for the same term. Due to a possible broad interpretation of the notion of “malicious evasion” it can lead to imprisonment of human rights defenders.
• Federal Law No. 530-FZ of December 30, 2020, on Amendments to the Federal Law on Information, Information Technologies and Information Protection (so called law on “censorship in social media”) came into force on February 1, 2021. The law introduces the concept of “the owner of a social network” on the Internet. It also provides for obligations for the owner of a social network, access to which during the day is more than 500 thousand users. In addition, the owner of the social network will have to independently monitor a number of types of illegal content. This list includes, in particular, the following categories of materials: information expressing clear disrespect for society, the state, its symbols and authorities; and information with calls for riots, participation in unauthorized public events, fake news, information and links to materials of undesirable organizations.
• Federal Law No. 538-FZ of December 30, 2020, on Amendments to Article 128-1 of the Criminal Code of the Russian Federation entered into force on January 10, 2021. The law broadens definition of “libel” crime, performed under aggravative circumstances, by including into it dissemination of knowingly false information made in public, “with the use of informational-telecommunications networks, including Internet”. It also substantially increases punishment for libel, adding to it prison term, up to 5 years. It expands definition of “libel” crime, which has already been very vague, and established cruel penalties for it.
• Federal Law No. 541-FZ of December 30, 2020, Amendments to the Federal Law on Assemblies, Rallies, Demonstrations, Processions and Picketing entered into force on January 10, 2021. The law provides for additional restrictions on fundraising for the preparation and holding of a public event. For example, its organizers will be prohibited from accepting funding from foreign states, organizations and citizens, NCOs-FAs, Russian citizens under 16 years of age, anonymous donors and legal entities registered less than a year before. According to the results of the campaign, its organizers will have to submit a report on the expenditure of funds to the authority with which the public event was coordinated. This law introduces new restrictions on foreign funding and NCOs-FAs activities.
• Federal law No. 14-FZ of February 24, 2021, on Amendments to the Code of Administrative Offenses of the Russian Federation proposes to expand the effect of Article 13.15 of CoAO, which provides for liability for abuse of freedom of the media. It is proposed to supplement this article with three new parts on responsibility for the dissemination of information, respectively, about an NCO, an unregistered public association, an individual included in the registries of organizations and individuals performing the functions of a foreign agent. It establishes identical penalties: “a fine for citizens in the amount of two thousand to two thousand five hundred rubles with or without confiscation of the subject of an administrative offense; on officials – from four thousand to five thousand rubles with or without confiscation of the subject of an administrative offense; for legal entities – from forty thousand to fifty thousand rubles with or without confiscation of the subject of an administrative offense. It is also proposed to supplement CoAO with new Articles 19.7.5-3 and 19.7.5-4, which establish administrative liability for violation of the procedure for the activities of a public association operating without acquiring the rights of a legal entity (unregistered public association) and violation of obligations by an individual acting as a foreign agent. This law is related to the adopted Federal Law of December 30, 2020 No. 481-FZ on Amendments to Certain Legislative Acts of the Russian Federation in terms of establishing additional measures to counter threats to national security and entered into force on March 1, 2021.
• Federal law No. 24-FZ of February 24, 2021, on Amendments to the Code of Administrative Offenses of the Russian Federation provides for increasing liability for violations in the preparation and conduct of public events, stipulating fines from 2 thousand to 4 thousand rubles for disobedience to the police orders. Repeated offences would result in fines from 10 thousand to 20 thousand rubles. Moreover, community service is envisaged as an alternative punishment for such violations. This law entered into force on March 7, 2021.
• Federal law No. 75-FZ of April 5, 2021, on Amendments to the Federal Law on Non-Commercial Organizations extends the concept of foreign sources, prohibits registration of structural units of foreign NCOs in households, introduces additional basis for unscheduled inspections and obliges NCOs-FAs and their units to submit programs and documents constituting grounds for running events and performance report to the MoJ. The law came into force on October 3, 2021.
• Federal law No. 85-FZ of April 5, 2021, on Amendments to the Federal Law on Education in the Russian Federation proposes to amend the law on education by introducing into it the concept of “educational outreach activities”, which will be prohibited from being conducted outside the framework established by the federal government. This new notion of “educational outreach activities” has a vast definition. According to the law, any seminars, round tables, trainings and similar events can be classified as educational activities. The law is very dangerous for NCOs conducting all sorts of trainings. There is a threat that they may lose the opportunity to include in charters and carry out any educational activities. Besides, the adopted law contains a large number of terms that are not defined in the legislation, which may lead to a broad and possibly restrictive interpretation of the concept of educational activities by state bodies. The law entered into force on June 1, 2021. As for implementing regulations, the Decree of the Government of the Russian Federation of July 1, 2022 No. 1195 on approval of the Rules for the implementation of educational activities was adopted a year later.
• Decree of the Government of the Russian Federation of April 19, 2021 No. 617 on the Establishment of Limit Values for the Average Number of Employees and the Amount of Income of Non-Commercial Organizations in order to extend to them the specifics of regulation of labor relations and other relations directly related to them established by Chapter 48.1 of the Labor Code of the Russian Federation” and Decree of the Government of the Russian Federation of April 19, 2021 No. 618 on Amending the Decree of the Government of the Russian Federation of August 27, 2016 No. 858. Both Decrees of the Government develop the legislative norms introduced in December 2020 on the ability of NCOs to conclude fixed-term employment contracts and approve the standard form of a fixed-term employment contract, i.e., simplify the workflow of a significant number of NCOs in terms of personnel documents and reduce their costs. Decrees entered into force on April 21, 2021.
• Federal Law No. 91-FZ of April 20, 2021, on Amendments to Certain Legislative Acts of the Russian Federation provides for restricting parliamentary candidates who have been identified as FAs or persons affiliated with them. This law introduces two new notions into the electoral legislation: “a candidate affiliated with a person acting as a foreign agent” and “a candidate who is a natural person – a foreign agent.” The first notion designates a candidate for an elective position who, two years before the election, worked in an NCO-FA or in a FM-FA, or, carrying out political activities, received funds from NCOs or individuals who are FAs (including through intermediaries). The second notion refers to those who are included in the list of individuals who perform the functions of FAs. Now candidates will be required to indicate when communicating with government agencies and in campaign materials that they receive funding from abroad. Information on the status of a FA or affiliation with him should occupy at least 15% of the area of campaign materials and subscription lists. Affiliation with a FA is recognized if the candidate was a member of an NCO-FA or an unregistered public association, was an employee or founder of a FM-FA (including its representative office in Russia). In addition, persons who receive funding or property from FAs for conducting political activity will be also considered affiliated. Candidates included in the Registry of FM-FAs, or nominated by an electoral association are required to report about their status. Individuals are included in the registry of FAs are now required to indicate their status when making donations to the electoral fund. The law entered into force on April 20, 2021.
• Federal Law No. 102-FZ of April 30, 2021, on Amendments to the Code of Administrative Offenses of the Russian Federation provides for amendments to Article 13.15 of the Code of Administrative Offenses (CoAO), which introduced administrative liability for abuse of freedom of the media, namely, a new part 2.4 was added, according to which the composition of an administrative offense forms distribution in the media, in messages and other information and telecommunication networks of messages and (or) materials of a foreign media outlet performing the functions of a foreign agent (FM-FA) and (or) a Russian legal entity included in the Registry of FM-FAs, without indicating that these messages and (or) materials were created and (or) disseminated by FM-FA, and (or) a Russian legal entity included in the Registry of FM-FAs. The penalty for this administrative offense is a fine for citizens in the amount of 2 thousand to 2,500 rubles; for officials – from 4,000 to 5 thousand rubles; for legal entities – from 40 thousand to 50 thousand rubles. The law came into force on May 11, 2021.
• Federal Law No. 104-FZ of April 30, 2021, on Amendments to Article 265 of Part Two of the Tax Code of the Russian Federation provides for the formation of a unified register of NCOs in order to increase the efficiency of measures for their state support and tax incentives (businesses donating funds to NCOs included in this register will reduce their taxes, within 1% of revenue, which will be attributed to non-operating expenses). In fact, two registries that existed in parallel will be merged: the SONCO register, which since 2017 have been recipients of grants or subsidies, public service providers, social service providers, and the register of NCOs most affected by the deterioration of the situation as a result of the spread of the new coronavirus infection. The law came into force on January 1, 2022.
• Federal Law No. 124-FZ of April 30, 2021, on Amendments to the Federal Law on Advertising provides for social advertising on the Internet. According to the law, a 5% quota is to be introduced with regard to the online placement of social advertising similar to the requirements already in force as to TV and banner advertisements. Before the adoption of this law the placement of social advertisements on the internet was carried out on the voluntary basis, NCOs were forced to draw attention to their activities on the same terms as commercial organizations. The adopted amendments are aimed at ensuring equal conditions for NCOs for the distribution of social advertising, for which an operator of social advertising will be determined by the government.
• Order of the Ministry of Justice of the Russian Federation of June 1, 2021 No. 92 on Approval of the Procedure for Maintaining the Registry of Unregistered Public Associations Performing the Functions of a Foreign Agent, the Procedure and Terms of Notification by a Public association Operating without Acquiring the Rights of a Legal Entity, on Receipt (Intention to Receive) Funds and (or) Other Property from Foreign Sources and on Participation (Intention to Participate) in Political Activities on the Territory of the Russian Federation and the Forms of Documents Submitted by the Public Association, included in the Registry of Unregistered Public Associations Performing the Functions of a Foreign Agent” (registered June 3, 2021 No. 63787). This Order came into force on June 14, 2021. The Order is a technical implementation of the norms introduced into the legislation on the extension to the activities of public associations that do not have the status of a legal entity, of provisions applicable exclusively to legal entities. Blurred and arbitrarily interpreted rules on the registration of unregistered public associations actually allow the MoJ to require the provision of information on the receipt of funds or other property from individuals, while the “connection” of these funds or other property with the activities of unregistered public associations in the overwhelming majority of cases is not obvious and unprovable.
• Federal Law No. 225-FZ of June 28, 2021, on Amendments to Part One of the Civil Code of the Russian Federation provides for the possibility of holding meetings in a remote form. According to the law, remote participation will require mandatory compliance with two conditions: reliable authentication of the participants and the properly expressed will of the participants. For NCOs, this means that they will be able to hold such meetings and submit documents to government agencies without fear of being rejected. The law came into force on July 1, 2021.
• Federal law No. 230-FZ of June 28, 2021, on Amendments to Article 6 of the Federal Law on Counteraction to Legalization (Laundering) of Criminally Obtained Incomes and Financing of Terrorism and Article 3-1 of the Federal Law on Measures of Affecting Persons Related to Violations of Basic Human Rights and Freedoms, Rights and Freedoms of Citizens of the Russian Federation provides for mandatory control over any financial transactions of NCOs, mandatory control over operations for receiving funds by individuals from payers from foreign countries included in the special list of the Central Bank and Rosfinmonitoring (not publicly available). The law also expands the list of grounds for recognizing the activities of foreign or international non-governmental organizations as “undesirable” in the Russian Federation – receipt of information about the provision of intermediary services by it when conducting transactions with monetary funds and (or) other property belonging to a foreign or international non-governmental organization, whose activities are recognized as undesirable in the territory of the Russian Federation, in order to carry out activities by such an organization that pose a threat to the foundations of the constitutional order, defense or security of the state. Citizens of the Russian Federation and Russian legal entities are prohibited from participating in the activities of an “undesirable” organizations outside the Russian Federation. Amendments regarding control over the transfer of any funds to NCOs from abroad came into force on October 1, 2021; amendments to “Dima Yakovlev” law came into force on July 9, 2021.
• Federal law No. 232-FZ of June 28, 2021, on Amendments to the Code of Administrative Offenses of the Russian Federation provides for strengthening administrative liability for illegal arms trafficking, abuse of freedom of the media and participation in the activities of “undesirable” organizations. The amendments have expanded the effect of Art. 20.33 of the CoAO, instead of “carrying out” the activities of “undesirable” organization in the territory of the Russian Federation, the composition of an administrative offense henceforth constitutes any participation in the activities of such an organization, including outside the Russian Federation. According Art. 20.33 of the CoAO the overwhelming majority of penalties are imposed on individuals. The law came into force on July 9, 2021.
• Order of the Ministry of Justice of the Russian Federation of June 28, 2021 No. 105 on the Form and Deadlines of Submission to the Ministry of Justice of the Russian Federation of Reports of Non-Commercial Organizations Performing the Functions of a Foreign Agent (registered on June 29, 2021 No. 64010) established new extended reporting forms for NCOs-FAs. The Order came into force on July 10, 2021.
• Order of the Ministry of Justice of the Russian Federation of June 28, 2021 No. 106 on Approval of the Documents Provided for in Article 2.1 of the Federal Law of December 28, 2012 No. 272-F3 on Measures of Affecting Persons Related to Violation of Basic Human Rights and Freedoms, Rights and Freedoms of the Citizens of the Russian Federation (registered on June 29, 2021 No. 64011) establishes the procedure for maintaining the list of individuals-FAs. The Order came into force on July 11, 2021.
• Order of the Ministry of Justice of the Russian Federation of June 28, 2021 No. 107 on Amending the Procedure for Maintaining the Registry of Non-Commercial Organizations Performing the Functions of a Foreign Agent, approved by Order of the Ministry of Justice of the Russian Federation No. 223 dated November 30, 2012, and Order of the Ministry of Justice of the Russian Federation of August 16, 2018 No. 170 on Approval of Reporting Forms for Non-Commercial Organizations (registered on June 29, 2021 No. 64012) approved new reporting forms for all NCOs and changed the procedure of maintaining the Registry o NCOs-FAs. The Order came into force on July 10, 2021.
• Federal Law No.236-FZ of July 1, 2021, on the Activities of Foreign Persons in the Information and Telecommunication Network Internet in the territory of the Russian Federation envisages that a foreign IT firm must open an office or an accredited legal entity in the Russian Federation, register its personal profile on the website of Roskomnadzor communications agency and publish electronic follow-up form for Russian citizens and organizations on its website. The law also contains measures of compulsion inducing IT giants to comply with Russian legislation, which include informing users of breaching of Russian laws by a resource, restriction of payments and funds transfer, search results ban, prohibition of collection and trans-border transfer of personal data, slowing of traffic or website blocking. The law came into force on July 1, 2021, with the exception of certain provisions for which other terms of entry into force are established.
• Federal Law No. 290-FZ of July 1, 2021, on Amendments to Article 4 of the Law of the Russian Federation on Media provides for the ban on the distribution of information in the media about the organization included in the published unified federal list of organizations, including foreign and international organizations recognized in accordance with the legislation of the Russian Federation terrorist, without specifying that they are eliminated or their activities are prohibited. Failures to comply with this requirement are to be punished with fines of up to 2,500 rubles imposed on journalists and up to 50 thousand rubles  imposed on the editorial boards of the media involved. The law entered into force on July 12, 2021.
• Federal Law No. 292-FZ of July 1, 2021, on Amendments to Article 284-1 of the Criminal Code of the Russian Federation completed Art. 284-1 of the Criminal Code which contained one corpus delicti – criminal liability for managing the activities of an “undesirable” organization in the territory of the Russian Federation, – with three separate corpus delicti: participation in any form in the activities of an “undesirable” organization, providing or collecting funds or providing financial services to such an organization, organization of its activities in the territory of the Russian Federation. The law, in particular, provides for imposing jail terms for fundraising for “undesirable” organizations. The violation will be punishable by compulsory labor for up to 360 hours, compulsory labor for up to four years with possible restraint of liberty for up to two years, and imprisonment for a term of one to five years. The law entered into force on July 12, 2021.
• Federal Law No. 323-FZ of July 2, 2021, on Amendments to Article 26 of the Federal Law on Banks and Banking Activities obliges credit institutions to provide the MoJ, upon its request, with access to financial documents of NCOs and information on transactions and accounts of NCOs, which constitutes bank secrecy (except for religious organizations). Despite the stipulation in the law of the obligation of the MoJ not to disclose information constituting bank secrets, there are very serious fears of leakage of this information or its use in order to put pressure on NCOs. The law came into force on July 13, 2021.
• Federal law No. 352-FZ of July 2, 2021, on Amendments to Certain Legislative Acts of the Russian Federation amended the procedure for NCOs-FAs’ submission of auditor’s report as part of their reporting. Changes have been made to Art. 32 of the Federal Law of January 12, 1996 No. 7-FZ on Non-Commercial Organizations, according to which an NCO-FA will have to post an audit report on the state information resource of accounting (financial) statements – https://bo.nalog.ru/, which is administered by the Federal Tax Service. After that, NCO-FA will only have to send to the MoJ information confirming the submission of an audit report on this resource. And the MoJ will receive all the information it needs using a unified system of interdepartmental electronic interaction. This law entered into force on January 1, 2022.
• Decree of the Government of the Russian Federation of July 30, 2021 No. 1290 on the Registry of Socially Oriented Non-Commercial Organizations was developed in compliance with previously adopted legislative changes, in accordance with which two registries will be united into a single registry, which were previously maintained in parallel: registry of SONCOs, which since 2017 have been recipients of grants provided by the President of the Russian Federation or recipients of subsidies and grants from federal and regional executive authorities; and the registry of NCOs most affected by the deteriorating situation as a result of the spread of the new coronavirus infection. The Decree entered into force on January 1, 2022.
• Decree of the Government of the Russian Federation of August 17, 2021 No. 1363 on the Approval of the Regulations on the procedure and deadlines for the submission by structural units of foreign non-profit non-governmental organizations of programs and other documents declared for implementation and being implemented on the territory of the Russian Federation, which are the basis for carrying out activities, as well as a report on implementation programs and execution of other documents that are the basis for events establishes the procedure and deadlines for submitting to the MoJ of information about the planned and ongoing programs of the structural units of the FNCO. The Decree is aimed at the technical implementation of the previously adopted legislative changes, which significantly increased the amount of information submitted by the affiliate and representative offices of FNCOs to the MoJ. The Decree entered into force on October 3, 2021.
• Order of the Federal Security Service of the Russian Federation of September 28, 2021 No. 379 on Approval of the List of Information in the field of Military, Military-Technical Activities of the Russian Federation, which, when Received by a Foreign State, its State Bodies, an International or Foreign Organization, Foreign Citizens or Stateless Persons Can Be Used against the Security of the Russian Federation approved a list of 60 items of information in the field of military and military-technical activities, the collection of which (provided that these actions are carried out in the interests of foreign sources, and with the provision of appropriate support) is the basis for recognizing an individual as performing the functions of a foreign agent and including this individuals persons in the corresponding registry, which is maintained by the MoJ. A number of wordings used in this Order are vague, which creates additional risks for individuals (primarily journalists) of being recognized as performing the functions of a foreign agent, for example, covering military corruption news becomes grounds for ‘foreign agent’ status. The Order entered into force on October 11, 2021.
• Order of the Ministry of Justice of the Russian Federation of September 30, 2021 No. 184 on the Forms and Deadlines of Submission to the Ministry of Justice of the Russian Federation of Reports of Non-Commercial Organizations Performing the Functions of a Foreign Agent significantly changed the reporting forms of NCOs-FAs, considerably increasing the amount of information included in the reporting. For example, instead of one reporting form ОИА001, seven new forms have been introduced, which, in particular, include not only information about the activities of NCOs-FAs in the reporting year, but also information about the governing bodies and employees; information on the expenditure of funds received from Russian legal entities, the beneficial owners of which are foreign citizens or stateless persons, and the use of other property that was previously absent. A new reporting form (ОИА005) is being introduced, in which it will be necessary to reflect information about ongoing programs, other documents that are the basis for activities. It will be necessary to include in the report basic information about the programs, for example, the name, date of approval, goals, stages, timing, territory of implementation, as well as the strategy and special conditions for implementation, the amount of funding and actual costs. The report on the conducted events will now be filled out in a separate ОИА006 form, which contains information about the full address of the venue for each event, as well as a list of event participants (so far only surname, name and patronymic), and/or its counterparties. Another innovation is the event spending report, which includes: information about the funds spent on a specific event, indicating the type of spending and the document-basis for the transfer of funds (including its name and date); and information about the actual use of other property: the name of the object of civil rights, the method of its use and the document-basis on which such use became possible. According to the ОИА007 reporting form, it will be necessary to provide information on the activities that were provided for by the program or other documents, but were not carried out in the reporting period. It will be necessary to indicate the name of the document (name of the program), which provided for the activities, and the date of sending information about the planned activities to the MoJ. Totally there are seven deadlines for submitting these reporting forms, which complicate the already difficult reporting of NCOs-FAs. The Order entered into force on March 1, 2022.
• Order of the Ministry of Justice of the Russian Federation of September 30, 2021 No. 185 on the Forms and Deadlines of Submission of Reports of Non-Commercial Organizations to the Ministry of Justice of the Russian Federation increased the volume of information included in the reporting forms of NCOs and structural units of FNCOs. of foreign non-profit non-governmental organizations. For example, NCOs will now have to provide information on the spending of funds received from Russian organizations, the beneficiaries of which are foreigners. Beneficiary owner means an individual who ultimately directly or indirectly (through third parties) owns (has a predominant participation of more than 25 percent in the capital) a legal entity or has the ability to control its actions. An additional line appears in the OH0001 reporting form that reflects information on targeted funding from citizens of the Russian Federation or Russian legal entities acting as intermediaries in the receipt of property by NCOs from foreign states, their state bodies, international and foreign organizations, foreign citizens, stateless persons or authorized persons. FNCO reporting is also increased, for example, to the reporting on the amount and sources of funds and other property, their planned distribution and purposes of spending (form СП0001), sheets have been added, in which it will be necessary to report on various sources of receipt of funds and other property separately: from Russian citizens, from foreign states and their bodies, from foreign and international organizations, from foreign citizens, and from authorized persons. In addition, information about the declared programs (СП0003 form) is supplemented with new sections (the same sections appear in the forms ОИА004, ОИА005, and ОИА006), for example, section 5 “Strategy of the implemented program”, section 8 “Program implementation mechanism” appears. Information on ongoing programs (form СП0004) is a new form and contains, for example, such innovations as section 9 “Special conditions for the implementation of the program”, section 10 “Target Indicators”, sections 11 and 12, respectively, “Intended and ongoing activities”, section 13 “Participants of the ongoing program”. Information on the holding of events (form СП0005) contains a fork: if the events were not held, a check mark is enough, if they were conducted, then sheet A is filled in for each conducted: title, date of the event, address of the place where it was held. The Order enterd into force on March 1, 2022.
• Federal Law № 377-FZ of November 22, 2021, on Amendments to the Labor Code of the Russian Federation came into force on November 22, 2021 (with the exception of certain provisions on uniform requirements for electronic documents, which take effect on March 1, 2023). On the one hand, the adopted legislative changes are positive, as they will allow organizations to reduce paper workflow (most of it can be stored in digital format). At the same time, there are fears that small organizations will not be able to afford the establishment and maintenance of their own electronic storage system, therefore, they will use the “Work in the Russian Federation” service. Thus, the state will have complete information on each employee’s responsibilities and activities.
• Federal Law № 423-FZ of December 21, 2021, on Amendments to Certain Legislative Acts of the Russian Federation took effect on March 22, 2022. Law № 115-FZ introduced a new definition of a “suspicious transaction,” which is a transaction with cash or other property, allegedly carried out for the purpose of legalization (laundering) of proceeds from crime, financing of terrorism. The functions of the Central Bank of the Russian Federation have been expanded (Article 4 of Law № 86-FZ), so it has the authority to assess the level of risk of conducting suspicious transactions of any legal entity or individual entrepreneur registered in Russia with an open bank account. The only exceptions are credit institutions, state bodies, and local governments. At the same time, in accordance with the amendments, banks will be required to conduct an independent assessment of each client. It is difficult to predict how the introduction of the new order will affect the activities of NCOs in Russia. As recent practice shows, in general, NCOs fell into the category of medium risk (there are categories of low and high risk, in which the organization cannot operate, with some exceptions). This category implies additional attention to them by banks and an increased, in comparison with the low category, the risk of refusal to operate or the risk of the bank requesting documents on the activities of NCOs. In general, so far this has not had a negative impact on the sector.
• Federal law No. 468-FZ of December 30, 2021, on Amending the Code of Administrative Offences proposes to supplement the provisions of the CoAO with Art. 6.34 “Violation of the rules for the installation and use of boxes for collecting donations”. The law introduces differentiated liability depending on the subject of the violation: either the violation was committed by a person who has the right to use the box, or by another person who does not have such a right. Installation and use of a box for collecting charitable donations on behalf of an NCO by a person who does not have the right to carry out this activity will entail a fine for citizens in the amount of 3 thousand to 5 thousand rubles, for officials – from 20 thousand to 50 thousand rubles , for legal entities – from 50 thousand to 150 thousand rubles. In all cases, the box will be confiscated. Installation and use of the box by an organization that has the right to do so, in violation of the requirements established by law, will entail a fine for officials in the amount of 5 thousand to 10 thousand rubles, for legal entities – from 10 thousand to 50 thousand. The box can also be confiscated. The law entered into force on February 28, 2022.
• Order of the Ministry of Justice of the Russian Federation dated December 30, 2021 No. 274 “On Approval of the Administrative Regulations for the implementation by the Ministry of Justice of the Russian Federation of state control (supervision) over the compliance of the activities of non-commercial organizations with the statutory goals and objectives, affiliate and representative offices of international organizations, foreign non-profit non-governmental organizations with the stated goals and objectives , as well as their compliance with the legislation of the Russian Federation” entered into force on January 11, 2022 The new Administrative Regulations makes it possible to request a large number of additional documents from the governing bodies of an NCO or FNGO (for example, documents on the website of a non-profit organization, publications in the media, including on the Internet) and increases the time for state inspection up to 45 days (previously 30 days).
• List of instructions of the President of the Russian Federation following the meeting of the Presidential Council for the Development of Civil Society and Human Rights, held on December 9, 2021 was published on January 27, 2022, a. In particular, Item 9 of the list of instructions provides that until May 1, 2022, the MoJ was instructed to: analyze, together with the Prosecutor’s General Office (PGO) and the Council under the President of the Russian Federation for the Development of Civil Society and Human Rights, the legislation of the Russian Federation on the regulation of the activities of NCOs-FAs, including with regard to their exclusion from the Registry of relevant organizations, and practice its application. If necessary, to submit proposals for improving the legislation of the Russian Federation; to analyze together with the Federal Service for Supervision in the Sphere of Telecom, Information Technologies and Mass Communications (Roskomnadzor) and with the participation of the Council under the President of the Russian Federation for the Development of Civil Society and Human Rights and the All-Russian Public organization “Union of Journalists” the provisions of the Russian legislation on the regulation of the activities of the media, performing the functions of a foreign agent, and the practice of its application. If necessary, submit proposals for improving the legislation of the Russian Federation.
• Decree on the Application of Special Economic Measures in connection with the unfriendly actions of the United States and Foreign States and International Organizations that have joined them was signed by the president on February 28, 2022. The Decree is related, in particular, to the mandatory sale of a portion of the foreign currency received by participants in foreign economic activity; prohibition of foreign exchange transactions involving residents providing non-residents with foreign currency under loan agreements; prohibition of residents crediting foreign currency to their accounts opened with banks or organizations abroad, or transferring money without opening a bank account by using electronic payment options provided by foreign payment service providers. In addition, the Order defined the terms and conditions under which companies may purchase their outstanding shares (except for the acquisition of outstanding shares in order to reduce their total number). Since then, foreign funding of NCOs was practically suspended.

• Federal law No. 30-FZ of March 4, 2022, on Amendments to the Federal Law on Measures of Influence on Persons Involved in Violations of Fundamental Human Rights and Freedoms, Rights and Freedoms of Citizens of the Russian Federation and Article 27 of the Federal Law on the Procedure for Leaving the Russian Federation and entry into the Russian Federation entered into force on March 15, 2022. The law proposes to expand the possibility of applying the measures of influence provided for by Federal Law No. 272-FZ on all foreign citizens and stateless persons, and not only on US citizens, as provided for in the previous edition. Namely it provides, in particular, for the following: The list of foreign citizens and stateless persons against whom enforcement measures are applied is maintained by the Ministry of Foreign Affairs. In relation to such foreign citizens and stateless persons: 1) a ban is established on the disposal of property located on the territory of the RF; 2) activities in the territory of the  RF of legal entities under their control are suspended; 3) authorities (membership) in the boards of directors or other management bodies of organizations registered in the territory of the RF are suspended. Correlating changes in terms of the prohibition of entry into the territory of the Russian Federation for foreign citizens and stateless persons were also introduced into the Federal Law of August 15, 1996 No. 114-FZ on the Procedure for Leaving the  RF and entering the RF. The adopted amendments apply only to NCOs whose management bodies include foreign citizens or stateless persons.On March 4, two Federal laws providing for administrative and criminal liability for public actions “aimed at discrediting Russia’s Armed Forces” were signed (Federal Law No. 31-FZ of March 4, 2022, on Amendments to the Code of Administrative Offenses of the Russian Federation and Federal Law No. 32-FZ of March 4, 2022, on Amendments to the Criminal Code of the Russian Federation and Articles 31 and 151 of the Code of Criminal Procedure of the Russian Federation). These laws entered into force on March 4, 2022. According to the Federal law No.31-FZ, two new articles 20.3-3 and 20.3-4 were introduced into the CoAO – public actions aimed at discrediting the use of the Russian Armed Forces in order to protect the interests of the Russian Federation and its citizens, to maintain international peace and security; and appeals for the introduction of restrictive measures against Russia, Russian citizens or legal entities. These articles provide for a fine on citizens in the amount of 30 thousand to 50 thousand rubles; for officials – from 100 thousand to 200 thousand rubles; for legal entities – from 300 thousand to 500 thousand rubles. The same actions, accompanied by calls for unauthorized public events, as well as creating a threat of harm, are punished more severely: a fine for citizens in the amount of 50 thousand to 100 thoustand rubles; for officials – from 200 thousand to 300 thousand rubles; for legal entities – from 500 thousand to 1,000,000 rubles.  articles: Article 207.3. Public dissemination of deliberately false information about the use of the Armed Forces of the Russian Federation (fine in the amount of 700 thousand to 1,5 million rubles or imprisonment for up to 3 years). The same act committed by a person using his official position; a group of persons, a group of persons by prior agreement or an organized group; with the artificial creation of evidence for the prosecution; from interested motives; motivated by political, ideological, racial, national or religious hatred or enmity, or motivated by hatred or enmity against any social group, is punishable by a fine in the amount of 3-5 million rubles or in the amount of the wage or other income of the convicted person for the period from 3 to 5 years, or by forced labor for up to 5 years with deprivation of the right to hold certain positions or engage in certain activities for up to five years, or by imprisonment for a term of 5 to 10 years with deprivation of the right to hold certain positions or engage in certain activities for up to five years; Article 280.3. Public actions aimed at discrediting the use of the Armed Forces of the Russian Federation in order to protect the interests of Russia and its citizens, maintain international peace and security (a fine of 100 thousand to 300 thousand rubles or imprisonment for up to 3 years with deprivation of the right to occupy certain positions or engage in certain activities for the same period). Public actions resulting in death by negligence and (or) causing harm to the health of citizens, property, mass violations of public order and (or) public safety, or interfering with the functioning or cessation of functioning of life support facilities, transport or social infrastructure, credit organizations, energy facilities, industry or connections, shall be punishable by a fine in the amount of 300 thousand to 1 million rubles, or in the amount of the wage or salary, or any other income of the convicted person for a period of 3 to 5 years, or by deprivation of liberty for a term of up to 5 years, with deprivation of the right to hold certain positions or engage in certain activities for that period. same term; and Article 284.2. Appeals for the introduction of restrictive measures against Russia, Russian citizens or legal entities after bringing to administrative responsibility for a similar act within one year, shall be punishable by a fine in the amount of up to 500 thousand rubles, or in the amount of the wage or salary, or any other income of the convicted person for a period of up to 3 years, or by restraint of liberty for a term of up to 3 years, or by compulsory labor for a term of up to 3 years, or by arrest for a term of up to 6 months, or by deprivation of liberty for a term of up to 3 years, with or without a fine in the amount of up to 200thousand rubles or in the amount of the salary or other income of the convicted person for a period of up to one year. Though not directly related to NCOs, it means introduction of severe censorship of all media and social networks, many activists and human rights defenders began to be punished under these laws almost immediately.
• Federal Law No. 35-FZ of March 6, 2022, on Amendments to Articles 14 and 14-2 of the Federal Law on the National Payment System and Articles 1-1 and 4-7 of the Federal Law on the Use of Cash Registers in the Implementation of settlements in the Russian Federation entered into force on September 3, 2022. In accordance with the amendment provided for by this law, legal entities, and in particular NCOs, will be able to deposit funds to their current account using ATMs. These changes create additional opportunities for NCOs and simplify the procedure for depositing cash into a current account.
• Federal Law No. 36-FZ of March 6, 2022, on Amendments to the Federal Law on the Procedure for the Formation and Use of Endowments of Non-Commercial Organizations proposes to expand the list of assets in which it is possible to invest funds that make up the endowment of an NCO, as well as to increase the share of endowment capital that is allowed to be spent on trust management expenses. This law does not change much directly for NCOs, but it fixes a number of advantages for management companies. The law entered into force on March 17, 2022.
• Decree of the Government of the Russian Federation of March 10, 2022, No. 336 on the Specifics of the Organization and Implementation of State Control (Supervision), Municipal Control canceled scheduled inspections in 2022, unless the objects of control are categorized as extremely high and high risk. Unscheduled inspections by the MoJ of the NCOs; activities in 2022 were possible for most of the reasons provided for in clause 4.2 of Art. 32 of the Federal Law of January 12, 1996 No. 7-FZ on Non-Commercial Organizations, but with a notification from the prosecution authorities. This Decree had a positive impact on the activities of NCOs, since in a difficult economic situation, the cancellation of scheduled inspections will not deprive NCOs of resources to prepare for them, eliminate identified violations and pay possible fines.
• Federal Law No. 60-FZ of March 14, 2022, on Amendments to Certain Legislative Acts of the Russian Federation entered into force immediately after publication. As a draft law, it was related to digital electronic voting, but for the second reading it was completed with amendments related to “unified registry of individuals – FAs.” In accordance with the adopted law, a “unified registry of information on individuals performing the functions of a foreign agent or affiliated with persons performing the functions of a foreign agent” will be created, is proposed to include in it individuals, both already included in other registries of FAs, and individuals, who were not previously included in them, namely: any individuals who have ever been founders, members, participants, managers, members of management bodies, employees of NCOs-FAs, UPAs-FAs, FM-FAs (and Russian legal entities created by them), as well as individuals who have ever received money and (or) other property assistance from them. The law can be considered as extremely negative, since the wordings used in the text of the law are vague and actually allow inclusion in the “unified registry” only on the formal basis of legal relations with the listed organizations, regardless of their nature and duration.
• On March 25, two Federal laws providing for administrative and criminal liability for public actions “aimed at discrediting agencies representing Russia’s interests abroad” were signed (Federal Law No. 62-FZ of March 25, 2022, on Amendments to Articles 8.32 and 20.3-3 of the Code of Administrative Offenses of the Russian Federation and Federal Law No. 63-FZ of March 25, 2022, on Amendments to the Criminal Code of the Russian Federation and Articles 150 and 151 of the Code of Criminal Procedure of the Russian Federation). It should be noted that the above amendments were made to the second reading of the draft laws on another topic: the Criminal Code was proposed to be completed with the norms clarifying responsibility for the destruction or damage of forest plantations, adopted in the first reading on January 25, 2022. A new draft law with amendments to the Criminal Code according to the regulations can be submitted to the State Duma only with the feedback of the Supreme Court and the government, while amendments to the second reading avoids this process. The above laws extended Article 20.3-3 of the CoAO and 207.3 of the Criminal Code to cover cases of discrediting the exercise of the powers of Russian state bodies outside the territory of the Russian Federation. Though not directly related to NCOs, it means further intensification of severe censorship of all media and social networks, as up to 15 years will be threatened for false information about agencies representing Russia’s interests abroad.
• Federal Law No. 70-FZ of March 26, 2022, on Amendments to the Code of Administrative Offenses of the Russian Federation entered into force on April 6, 2022 and is overwhelmingly positive, as it significantly reduced fines for NCOs for committing administrative offenses. The adopted law introduced into the CoAO the norms on the mandatory replacement of a fine with a warning for an offense committed by an NCO for the first time, reduction in the amount of fines, a ban on simultaneously bringing an NCO and its head to administrative responsibility, and a ban on summing fines for several simultaneously identified administrative offenses of an NCO.
• Federal law No. 89-FZ of April 1, 2022, on Amendments to Articles 6 and 7 of the Federal law on National-Cultural Autonomy entered into force on April 12, 2022. The law changed the procedure for the formation and maintenance of the register of national-cultural autonomies (NCA): the functions of maintaining this register were transferred from the MoJ to the Federal Agency for Nationalities Affairs (FADN). The procedure for maintaining the register and the composition of the information included in it will be determined by a decree of the government, information in the FADN for maintaining the register will be provided by the MoJ. It is possible to assess the positive or negative nature of the changes made only after the adoption of all necessary by-laws and the application of their norms in practice. Formally, no new duties are imposed on the NCAs, and the previously existing procedure for their registration and control of activities does not change.
• Decree of the Government of the Russian Federation of July 1, 2022, No. 1195 on Approval of the Rules for the Implementation of Educational Outreach Activities was adopted in accordance with Part 3 of Article 12 of the Federal Law on Education in the Russian Federation. In accordance with this law, educational activity is an activity carried out outside the framework of educational programs aimed at spreading knowledge, skills, values, experience and competence for the purposes of intellectual, spiritual, moral, creative, physical and (or) professional development of a person, satisfaction of his educational needs and interests, affecting relations regulated by Federal Law on Education and other legislative acts of the RF. The Decree establishes the procedure, conditions and forms for the implementation of educational outreach activities. It also defines the forms of educational outreach activity, the requirements for the person carrying it out and for educational programs, as well as procedure of conducting control over educational outreach activities executed by the Ministry of Public Education (MPE). The forms of educational activities are defined as follows: lectures, presentations, seminars, master classes, round tables, discussions and other forms, including using the information and Internet telecommunication network, i.e. any public dissemination of information. The Decree provides for additional requirements for certain persons, namely: 1) The messages and materials of the organizer of educational activities included in the FA Registries distributed in the territory of the RF are accompanied by an indication that these messages and materials were created and (or) distributed by a person performing the functions of a foreign agent. The text of the instruction will be determined by the MPE. 2) The organizer of educational outreach activities, carrying out educational outreach activities in relation to minors and with the involvement of funds from the budgets of the budgetary system of the RF, notifies the MPE about the planned implementation of educational outreach activities by preparing and presenting an educational program no later than 30 working days before the expected start date of its implementation. The form and procedure for sending such notification will be determined by the authorized federal executive authority. The program of educational activities must reflect the goals, objectives, terms, forms and place of its implementation, target audience, information about the organizer of educational outreach activities and persons participating in the implementation of the program, sources of financing of the program in the amount of information determined by the authorized federal executive body. The submitted documents can be sent for examination, in case of a discrepancy between the requirements or a violation of the law, no later than 5 days before the start of the program, the MPE returns the documents and requires revision or goes to court in connection with a violation of criminal or administrative law. The rules for the implementation of educational activities do not apply to cultural and educational outreach activities of religious organizations; educational outreach activities of teaching staff of educational organizations in the framework of their official duties in relation to the students of these organizations, their parents (legal representatives). Control over the implementation of educational outreach activities is carried out by the MPE without interaction with the organizer of educational outreach activities, so the organization may not be aware of the conduct of control measures.
• Two Federal laws on the exclusion from the Russian legislation of the norms concerning the possibility of applying to the European Court of Human Rights and the execution of its decisions were signed on July 11, 2022 (Federal Law No. 183-FZ of June 11, 2022, on Amending Certain Legislative Acts of the Russian Federation and Recognizing Certain Provisions of Legislative Acts of the Russian Federation as Invalid and Federal Law No. 180-FZ of June 11, 2022, on Amendments to the Code of Criminal Procedure of the Russian Federation). These laws amended a number of laws of the Russian Federation, excluding the rules on the representation of the Russian Federation in the European Court of Human Rights (ECtHR), guarantees of the right of suspects, accused and convicted persons to apply to the ECtHR, as well as on the accounting and enforcement of decisions of the ECtHR, including when the courts review decisions and sentences. As a result of the adoption of the law: the activities of the ECtHR, its decisions and established practice will in no way be taken into account by the Russian judicial system when making or reviewing decisions and sentences; compensation awarded by the ECtHR cannot be paid; and suspected, accused or convicted persons who are in investigative or correctional institutions cannot be granted meetings with defense lawyers in connection with an application to the ECtHR. Listed here are the changes in specific laws: 1) The provisions on ensuring by the Prosecutor General’s Office the representation and protection of the interests of the Russian Federation in the ECtHR have been excluded from the Federal Law of January 17, 1992 No. 2202-1 on the Prosecutor’s Office of the Russian Federation. 2) The provision on granting suspects and accused persons, on the basis of written permission of the person or body in charge of the criminal case, meetings with their representatives to the ECtHR and persons providing them with legal assistance in connection with the intention to apply to the ECtHR, is excluded from the Federal Law of July 15, 1995 No. 103-FZ on the Detention of Suspects and Accused of Committing Crimes. Also, provisions on the possibility of sending proposals, complaints and applications to the ECtHR by suspects and accused persons are excluded from this law. 3) The provisions on the transfer of proposals, petitions and complaints to the ECtHR of persons sentenced to arrest, detention in a disciplinary military unit, deprivation of liberty, the death penalty, as well as the provisions on providing convicts (including convicted military personnel) meetings with representatives of the ECtHR, persons providing legal assistance to convicts in connection with the intention to apply to the ECtHR are excluded from the Criminal Executive Code of the Russian Federation. 4) The provision that the amount of compensation is determined by the court taking into account the practice of the ECtHR is excluded from the Federal Law No. 68-FZ of April 30, 2010 on Compensation for Violation of the Right to Legal Proceedings within a Reasonable Time or the Right to Enforce a Judicial Act within a Reasonable Time. 5) The provision that the reasoning part of the court decision should contain references to the rulings and decisions of the ECtHR has been excluded from the Code of Administrative Procedure of the RF. 6) In the Arbitration Procedure Code of the Russian Federation and the Civil Procedure Code of the Russian Federation, from the list of new circumstances that are the basis for the review of judicial acts and decisions, the violation of the provisions of the Convention for the Protection of Human Rights and Fundamental Freedoms established by the ECtHR when considering a specific case by the court is excluded, in connection with the adoption of a decision on which the applicant applied to the ECtHR. 7) The norms on the revision of the sentence, ruling and court decision that have entered into force in connection with the violation of the provisions of the Convention on the Protection of Human Rights and Fundamental Freedoms established by the ECHR when considering a criminal case by the court of the  RF are excluded from the Criminal Procedure Code of the RF. 8) The rulings of the ECtHR, which entered into force after March 15, 2022, are not enforceable in the Russian Federation. 9) Payment of monetary compensation under the ECtHR resolutions, which entered into force before March 15, 2022 inclusive, is made exclusively in rubles to accounts in Russian credit institutions and cannot be made to accounts in foreign credit institutions located in foreign countries that commit unfriendly actions against the RF. 10) The law contains a reservation that, in order to enforce the rulings of the ECtHR, which entered into force until March 15, 2022 inclusive, the excluded legislative norms may continue to be applied by the courts. Both Federal laws entered into force on June 11, 2022, with the exception of certain provisions concerning the payment of compensation by the Prosecutor General’s Office, which came into force on January 1, 2023.
• On July 14, a series of Federal laws related to all Russian legal entities and individuals was signed, their character can be determined as neutral, but they present certain difficulties during re-adaptation period for everybody, specifically: A package of seven Federal laws related to the merger of two funds – the Pension Fund of the  RF and the Social Insurance Fund – into a single Fund of Pension and Social Insurance of the RF. The main laws of the package are: Federal law No. 236-FZ of July 14, 2022, on the Pension and Social Insurance Fund of the Russian Federation (entered into force on July 14, 2022 with the exception of certain provisions that entered into force on January 1, 2023); Federal Law No. 238-FZ of July 14, 2022, on Amendments to the Code of Administrative Offenses of the Russian Federation (entered into force on January 1, 2023); and Federal law No. 240-FZ of July 14, 2022, on Amendments to the Labor Code of the Russian Federation (entered into force on January 1, 2023). For NCOs, as well as for all other legal entities, the difficulty is the need to rebuild the already established mechanisms for interaction with non-budgetary funds, to understand the new differences between an employment contract and a civil law contract, with the taxation of payments by insurance premiums, and new reporting.
• Federal Law No. 255-FZ of July 14, 2022, on Control over Activities of Persons Under Foreign Influence entered into force on December 1, 2022. The Law significantly worsened the regulation of FAs and created new grounds for including persons (including legal entities) in the registries of FAs. All provisions on FAs in other laws cease to have effect at the time of the Law coming into effect. The main changes to the current legislation on FAs provided for by the Law are the following: 1) Russian and foreign commercial legal entities will be added to the list of persons (including entities) that can be assigned the status of a FA. Up to December 1, 2022, Russian commercial organizations, such as limited liability companies (LLCs), couldn’t be recognized as FAs as well as foreign legal entities. As a result of the adoption of the Law, any individual or legal entity, with the exception of Russian state ones, may be recognized as a FA. 2) New registry of “affiliated” persons is to be created. A person affiliated with a FA is defined as a person who is (was) a member of the governing body of legal entity-FA (or unregistered public association-FA) and /or its founder, member, participant, manager or staff, who carries political activity and receives assets from a FA, including through intermediary, for the purpose of carrying political activity. There are no requirements for “affiliated” persons. 3) List of foreign sources is expanded to include foreign structures without legal entity status (probably affiliate and representative offices of foreign legal entities and projects of specific organizations). 4) Recognition as a FA will no longer require foreign funding. “Being under foreign influence” is enough to be recognized as a FA. A new definition of the concept of “foreign influence” was introduced: “providing support from a foreign source to a person and (or) influencing a person, including by coercion, persuasion and (or) in other ways,” which will cause any legal entity and individual to be assigned the status of FAs. Before the adoption of this law, the narrower definition of this term applies only to individuals, but not to the media, NCOs and others. 5) In addition to the existing prohibitions and restrictions for FAs, the Law proposed to introduce new ones: prohibition to take part in the activities of commissions, committees, consultative, advisory, expert and other bodies formed under public authorities; prohibition to carry out teaching, educational and educational outreach activities to minors; prohibition of release of information products for minors; prohibition to act as a supplier (contractor, implementor) in the procurement of goods, works, services to meet state or municipal needs; ban on receiving state financial support; ban on insurance of funds invested by FAs (with the exception of individuals) or in their favor; ineligibility to apply the simplified taxation system; ineligibility to apply simplified accounting (financial) statements; and prohibition of investing in business entities of strategic importance that ensure the defense of the country and the security of the state. Of this list, the most financially significant is the ban on the use of the simplified taxation system. Most LLCs created by activists after the liquidation of NCOs are using a simplified taxation system. For them, recognition of an LLC as a FA means paying a much higher tax (20% income tax and 20% VAT on the sale of services instead of the only tax of 6% on gross income received) and filing more complex tax returns. However, by February 10, 2024, no correlating legislative acts in FA taxation system were submitted or adopted. Responsibilities are unified and new responsibilities are added for all types of FAs: a FA is obliged to disclose its status as an FA when carrying out political activities and collecting information in the military and military-technical spheres, including if, in the course of carrying out such activities, an appeal is sent to state authorities, educational organizations, other bodies and organizations; a FA is obliged to disclose its status as an FA to its founders (participants), beneficiaries, and employees; it is not clear what material labeling requirements are to be applied to all FAs (whether it will be those that currently apply only to foreign mass media outlets-FAs, or other); special requirements are established by the MoJ in implementing regulations; special requirements are established by the MoJ in implementing regulations; and all types of FAs that do not have the status of a legal entity will be required to establish a Russian legal entity to distribute printed, audio, audiovisual and other messages and materials intended for an unlimited number of persons. Before the adoption of this law, such a requirement applied only to individuals, foreign mass media or foreign organizations that do not have the status of a Russian legal entity and that are recognized as performing the functions of a FA in accordance with the Law “On Mass Media”. A single list of grounds for exclusion from the registry of FAs is introduced for all types of FAs. It is also proposed to reduce the period for the MoJ to make a decision on exclusion from the registry of FAs from 90 to 60 days.
• Federal Law No. 260-FZ of July 14, 2022, on Amendments to the Criminal Code of the  RF and the Code of Criminal Procedure of the  RF entered into force on July 14, 2022, with the exception of certain provisions effective from January 1, 2023. The law provides for multiple amendments mainly to the Criminal Code (including, for example, organization of an illegal armed formation or participation in it; violation of the rules for centralized management of technical means of countering threats to the stability, security and integrity of the operation in the territory of the  RF of the Internet information and telecommunication network and the public communication network; attributing to high treason the transition to the side of the enemy; cooperation on a confidential basis with a foreign state, international or foreign organization punished with imprisonment for a term of 3 to 8 years; expansion of the list of actions falling under the definition of espionage; violation of requirements for the protection of state secrets will be punished with imprisonment for up to 3 years; under the article Mercenary, the term of punishment in the form of imprisonment is increased by 2 or more times; etc.) However, the most negative for NCOs are the following amendments provided by this law: a new article 280.4 “Public calls to carry out activities directed against the security of the state” is introduced (imprisonment for a term of 2 to 4 years); a new article 282.4 is introduced “Repeated propaganda or public demonstration of Nazi paraphernalia or symbols, or paraphernalia or symbols of extremist organizations, or other paraphernalia or symbols, the propaganda or public display of which is prohibited by federal laws” (imprisonment for up to 4 years); and article 284.1 (Carrying out the activities of a foreign or international non-governmental organization, in respect of which a decision has been made to recognize its activities as undesirable on the territory of the RF) is amended, from now on, persons participating in the activities, financing or organizing the activities of an “undesirable” organization will be brought to criminal responsibility not only for their activities in the territory of the  RF (as in the previous version of the article said), but also abroad. As the previous law enforcement practice shows, human rights activists can be easier brought to responsibility under the new articles of the Criminal Code 280.4 and 282.4 due to the vagueness of their wordings. And for the leaders, members (participants) and employees of NCOs, the risk of being held criminally liable under Art. 284.1 of the Criminal Code (deprivation of liberty for a term of 1 to 4 years), since the crime constitutes participation in the activities of an “undesirable” organization not only in the territory of the RF, but also abroad.
• Federal law No. 261-FZ of July 14, 2022, on the Russian Movement of Children and Youth entered into force on July 14, 2022. The law provides for the creation of the Russian movement of children and youth (hereinafter referred to as the Movement), determine its legal status, goals, organizational and property bases of activity. In accordance with the law, the goals of the Movement being created are the following: to promote the implementation of state policy in the interests of children and youth; assistance in the upbringing of children, their professional orientation, organization of leisure for children and youth; creation of equal opportunities for the comprehensive development and self-realization of children and youth; preparation of children and young people for a full life in society, including the formation of their worldview, the development of socially significant and creative activity in them, and other socially useful goals. The Movement being created will have structural subdivisions in the regions, municipalities, as well as on the basis of individual educational organizations. Participation in the movement is expected both for individuals (participants-student, participants-mentors), and for collective participants (registered public associations and other NCOs of the organizational and legal forms specified in the law).
• Federal law No. 262-FZ of July 14, 2022, on Amendments to Certain Legislative Acts of the Russian Federation in Connection with the Adoption of the Federal Law on the Russian Movement of Children and Youth entered into force on July 14, 2022. The law provides for amendments to a number of laws in connection with the creation of the Russian Movement of Children and Youth, in particular: Federal Law No. 82-FZ of May 19, 1995, on Public Associations (technical amendments related to the legal status of the movement being created), Federal Law No. 98-FZ of June 28, 1995, on State Support for Youth and Children Public Associations (technical amendments related to state support for the movement being created), Federal Law No. 124-FZ of July 24, 1998, on Basic Guarantees of Rights of the Child in the  RF (technical amendments related to the legal status of the movement being created), Federal Law No. 120-FZ of June 24, 1999, on the Basics of the System for the Prevention of Neglect and Juvenile Delinquency (technical amendments related to the legal status of the movement being created), Federal Law No. 273-FZ of December 29, 2012, on Education in the RF (technical changes related to the legal status of the movement being created).
• Federal Law No. 263-FZ of July 14, 2022, on Amendments to Parts One and Two of the Tax Code of the Russian Federation established the legal basis for the application of a single tax account for the payment of taxes (in accordance with Federal Law No. 379-FZ of November 29, 2021, from July 1, 2022 to December 31, 2022, organizations could voluntarily participate in an experiment on the procedure for applying a single tax payment.), fees and insurance premiums by organizations, including non-profit organizations, individual entrepreneurs and individuals. It entered into force on January 1, 2023. The amendments to the Tax Code are aimed at simplifying the procedure for paying taxes, fees and insurance contributions to the budget system and improving tax administration. The changes do not affect issues related to the procedure for calculating taxes. Instead of the current obligation for taxpayers to fill in a large number of payment orders with a huge number of details, the institution of a single tax account is being introduced. Each taxpayer has a single tax account opened with the Federal Treasury. Taxpayers are required to transfer a single tax payment to this account, indicating in the payment order only two details – the payment amount and individual taxpayer number. The current deadlines for paying taxes, fees and insurance premiums are subject to change, all payments are subject to be made on the 28th of each month. An organization and an individual entrepreneur are required to pay all taxes and fees (with the exception of state duty, tax on professional income, fees for the use of wildlife objects) in a single tax payment, including personal income tax for employees; advance tax payments; insurance premiums; penalties, fines and interest accrued by the tax authority. The amount of money that the organization or individual entrepreneur as a whole must pay to the budget is the total responsibility of the taxpayer. The tax authorities independently set off the single tax payment against the fulfillment by the payer of the obligations to pay taxes. From the unified tax account, the tax authorities, on the basis of the information (documents) they have, notifications submitted by organizations on the calculated amounts of taxes, advance payments on taxes, insurance premiums, independently offset funds against the payment of mandatory payments in accordance with the established order. In the first place – arrears (starting from the earliest moment of its detection), in the second – upcoming payments on taxes and contributions, in the third – penalties, in the fourth – interest, in the fifth – fines. Notifications of the organization will have to be submitted to the tax authority in the form and format approved by the Federal Tax Service. The amounts of a single tax payment transferred to a single tax account that exceed the total amount of taxes payable are at the disposal of the taxpayer and can be returned to him on the current account or credited against taxes of another person at the request of such a taxpayer. The introduction of paying taxes through a single tax account reduces the costs of entities involved in settlement and cash transactions, the time for processing settlement documents, the number of documents generated by the tax authority for balancing settlements for different types of payments (offsets, clarifications of payments), and will also provide clear and simple the state of the payer’s settlements with the budget with a minimum number of errors both on the part of the payers and the tax authorities.
• Federal Law No. 277-FZ of July 14, 2022, on Amendments to Certain Legislative Acts of the Russian Federation entered into force on July 14, 2022. This law provides for the following amendments: A new article (56.2) is introduced into the Law of the Russian Federation on the Mass Media, giving the Prosecutor General (his deputies) the authority to suspend the activities of the media, invalidate the registration of the media or terminate the broadcasting license. A list of 6 types of information is fixed, the dissemination of which by the media can serve as a basis for the prosecutor to take the above measures, namely: unreliable socially significant information that poses a threat to life, health, the functioning of life support facilities, etc.; unreliable information about the armed forces and government agencies outside the Russian Federation; unreliable information about the measures taken to protect the population and territories; information that offends human dignity, society, state symbols, authorities; information aimed at discrediting the armed forces and government agencies; and information calling for unauthorized public events and justification of extremist activity. In accordance with the amendments to the Federal law of December 28, 2012 No. 272-FZ on Measures of Influence on Persons Involved in Violations of Fundamental Human Rights and Freedoms, the Rights and Freedoms of Citizens of the Russian Federation, it is proposed to give the Prosecutor General (his deputies) the right to make a decision to ban (restrict) the activities of a foreign mass media registered on the territory of such a foreign state and distributing its products in the territory of the Russian Federation, as a response to the ban (restriction) of the activities of the Russian media in the territory of a foreign state. Thus, Prosecutor General can now ban foreign news media in response to “hostile” actions taken against Russian media outlets abroad. The new law also allows the Prosecutor General to revoke any outlet’s media license for disseminating “publicly significant information” deemed illegal or dangerous, or information “expressing clear disrespect for the state.” First time offenders may face a three-month suspension rather than losing their media licenses right away. Journalists will also be held liable for republishing information that “discredits the use of the army” or contains calls for street protests.
• Federal law No. 279-FZ of July 14, 2022, on Amendments to Certain Legislative Acts of the Russian Federation and on the Suspension of Certain Provisions of the Federal Law on the Procedure for the Formation and Use of Endowments of Non-Commercial Organizations came into force from July 14, 2022, except for some provisions that come into force from January 1, 2026. The law provides for the following: the rule obliging NCOs – owners of the endowments to disband the endowment capital in cases of a decrease in the value of the net assets of the endowment for three reporting years by more than 30 percent (or by the results of one reporting year by more than 50 percent) is suspended; the maximum amount of interest from the amount of donation and income from endowment, which can be used by the specialized endowment fund management for administrative and management expenses, is increased from 5 to 10 percent, from 10 to 25 percent, from 15 to 30 percent, respectively; NCOs will have the possibility not to use the income from the trust management of property constituting the endowment capital for its intended purpose, but to fully reinvest it in the “body” of the endowment. The measures proposed by the law are temporary, they are expected to be valid until January 1, 2026, this is due to the current political and economic situation in the country. However, these changes will have a positive impact on the activities of NCOs – owners of the endowments in conditions of instability. First, they will help cover the increasing administrative and management costs that the Specialized Fund may incur. Secondly, they will prevent the forced dissolution of the endowments, which contributes to their preservation and is aimed at observing the interests of their beneficiaries. Thirdly, they contribute to the increment of the “body” of endowment capital, which is important in conditions of high volatility and instability in the economy.
• Federal Law No. 290-FZ of July 14, 2022, on Amendments to the Code of Administrative Offenses and Article 1 of the Federal Law on Amendments to the Code of Administrative Offenses of the Russian Federation came into force on July 25, 2022. This law provides for the following: a warning is applied as a form of punishment for the first administrative offense committed to all subjects of offenses; in the case of voluntary prevention of harmful consequences or compensation for harm caused by an offense, the guilty person may be fined only in the minimum amount; the possibility of paying a fine in half within 20 days for violations identified in the course of state control (supervision); and a ban on the consideration of a case on an administrative offense by the same person who conducted the inspection or initiated administrative proceedings on the case. The amendments proposed by the law reduce the burden of administrative fines in case of NCOs committing administrative offenses.
• Federal Law No. 303-FZ of July 14, 2022, on Amendments to Article 265-10 of the Code of Administrative Procedure of the Russian Federation and Articles 13 and 15 of the Federal Law on Counteracting Extremist Activity entered into force on July 14, 2023, except for certain provisions that entered into force on July 14, 2022. The law proposes to consolidate the obligation of the MoJ to create and determine the procedure for maintaining a database of extremist materials, in which a copy of the decision received from the court on recognizing information materials as extremist and extremist materials will be entered. The database of extremist materials will be maintained in parallel with the publicly available Federal List of Extremist Materials, which has been maintained since 2004, containing a brief description of materials recognized as extremist. The new database includes the materials themselves, recognized as extremist, but access to it is only be available to officials of the bodies involved in countering extremist activities, in accordance with their competence. In addition, Article 15 of the Federal Law on Countering Extremist Activity, which provides that “in order to ensure state and public security, on the grounds and in accordance with the procedure provided for by federal law, a person who participated in the implementation of extremist activity may be restricted by a court decision access to state and municipal service, military service under contract and service in law enforcement agencies, as well as to work in educational organizations and engage in private detective and security activities”, the law provides to supplement this list with a restriction for a person involved in the activities of an extremist or terrorist organization to be elected on the grounds and in accordance with the procedure established by the Russian legislation on elections. The same Article 15 is supplemented with new parts 6-9, which provide for the empowerment of the MoJ to create and maintain a unified register of information about persons involved in the activities of an extremist or terrorist organization. This register is proposed to be created for the purpose of conducting by the MoJ, at the request of election commissions, verification of the accuracy of the information provided by candidates in accordance with the Russian legislation on elections. Information about an individual who was a founder, member of a collegial governing body, head, deputy head, head of a regional or other structural unit, deputy head of a regional or other structural unit, participant, member, employee of an extremist or terrorist organization or other person, whose involvement in the activities of an extremist or terrorist organization has been established by a court decision that has entered into legal force, is subject to inclusion in the unified register. The information necessary for maintaining the register will be provided by the Ministry of Internal Affairs, Rosfinmonitoring, the Federal Tax Service, the Pension Fund, and the prosecution authorities. So, if an NCO is recognized as an extremist or terrorist organization (which is becoming more common), its founders, members of the collegiate governing body, head (deputy), participant, member, employee will be limited the right to be elected in accordance with the election legislation.
• Federal Law No. 340-FZ of July 14, 2022, on Amendments to Article 2 of the Federal Law on Charitable Activities and Volunteering entered into force on July 25, 2022. The law has supplemented the list of goals of charitable and voluntary activities with two new objectives. The updated list includes the following objectives: participation in the liquidation of emergency situations and their consequences, prevention and extinguishing of fires, carrying out emergency rescue operations; and participation of citizens in the search for missing persons. It should be noted that the current legislation already regulates the possibility and limits (mainly for preventive purposes) of the participation of public associations in emergency situations (Federal law of December 21, 1994 No. 68-FZ on the Protection of the Population and Territories from Natural and Man-Made Emergencies) and in the field of fire safety, emergency rescue operations (Federal law No. 100-FZ of May 6, 2011 on Voluntary Fire Protection). The initiators of the law believe that the recognition of this activity as volunteering makes it possible to take advantage of additional support measures established at the federal, regional and local levels in accordance with the Federal Law on Charitable Activities and Volunteering. However, the government noted that the law may lead to the need to additional budgetary allocations, including for the training and equipment of volunteers, from the budgets of the budgetary system of the RF.
• Order of the Ministry of Economic Development of the Russian Federation of October 14, 2022 No. 559 “On approval of the requirements for the format of information submitted about non-commercial organizations for inclusion in the register of socially oriented non-commercial organizations” was registered and published of November 11, 2022. The Order defines the requirements for the format of information about NCOs submitted by federal executive authorities, executive authorities of the constituent entities of the RF, organizations authorized to provide grants from the President of the  RF for inclusion in the Register of Socially Oriented Non-Commercial Organizations (SONCO Register).
• Federal Law No. 393-FZ of October 7, 2022, on Amendments to the Federal Law on Non-Commercial Organizations supplemented Article 10 of the Federal Law No. 7-FZ of January 12, 1996, on Non-Commercial Organizations (regulating the legal basis for the activities of autonomous non-commercial organizations – ANO) with a new paragraph 4.1, which states that a major transaction can be made by ANO only with the prior consent of the founders (founder) or the collegiate supreme governing body of the ANO in the manner prescribed by the constituent documents of the ANO, if its settlement accounts have unused funds from the budgets of the budget system of the Russian Federation by the time the major transaction is approved. These changes apply only to ANOs, whose activities use funds from the budgets of the budget system of the RF, while for the majority of NCOs registered in the legal form of ANOs, major transactions seem unlikely.
• Federal Law No. 394-FZ of October 7, 2022, on Amendments to the Federal Law on Charitable Activities and Volunteering supplemented the List of goals of charitable activities (clause 1, article 2) with two new sub-clauses: assistance in the provision of medical care in organizations providing medical care; and assistance to internal affairs bodies (police) and other law enforcement agencies in the protection of public order in accordance with the legislation of the RF. Support for a volunteer in the form of insurance of his life or health, as well as compensation for harm to life and health caused in the course of voluntary (volunteer) activities, is singled out in a separate subparagraph, which is supplemented by the right to reimbursement of expenses incurred by a volunteer for insurance of his life or health. Compensation is paid at the expense of the federal budget if harm to the life or health of a volunteer is caused in the course of the following types of voluntary activities: participation in the liquidation of emergency situations and their consequences, the prevention and extinguishing of fires, the conduct of emergency rescue operations, as well as the provision of assistance to victims of natural disasters, environmental, industrial or other disasters, social, national, religious conflicts, victims of repression, refugees and forced settlers; assistance in providing citizens suffering from diseases that pose a danger to others, medical care in organizations providing medical care; and participation in the search for missing persons, including the provision of assistance to the internal affairs bodies (police) and other law enforcement agencies in the search for missing persons. Compensation is awarded if harm has been caused to the life or health of a volunteer, information about which is contained in a unified information system in the field of volunteerism development. The amount, procedure and conditions for the appointment and payment of compensation are established by the Government of the RF. The law came into force on January 1, 2023.

• Decree of the President of the Russian Federation of November 4, 2022 No. 799 “On Amendments to the Regulations on the Ministry of Justice of the Russian Federation, approved by Decree of the President of the Russian Federation of October 13, 2004 No. 1313” expanded and specified the list of powers of the MoJ: maintaining a FA Registry, a unified registry of persons affiliated with FAs, a unified registry of information about persons involved in the activities of an extremist or terrorist organization, a database of extremist materials.
• Federal Law No. 426-FZ of November 4, 2022, on Amendments to Article 9 of the Federal Law on Public Associations entered into force on November 15, 2022. The law simplified the process of making managerial decisions in public movements (it extended to them the norms regarding the powers of a permanent governing body, which previously applied only to public organizations).
• Order of the Federal Security Service of the Russian Federation dated November 4, 2022, No. 547 “On approval of the List of information in the field of military, military-technical activities of the Russian Federation, which, if received by foreign sources, can be used against the security of the Russian Federation”. The order defines a list of information (60 items) in the field of military and military-technical activities of the Russian Federation, which do not constitute a military secret, but the collection of which is one of the grounds for recognizing a person as a foreign agent.
• Decree of the Government of the Russian Federation of November 5, 2022 No. 1996 “On Approval of the Rules for the Notification by the Ministry of Justice of the Russian Federation and its Territorial Bodies of Prosecutor’s Offices of an Unscheduled Inspection of Foreign Agents, as well as Persons Specified in Part 2 of Article 1 of the Federal Law on Control over Activities persons under foreign influence came into force on December 1, 2022 and established a list of documents sent by the MoJ to the prosecutor’s office during unscheduled inspections of FAs.
• Order of the Government of the Russian Federation dated November 10, 2022, No. 3417-p entered into force on December 1, 2022 and fixed the volume of information contained in the FA Registry to be posted on the official website of the MoJ in the Internet information and telecommunication network.
• Decree of the Government of the Russian Federation of November 16, 2022, No. 2075 “On Approval of the Rules for the Interaction of the Federal Service for Supervision of Communications, Information Technology and Mass Communications with Foreign Agents, as well as Limiting and Resuming Access to Their Information Resources” came into force on December 1, 2022. The Decree specifies the procedure for suspending and resuming access to information resources of FAs, provided for by the Federal Law on Control over the Activities of Persons Under Foreign Influence and fixed two types of interaction between the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) with FAs.
• Federal Law No. 439-FZ of November 21, 2022, on Amendments to Article 17-1 of the Federal Law on Charity and Volunteering and Federal Law No. 440-FZ of November 21, 2022, on Amendments to Article 217 of Part Two of the Tax Code of the Russian Federation came into force on January 1, 2023. The adopted changes are aimed at the legal regulation of the right of volunteers to receive support in the form of payment for communication services and the inclusion of this type of income of individuals in the list of income not subject to taxation (exempted from taxation) by personal income tax (PIT), on an equal basis with the rest of the income received by volunteers (volunteers) under civil law contracts, the subject of which is the gratuitous performance of work, the provision of services.
• Decree of the Government of the Russian Federation dated November 22, 2022 No. 2107 “On Amendments to the Rules for Issuing a Permit to Include the Official Name “Russian Federation” or “Russia” in the Name of a Non-Commercial Organization, as well as Words Derived from This Name” is aimed at simplifying the procedures related to the preservation of the right of NCOs that use the official name “Russian Federation” or “Russia” in their names, as well as words derived from this name, when changing their name, legal form or reorganization.
• Decree of the Government of the Russian Federation of November 22, 2022 No. 2108 “On Approval of the Rules for Placing Indications Provided for by Parts 3 and 4 of Article 9 of the Federal Law on Control over the Activities of Persons Under Foreign Influence, including the requirements for their placement, as well as the forms of indications provided for by Parts 3 and 4 of Article 9 of the Federal Law on Control over the Activities of Persons Under Foreign Influence entered into force on December 1, 2022. The Decree establishes requirements for placing in text, audiovisual and audio materials of indications that they were produced, distributed or sent by a FA.
• Order of the Ministry of Justice of the Russian Federation dated November 28, 2022 No. 300 “On approval of the procedure for the adoption by the Ministry of Justice of the Russian Federation of a decision to exempt persons (categories of persons) from the obligation to submit an application for inclusion in the registry of foreign agents” determined the procedure for the coordination by the MoJ with the Federal Security Service of Russia, the Federal Guard Service of Russia, the Foreign Intelligence Service of Russia and the Ministry of Defense of Russia of the decision to exempt persons (categories of persons) from being included in the Registry of foreign agents.
• Order of the Ministry of Justice of the Russian Federation dated November 29, 2022 No. 302 “On Approval of the Procedure for Maintaining a Unified Registry of Individuals Affiliated with Foreign Agents and the Procedure for Making a Decision to Exclude an Individual from the Said Register” determined the procedure for maintaining the Unified Registry of Persons affiliated with FAs. This registry is not public and is created for verification by the MoJ at the request of election commissions of persons, when they are nominated as candidates for elections.
• Order of the Ministry of Justice of the Russian Federation dated November 29, 2022 No. 304 “On approval of the Procedure and forms for the submission to the Ministry of Justice of the Russian Federation by a foreign agent of information provided for by Part 8 of Article 9 of the Federal Law of July 14, 2022 No. 255-FZ on Control over the Activities of Persons under Foreign Influence, and the Procedure and terms for posting by a foreign agent a report on its activities in the information and telecommunication network “Internet” determines the procedure for submission and reporting forms of FAs.
• Order of the Ministry of Justice of the Russian Federation of November 29, 2022 No. 305 “On approval of the procedures for filing by persons specified in parts 1 and 2 of Article 7 of the Federal Law of July 14, 2022 No. 255-FZ on Control over the Activities of Persons under Foreign Influence, applications for inclusion in the register of foreign agents and forms for such an application” determines the forms of applications for the voluntary inclusion of a person in the FA Registry.
• Order of the Ministry of Justice of the Russian Federation of November 29, 2022 No. 306 “On approval of the procedure for notifying the Ministry of Justice of the Russian Federation by a foreign agent about the establishment of a Russian legal entity” determines the procedure for notification by FAs of the MoJ of the fulfillment of the obligation stipulated by law to establish a legal entity in order to distribute their materials.
• Order of the Ministry of Justice of the Russian Federation of November 29, 2022 No. 307 “On approval of the Procedure for maintaining the registry of foreign agents and posting the information contained therein on the official website of the Ministry of Justice of the Russian Federation on the Internet information and telecommunications network”, the Procedure for making a decision to exclude an individual, for the first time included in the registry of FAs, from the registry of FAs, the application form of a foreign agent for exclusion from the registry of FAs” establishes the procedure for maintaining the FA Registry, inclusion and exclusion from it. The Registry itself is placed in the form of a pdf-file and can be downloaded from the link. In contrast to the previous regulation, from now on, the FA Registry contains all FAs in respect of which a decision was made to exclude them from it.
• Federal Law No. 494-FZ of December 05, 2022, on Amending Article 325 of the Federal Law on Customs Regulation in the Russian Federation and on Amending Certain Legislative Acts of the Russian Federation initially proposed to allow the Federal Customs Service to transfer sanitary and hygienic and medical products, perishable foodstuffs, baby and medical food, clothing, shoes and other essentials to organizations engaged in charitable activities. Finally, this possibility was offered only to United People’s Front (pro-governmental organization, UPF), however, UPF will further distribute the above-mentioned essentials to SONCOs.
• Federal Law No. 497-FZ of December 5, 2022, on Amendments to the Federal Law on Public Control over Ensuring Human Rights in Places of Detention and on Assistance to Persons in Places of Detention entered into force on June 4, 2023. The main changes to the law are as follows: the list of NCOs participating in public control over the provision of human rights in places of detention has been supplemented by associations (unions), foundations, and autonomous non-commercial organizations. Previously, only public associations appeared in the law; provisions were introduced on the independence of the Public Monitoring Commissions (PMC) from the authorities, on the inadmissibility of interference by political parties, international and foreign organizations (associations) in the field of activity of the PMC; the financial activities of PMCs are being optimized at the expense of the budgets of the civic chambers of the constituent entities of the Russian Federation; and the required term for the human rights activities of an NCO that has the right to nominate candidates for PMCs is reduced from 5 to 3 years.
• Federal Law No. 498-FZ of December 5, 2022, on Amendments to Certain Legislative Acts of the Russian Federation came into force on December 5, 2022. This Federal Law is associated with the entry into force of Federal Law No. 255-FZ dated July 14, 2022 on Control over the Activities of Persons Under Foreign Influence from December 1, 2022 and introduces correlative changes to 40 federal laws in terms of the terminology used in relation to FAs, and the restrictions imposed on them, for example, the prohibition of carrying out educational and educational outreach activities in relation to minors, the prohibition of anti-corruption and public environmental expertise, etc.
• Order of Federal Agency on Technical Regulating and Metrology (Rosstandart) of December 20, 2022 No. 1533-st “On approval of Amendment 52/2022 OKVED 2 to the All-Russia Classifier of Types of Economic Activity (OKVED 2) and Amendment 75/2022 OKPD 2 to the All-Russia Classifier of Products by Type of Economic Activity” entered into force on March 1, 2023. The current OKVED 2 classifier has been amended, in particular, OKVED codes have appeared that directly reflect the activities of NCOs in terms of the purpose of their creation and the direction of their activities. According to the current legislation, each type of activity must correspond to a certain OKVED code. In this regard, it is very important to be able to choose the appropriate code for such activities. Previously, the classifier contained, for the most part, codes suitable only for commercial legal entities and individual entrepreneurs; NCOs had a very small number of codes that they could use. In most of the codes, the decryption indicated such activities, which, in their meaning, contradicted the goals of creating an NCO. In addition, the types of activities carried out by an NCO, due to which it would be recognized as socially oriented (Article 31.1 of the Federal Law on Non-Commercial Organizations), were in fact completely absent in the classifier. After updating the classifier, NCOs have the opportunity to select codes that correspond both to the goals of creating an organization and to the types of activity. The new codes quite concretely reflect the essence of NCOs as such; their decoding makes it possible to compare the activity in the Charter with its “numerical designation.” Thus, an NCO has the opportunity to “cover” with codes, if not all, then a significant part of the activities that it carries out. The situation with charitable organizations is significantly improving due to the appearance of a code that clearly reflects the essence of the creation of such NCOs within the framework of the Federal Law of August 11, 1995 No. 135-FZ on Charitable Activities and Volunteering. In addition, specialized endowment organizations will have their own code, which did not exist before. These changes are extremely positive because the adaptation of OKVED codes for NCOs will allow selecting codes that best reflect the essence of the creation of such organizations and activities that are unique to NCOs.
• Federal Law No. 568-FZ of December 28, 2022, on Amending Certain Legislative Acts of the Russian Federation and Recognizing Part 3 of Article 3 of the Federal Law on Amending Certain Legislative Acts of the Russian Federation in Connection with the Adoption of the Federal Law on State (Municipal) Social Order for the Provision of State (Municipal) Services in the Social Sphere came into force on December 28, 2022, with the exception of certain articles that entered into force on January 1 and March 1, 2023. SONCOs will have easier access to social contracting in the field of sports and health. It is proposed to expand the mechanism of social ordering in three more areas: sports and health services, prevention of socially significant diseases and the implementation of additional educational programs (expanding the pilot regime for testing social ordering tools in the social sphere, which is currently being implemented in 30 constituent entities of the RF, and will be implemented from 2023 at 34).
• Federal Law No. 582-FZ of December 29, 2022, on Amendments to Articles 239 and 330-1 of the Criminal Code of the Russian Federation came into force on December 29, 2022. The law amended the articles of the Criminal Code of the  RF establishing the criminal liability of FAs. Article 239 of the Criminal Code, which provides for criminal liability for the creation of an NCO that infringes on the personality and rights of citizens, the maximum penalty was increased (the maximum term of imprisonment for the creation of such an NCO is increased from 3 to 6 years, for participation in its activities – from 2 to 4 years). In Article 330-1 of the Criminal Code, which establishes criminal liability for evading the fulfillment of obligations stipulated by the Russian legislation on FAs, the terminology has been changed, but the previously existing punishments have not changed: for evading the submission of documents for inclusion in the FA Registry and for violating the order of activities a FA, if this person has previously been subjected to administrative punishment twice within one year, the maximum punishment is in the form of imprisonment for up to 2 years, and for failure to submit documents for inclusion in the FA Registry by a person collecting information in the field of military and military-technical activities RF, the maximum punishment is imprisonment for up to 5 years.
• Federal Law No. 622-FZ of December 29, 2022, on Amendments to the Code of Administrative Offenses of the Russian Federation came into force on December 29, 2022. The law amended Articles 13.15 and 19.34 of the CoAO regarding the administrative liability of FAs. Article 13.15 of the CoAO (abuse of freedom of the media) the terminology was changed, but the penalties remained the same. Article 19.34 of the CoAO (violation of the procedure for the activities of a foreign agent) the terminology was changed, the composition of administrative offenses for all types of FAs was unified. For the commission of most of these offenses, a fine is provided for citizens from 30,000 to 50,000 rubles; for officials and/or for legal entities – from 100 thousand to 300 thousand rubles.
• Federal Law No. 625-FZ of December 29, 2022, on Amendments to the Code of Administrative Offenses of the Russian Federation came into force on December 29, 2022. The amendments to the law for NCOs may mean the possibility of bringing to administrative responsibility for violations in the field of personal data processing without an inspection by Roskomnadzor. Thus, the possibility of correcting the committed violations during the inspection process is significantly reduced, and, accordingly, the risk of bringing NCOs to administrative responsibility under Art. 13.11 of the CoAO is increased.
• Decree of the Government of the Russian Federation of January 10, 2023 No. 6 “On approval of the Rules for making a decision to prohibit or restrict the cross-border transfer of personal data by the authorized body for the protection of the rights of personal data subjects and informing operators of the decision” and Decree of the Government of the Russian Federation dated January 16, 2023 No. 24 “On approval of the Rules for making a decision by the authorized body for the protection of the rights of subjects of personal data on the prohibition or restriction of cross-border transfer of personal data in order to protect morality, health, rights and legitimate interests of citizens” entered into force on March 1, 2023. New legal requirements regarding the cross-border transfer of personal data significantly complicate the activities of personal data operators, including NCOs. The difficulties are primarily related to the vagueness of the legislative definition of cross-border transfer of personal data, since formally the use of the vast majority of Internet resources / services / applications can be recognized as cross-border transfer of personal data, based on the fact that servers can be located outside the RF. At the same time, it is almost impossible for a personal data operator to check the “cross-border” nature of the resources/services/applications used, even conventionally considered domestic ones.
• Decree of the Government of the Russian Federation of January 14, 2023 No. 18 “On Approval of the Regulations on State Control over the Activities of Foreign Agents” entered into force on January 27, 2023. The new procedure for state control over the activities of FAs does not differ from the previously existing control mechanisms; in fact, the Decree streamlined the previously disparate norms on control over the activities of persons performing the functions of a foreign agent (legal entities, unregistered public associations, the media, individuals).
• Order of the Federal Service for Supervision in the Sphere of Communications, Information Technology and Mass Communications of February 2, 2023 No. 13 “On approval of the procedure for monitoring information and telecommunication networks, including the Internet”, as well as determining the types of information and (or) information resources which are being monitored” states, in particular, that websites and pages of websites on the Internet of FAs (both natural and legal persons) are subject to constant monitoring in order to identify information and (or) sites on the Internet, and (or) pages of sites on the Internet, access to which is subject to restriction.
• Federal Law No. 43-FZ of February 28, 2023, on the Termination of International Treaties of the Council of Europe in relation to the Russian Federation denounces part of the international agreements of the RF, including those regarding the protection of human rights and freedoms. In accordance with the text of the law, as of March 16, 2022, the following international treaties are considered to have terminated in relation to the Eurasian Country: Statute of the Council of Europe of May 5, 1949; General Agreement on Privileges and Immunities of the Council of Europe of September 2, 1949; Protocol to the General Agreement on the Privileges and Immunities of the Council of Europe of November 6, 1952; Second Protocol to the General Agreement on the Privileges and Immunities of the Council of Europe (Provisions Concerning Members of the European Commission on Human Rights) of December 15, 1956; Fourth Protocol to the General Agreement on the Privileges and Immunities of the Council of Europe (Regulations concerning the European Court of Human Rights) of December 16, 1961; Fifth Protocol to the General Agreement on the Privileges and Immunities of the Council of Europe of June 18, 1990; Sixth Protocol to the General Agreement on the Privileges and Immunities of the Council of Europe of March 5, 1996; Convention for the Protection of Human Rights and Fundamental Freedoms of November 4, 1950; Protocol No. 1 to the Convention for the Protection of Human Rights and Fundamental Freedoms of March 20, 1952; Protocol No. 2 to the Convention for the Protection of Human Rights and Fundamental Freedoms on the competence of the European Court of Human Rights to issue advisory opinions of May 6, 1963; Protocol No. 3 to the Convention for the Protection of Human Rights and Fundamental Freedoms, amending Articles 29, 30 and 34 of the Convention of May 6, 1963; Protocol No. 4 to the Convention for the Protection of Human Rights and Fundamental Freedoms on securing certain rights and freedoms other than those already included in the Convention and its first Protocol, of September 16, 1963; Protocol No. 5 to the Convention for the Protection of Human Rights and Fundamental Freedoms, amending Articles 22 and 40 of the Convention of January 20, 1966; Protocol No. 7 to the Convention for the Protection of Human Rights and Fundamental Freedoms of November 22, 1984; Protocol No. 8 to the Convention for the Protection of Human Rights and Fundamental Freedoms of March 19, 1985; Protocol No. 11 to the Convention for the Protection of Human Rights and Fundamental Freedoms on the reorganization of the control mechanism established in accordance with the Convention, of May 11, 1994; Protocol No. 14 to the Convention for the Protection of Human Rights and Fundamental Freedoms, amending the control mechanism of the Convention, of May 13, 2004; Protocol No. 15 amending the Convention for the Protection of Human Rights and Fundamental Freedoms, of June 24, 2013; European Convention for the Suppression of Terrorism of January 27, 1977; European Charter of Local Self-Government of October 15, 1985; and European Social Charter (Revised) of May 3, 1996.
• Federal Law No. 57-FZ of March 18, 2023, on Amendments to Articles 13.15 and 20.3-3 of the Code of Administrative Offenses of the Russian Federation provides for tightening the administrative responsibility for “public actions aimed at discrediting (it should be noted that the definition of the term “discredit” in Russian legislation is enshrined only in Art. 14.1 of the Federal Law of July 26, 2006 No. 135-FZ on Protection of Competition; this is “the dissemination of knowingly false, inaccurate or distorted information that can cause losses to an economic entity and (or) damage its business reputation.” There is no separate list of actions and information that can be qualified as discrediting in the Code of Administrative Offenses and the Criminal Code) volunteer formations, organizations and individuals who assist in the fulfillment of the tasks assigned to the Armed Forces, if these actions do not contain signs of a criminally punishable act.” Penalties up to 50 thousand rubles are provided. for citizens and up to 500 thousand rubles. for legal entities. The law entered into force on March 29, 2023. Though not directly related to NCOs, this law can seriously complicate the work of bloggers and human rights defenders.
• Federal Law No. 58-FZ of March 18, 2023, on Amendments to the Criminal Code of the Russian Federation tightens the criminal responsibility for “public actions aimed at discrediting volunteer formations, organizations and persons assisting the Armed Forces, as well as for spreading fakes about them.” The law provides for fakes imprisonment for up to 5 years or fines in the amount of 700 thousand to 1.5 million rubles; if the deeds caused serious consequences – deprive of liberty for a term of 10 to 15 years. The law entered into force on March 29, 2023. Though not directly related to NCOs, this law can seriously complicate the work of bloggers and human rights defenders.
• Order of the Ministry of Justice of March 29, 2023 No. 54 “On amendments to the Order of the Ministry of Justice of September 30, 2021 No. 185” comes into force on September 1, 2023, and is related to the federal law on foreign influence. It made changes to the NCO reporting forms: OH0001 (on the activities of an NCO, the personal composition of the governing bodies and employees, as well as on the purposes of spending money and using other property, including those received from foreign sources), OH0002 (on the purposes of spending money by an NCO and use of other property, including those received from foreign sources), OH0003 (on the amount of funds and other property received by a public association from foreign sources). They will include the following foreign sources: 1) targeted receipts from foreign states; 2) targeted receipts from public authorities of foreign states; 3) targeted receipts from international and foreign organizations; 4) targeted receipts from foreign citizens; 5) targeted receipts from stateless persons; 6) targeted receipts from foreign structures without the formation of a legal entity; and 7) targeted receipts from persons authorized by the sources specified in paragraphs 1) – 6).
• Federal Law No. 119-FZ of April 14, 2023, on Amendments to Article 31-1 of the Federal Law on Non-Commercial Organizations provides for supplementing the SONCO support components with a new type of information support: to provide various authorities with the opportunity to provide SONCO services for the provision of computing power on servers (for example, using the government state unified cloud platform) to place large SONCO information resources on a secure telecommunications infrastructure; provide SONCOs, included in the register, with access to the website builder of the Ministry of Digital Development of Russia (“Gosweb” subsystem of the federal state information system “Unified Portal of State and Municipal Services (Functions))”. The law is aimed at the reduction of SONCOs’ expenses for technical and material support, and provision of security of the personal data of citizens working and interacting with SONCOs.
• Federal Law No. 231-FZ of June 13, 2023, on Amendments to the Code of Administrative Offenses entered into force on June 24, 2023. It provides for amendments into Art 20.29 of the CoAO “Production and distribution of extremist materials.” The scope of the article has been expanded and now assumes administrative responsibility for the mass distribution of extremist materials, not only included in the relevant List of the MoJ, but also any other extremist materials. Legislative changes that have come into force may significantly complicate the activities of NCOs, which involve the distribution of materials to an unlimited number of people, as well as increase the risks of bringing NCOs to administrative responsibility.
• Order of the Ministry of Justice dated June 30, 2023, No. 163 “On Approval of Model Charters of Non-Commercial Organizations” entered into force on July 11, 2023. The Order applies to local and regional public organizations; local and regional public movements; associations (unions), communities of indigenous peoples; public benefit foundations; private institutions; and autonomous non-commercial organizations. The ability of NCOs to act on the basis of a model charter is positive, since it is rather problematic for most NCOs to independently develop a charter.
• Federal Law No. 353-FZ of July 24, 2023, on Amendments to Article 7 of the Federal Law on State Registration of Legal Entities and Individual Entrepreneurs came into force on August 4, 2023. Before the adoption of this law, paragraph 1 of Art. 7 of the Law (129-FZ) stipulated that, as a general rule, the provision of information from the Unified State Register of Legal Entities and the Unified State Register of Individual Entrepreneurs is paid. The introduced legislative changes provide for the simplification of the procedure for obtaining copies of the charters of legal entities in the form of an electronic document free of charge. Any interested person is able to request an electronic copy of the charter of a particular legal entity. The adopted changes make it possible to reduce the paperwork and reduce the costs of persons requesting the charter. It is also necessary to take into account that the general availability of charters, on the one hand, will contribute to the information openness of NCOs, on the other hand, it will require NCOs to be more attentive to the issue of updating charters in accordance with changing legislation.
• Federal Law No. 358-FZ of July 24, 2023, on Amendments to Certain Legislative Acts of the Russian Federation came into force on August 4, 2023. It provides for extending the scope of the article on state control over the activities of the FAs through the possibility of control actions of the MoJ in relation to persons interacting with the FAs; the MoJ is empowered to issue a warning (with a period of elimination of violations of at least 1 month) to public authorities, organizations of all forms of ownership, as well as their officials and individuals (regardless of their citizenship or lack thereof) upon receipt of information about actions (inaction) that contribute to violation of the law by FAs. Thus, it is assumed that the responsibility for compliance with FA restrictions lies both with the “foreign agent” and with any persons who, to one degree or another, by their actions or inaction, may contribute to the fact that these restrictions and prohibitions are not observed. In addition, scheduled and unscheduled inspections can be carried out in relation to persons about whom the MoJ received information; and a FA is not entitled to receive state financial and other property support, including when carrying out creative activities.
• Federal Law No. 360-FZ of July 24, 2023, on Amendments to Certain Legislative Acts of the Russian Federation came into force on July 24, 2023. The essence of the adopted legislative changes is to equalize the terms for the submission by NCOs and commercial organizations and individual entrepreneurs of information about changes in the information contained in the Unified State Register of Legal Entities (USRLE) which is from now on 7 days. Previously NCOs were obliged to inform the MoJ about changes in information contained in USRLE within 3 days.
• Federal Law No. 364-FZ of July 24, 2023, on Amendments to the Code of Administrative Offenses of the Russian Federation came into force on August 4, 2023, and is related to the Federal Law No.358-FZ. The law established administrative liability for failure to comply within the prescribed period of a legal warning to eliminate violations of the law on FAs: an administrative fine on citizens in the amount of 30,000 to 50,000 rubles; on officials – from 70,000 to 100,000 rubles or disqualification for a period of up to two years; for legal entities – from 200,000 to 300,000 rubles (Art. 5 of the CoAO).
• Federal Law No. 386-FZ of July 24, 2023, on Amendments to Certain Legislative Acts of the Russian Federation entered into force on July 24, 2023. The law prohibits: changing the gender marker in the passport; operations related to transgender transition, with the exception of cases related to the treatment of “congenital physiological anomalies” (this item also applies to hormone therapy); medications “aimed at changing sex” and “forming a person’s sexual characteristics of the opposite sex”; adoption of children, guardianship; prohibition of registry offices to make changes to a person’s documents on the basis of medical certificates of “sex change”. When discussing the law at the stage of consideration, the Ministry of Health passed a negative opinion on the draft law, where, among other things, it indicated that it could lead to an increase in the number of suicides in people whose gender does not correspond to the official sex. However, the draft law submitted by almost all State Duma deputies was adopted unanimously.
• Federal Law No. 409-FZ of July 31, 2023, on Amendments to the Federal Law on Non-Commercial Organizations came into force on July 31, 2023. It provides for preventing the participation of Russian citizens in the activities in the territory of the RF of affiliate or representative offices of foreign non-governmental non-for-profit organizations (FNCOs) that have not passed the registration procedures in the MoJ established by the law. In addition, the Law on NCOs is supplemented with a new ground for refusing to enter an affiliate or representative office of a FNCO in the relevant register: if the affiliate or representative office of a FNCO previously entered in the register was excluded from the register within 3 years preceding the date of submission of the notification due to violation of the current legislation. The law actually prohibits any participation in activities on the territory of the RF of affiliate or representative offices of FNCOs that are not duly registered.
• Federal Law No. 412-FZ of August 4, 2023, on Amendments to the Code of Administrative Offenses of the Russian Federation came into force on August 4, 2023. The law related to Federal Law No.409-FZ provides for introducing a new article 19.34.2 into the CoAO on administrative responsibility for participation in activities in the territory of the RF of a FNCO not registered by the MoJ, and bringing a person to administrative responsibility under this article twice during the year will serve as the basis for bringing him/her to criminal responsibility. Violation entails the imposition of an administrative fine on citizens in the amount of 3,000 to 5,000 rubles; for officials – from 20,000 to 50,000 rubles; for legal entities – from 50,000 to 100,000 rubles. The law actually prohibits any participation in activities on the territory of the RF of affiliate or representative offices of FNCOs that are not duly registered; and establishes administrative liability for organizing and participating in their activities.
• Federal Law No. 413-FZ of August 4, 2023, on Amendments to the Criminal Code of the Russian Federation and Articles 31 and 151 of the Code of Criminal Procedure of the Russian Federation came into force on August 4, 2023. The law related to Federal Law No.409-FZ provides for supplementing the Criminal Code with a new article 330.3, which introduces criminal liability for persons participating in the activities of affiliate or representative offices of FNCOs in the territory of the RF that are not registered by the MoJ, provided that they have previously been brought to administrative responsibility twice during the year for a similar administrative offense (Article 19.34 .2 of the CoAO). Violation is punishable by a fine in the amount of 100,000 to 200,000 rubles, or in the amount of the wage or other income of the convicted person for a period of one to two years, or by compulsory labor for up to 200 hours, or by compulsory labor for a term of up to two years, with restriction of freedom for a term of up to two years or without it, or by deprivation of liberty for a term of up to two years with deprivation of the right to hold certain positions or engage in certain activities for a term of up to five years or without it. At the same time, bringing to criminal liability for organizing the activities of such an affiliate or representative office of a FNCO does not require a recorded fact of bringing a person to administrative responsibility earlier. This violation is punishable by compulsory labor for a term of up to 360 hours, or by forced labor for a term of up to three years with or without restriction of liberty for a term of up to two years, or by imprisonment for a term of up to three years with deprivation of the right to occupy certain positions or engage in certain activities for up to seven years or without it. The law actually prohibits any participation in activities on the territory of the RF of affiliate or representative offices of FNCOs that are not duly registered; and establishes criminal liability for organizing and participating in their activities.
• Order of the Ministry of Education of the Russian Federation dated October 11, 2023, No. 754 “On approval of the form and procedure for sending notifications about the planned implementation of educational activities to the Ministry of Education of the Russian Federation” published on December 25, 2023, applies only to those NCOs that receive budget funds to carry out outreach educational activities for minors.
• Federal Law No. 503-FZ of October 19, 2023, on Amendments to Certain Legislative Acts of the Russian Federation came into force on January 1, 2024. It provides for the transfer of powers of the Government to relevant ministries and departments for legal regulation in the areas of their competence. In particular, the requirements for boxes for collecting charitable donations, the procedure for their installation, use and removal of collected charitable donations will be determined by the MoJ. The established requirements may affect the activities of NCOs.
• Order of the Ministry of Justice of the Russian Federation dated October 24, 2023, No. 314 “On amending the Procedure for maintaining the registry of foreign agents and posting the information contained therein on the official website of the Ministry of Justice of the Russian Federation on the Internet information and telecommunications network”, approved by order of the Ministry of Justice dated November 29, 2022, No. 307″ was published on October 31, 2023. The Order adjusted the Procedure for maintaining the Registry of FAs in terms of expanding the list of information about a FA contained in the registry (date of inclusion in the registry; pseudonym of an individual (if any); and the previous surname, and (or) first name, and (or) patronymic (if the FA changed the surname, and (or) first name, and (or) patronymic) or the previous name of a legal entity, public association operating without forming a legal entity, another association of persons, a foreign structure without forming a legal entity (if it is changed). On the one hand, the changes made increase the reputational risks of persons recognized as FAs, on the other hand, this will allow other persons who, in accordance with the Federal Law No. 255-FZ of July 14, 2022, on Control over the Activities of Persons under Foreign Influence are obliged to comply with the prohibitions and restrictions established for FAs and to prevent violations of this requirement.
• Federal Law No. 525-FZ of November 2, 2023, on Amendments to Articles 3 and 9-1 of the Federal Law on Non-Commercial Organizations comes into force on June 1, 2024. The law establishes the right (and not the obligation, as in the previous version of the law) of NCOs to have a seal. Commercial entities back in 2015 had the opportunity to refuse using a seal, so from June 1, 2024, the presence of a seal for NCOs will become voluntary, and information that the organization has a seal with the full name of this NCO in the main state language will be reflected in the organization’s charter. Those organizations whose charters currently do not contain information about the seal, although the seal itself has been produced and is used, will need to make changes to the charter. The adopted changes seem positive, since they will allow NCOs to choose a preferable method for identifying their own documents, which will reduce the costs of NCOs to produce seals.
• Federal Law No. 526-FZ of November 2, 2023, on Amendments to Article 15-3 of the Federal Law on Information, Information Technologies and Information Protection and Article 16 of the Federal Law on Freedom of Conscience and Religious Associations came into force on November 13, 2013. The adopted changes allow, in accordance with the established procedure, to block the spread of false information about the collection of donations under the guise of religious organizations.
• Order of the Federal Antimonopoly Service of November 14, 2023, No. 821/23 “On approval of the guide to compliance with mandatory requirements “The Concept of Advertising” is very useful for NCOs, since it allows to understand many issues related to the attribution of this or that information to advertising and avoid huge penalties.
• Federal Law No. 558-FZ of November 27, 2023, on Amendments to Certain Legislative Acts of the Russian Federation entered into force on January 1, 2024. The adopted changes include: new charity goals; expanding the list of participants in charitable and volunteer activities (associations (unions) of volunteer organizations, volunteer resource centers and volunteer organizations were added); the definition of the organizer of volunteer activities has been changed (they can be any legal entities); a definition of a volunteer resource center is given; the right of a volunteer to pay the costs of providing medical services in cases of necessity; etc.
• Order of the Ministry of Justice of the Russian Federation dated November 29, 2023, No. 348 “On approval of the Procedure for maintaining a register of affiliate and representative offices of international organizations and foreign non-profit non-governmental organizations, posting the register on the official website of the Ministry of Justice of the Russian Federation in the information and telecommunications network “Internet”, and also the amount of information subject to such placement” was published on November 30, 2023. The adoption of this Order can be regarded as eliminating the existing legal conflict, when the register of affiliate and representative offices of foreign NCOs has actually been maintained for a long time, however, no normative act on the procedure for maintaining it has been adopted.
• Order of the Ministry of Justice of the Russian Federation dated November 29, 2023, No. 349 “On approval of the Procedure and terms for posting information about an event with the participation of a foreign non-profit non-governmental organization, information about the structural divisions of which is not in the register of affiliate and representative offices of international organizations and foreign non-profit non-governmental organizations that do not have registered in the manner prescribed by Article 13.1 of the Federal Law of January 12, 1996 No. 7-FZ on Non-Commercial Organizations, a structural unit – branch, as well as a notification form for an event with the participation of such an organization” was published on November 30, 2023. NCOs must consider that they can only participate in those events that are held by foreign and international organizations that have structural divisions registered on the territory of the RF, or in those events, information about which is posted on the official websites of government authorities. authorities, local authorities, or relevant organizations.
• Federal Law No. 565-FZ of December 12, 2023, on Employment of the Population in the Russian Federation came into force on January 1, 2024, except for certain provisions. The law was adopted to replace the previously valid Law of the RF No. 1032-1 of April 19, 1991, on Employment in the Russian Federation. In particular, the law clarifies that only founders (members) of corporate commercial organizations can be recognized as employed; founders and members of NCOs are completely excluded from the list of persons considered employed. The law, as amended, sets out an article regulating the obligation of employers, in particular NCOs, to inform the state employment service. The list of information about which information will need to be sent additionally includes a temporary transfer (or its change and cancellation) of employees to remote work in exceptional cases provided for by labor legislation – this information will need to be submitted within 3 working days from the date of the relevant decision. Local experts believe that, on the one hand, the adoption of a new law on employment will make it possible to inform employment services not in accordance with a certain schedule, but in the presence of a corresponding event, which will reduce the risks of bringing NCOs to justice in this area. On the other hand, the list of mandatory information is expanding. The important issue for NCOs of declaring the head of an NCO acting on a voluntary basis as unemployed has also been left without resolution.
• Federal Law No. 589-FZ of December 12, 2023, on Amendments to the Code of Administrative Offences came into force on December 23, 2023, significantly increasing fines for individuals, for officials and organizations for collecting personal data without the written consent of personal data subjects. To minimize the risks of administrative liability, NCOs should be very careful about obtaining written consent to process personal data.
• Federal Law No. 671-FZ of December 25, 2023, on Amendments to Certain Legislative Acts of the Russian Federation that entered into force on December 25, 2023, made a number of changes to the current legislation on issues related to the founders of NCOs, in particular: persons included in the list of “undesirable” organizations cannot be founders, participants or members of public associations and NCOs; a new procedure for registering voluntary resignation from the founders of an NCO (now the resigning founder of a non-commercial corporation, autonomous non-commercial organization (ANO) or fund must send information about his resignation not to the Federal Tax Service (as in the previous version of the law), but to the territorial department of the MoJ; the exit of the last or sole founder is still not allowed); and the possibility and grounds for excluding persons from the list of founders by decision of the highest body of an ANO or a fund (in the event of the death of the founder-individual; recognition of the founder-individual as incapacitated or missing; in the event of liquidation of the founder-legal entity or exclusion of the founder-legal entity from the Unified State Register of Legal Entities according to decision of the Federal Tax Service).