Further legal developments on regulation of foreign tech companies’ activities in Russia

Following on from the adoption on 16 July 2021 of a new law regulating foreign tech companies’ activities in Russia, the Russian personal data and tech regulator (Roskomnadzor) has adopted a methodology (in Russian) for determining the daily number information resources users.

The new law applies to foreign tech companies, including those not represented in Russia, that meet certain criteria (for more on this matter, see our blog post), which, in particular, includes access by 500,000 or more users from Russia to the tech company’s internet resource.

According to the methodology, the number of users shall primarily be determined based on the information provided by the relevant tech companies themselves based on Roskomnadzor’s requests. Therefore, we can expect major tech companies not represented in Russia will soon receive requests from Roskomnadzor to provide the number of their Russian users per day.

Should this information not be provided by the companies, Roskomnadzor shall determine the number of Russian users of the relevant resources using special software or by collecting publicly available information in the internet.

The methodology shall be applied from 2 August 2021.