In our article "How not to end up in spam: rules for lawful SMS and email marketing", we looked at what counts as advertising and what rules Russian law sets for sending advertising messages lawfully. In this article we look at the restrictions on advertising on social media.

Given the current geopolitical situation, social media have become one of the channels for spreading information that may threaten the constitutional order of the Russian Federation. In 2022, the Federal Service for Supervision of Communications, Information Technology and Mass Media ("Roskomnadzor") began blocking "undesirable social networks" to counter the spread of such information. In 2025, the list of blocked social networks grew, and with it came dedicated regulation: since 01.09.2025, it has been prohibited to place advertising on information resources to which access is restricted under Russian law.

On which social networks is advertising prohibited?

Under Article 5(10.7) of Federal Law No. 38-FZ of 13 March 2006 "On Advertising", advertising may not be placed on the information resources of a foreign or international organisation whose activities have been declared undesirable in the Russian Federation.

The ban covers:

• Information resources of foreign and international organisations whose activities have been declared undesirable in Russia (the Ministry of Justice keeps a list on its website);
• Information resources of public and religious associations and other organisations in respect of which a court has issued a final decision to liquidate them or ban their activities on grounds provided for by legislation on countering extremism and terrorism (the list can be found on the Ministry of Justice website);
• Information resources to which access is restricted under legislation on information, information technologies and information protection.

Social networks banned in Russia include:

• Instagram;
• Threads;
• Facebook;
• Twitter;
• LinkedIn;
• Viber;
• Discord;
• Reddit.

What counts as advertising activity?

According to FAS Order No. 821/23 of 14.11.2023, advertising activity includes:

• Paid integrations with bloggers or companies — stories, posts;
• Free or barter advertising;
• Targeted advertising.

Liability for advertising on banned social networks

A specific offence has not yet been introduced, so Article 14.3(1) of the Code of Administrative Offences applies: a fine is imposed for each separate violation — that is, for each advertising post, story or Reel. Note that the advertiser and the advertising distributor are equally liable.

Individuals — RUB 2,000 to RUB 2,500.

Officials and sole proprietors — RUB 4,000 to RUB 20,000.

Legal entities — RUB 100,000 to RUB 500,000.

A temporary exception to the general rule should be singled out. Until 31.12.2026, a so-called "advertising amnesty" applies: no liability is imposed for advertising on Telegram and YouTube, even though access to these resources is restricted. Note, however, that in March 2026 the FAS opened a case against the fashion Telegram channel "Loskutova Maria" over two advertising integrations placed in January–February 2026. The grounds were not the lack of labelling but the very fact that the ads were placed on a resource to which access is "restricted". In essence, this case shows that even the amnesty in force until the end of 2026 does not guarantee full immunity.

As the FAS states: "Clearly, businesses need time to adapt to the new rules and switch to other advertising channels. A transition period until the end of 2026 is therefore needed for advertising on Telegram and YouTube, during which no liability will be imposed for advertising on these resources."

Recommendations from the C Cases team

• Audit your social media and remove any advertising posts;
• Use the Telegram and YouTube transition period with caution, bearing in mind that FAS practice on these platforms is still taking shape and the regulator may reinterpret the advertising amnesty;
• Develop alternative platforms not banned by Roskomnadzor for placing advertising integrations.

If, as an advertiser or advertising distributor, you need to determine whether a particular publication falls under the ban on advertising on social media, audit your current advertising integrations and the related contracts, adjust your content format in line with the positions of the supervisory authorities, or assess the risk of administrative liability, the C Cases team will help you prepare a "working" set of documents and protect your interests in dealings with counterparties and supervisory authorities.

Sources

• Federal Law No. 38-FZ of 13.03.2006 (as amended on 29.12.2025) "On Advertising";
• Code of Administrative Offences of the Russian Federation No. 195-FZ of 30.12.2001;
• FAS Order No. 821/23 of 14.11.2023 "On Approval of the Guidelines on Compliance with Mandatory Requirements 'The Concept of Advertising'".