Fines for social media advertising: what has changed in 2026
In our article "How to Avoid the Spam Folder: Rules for Legal SMS and Email Marketing," we examined what constitutes advertising and the legal requirements for sending promotional messages under Russian law. In this article, we will break down the restrictions on advertising on social media.
Due to the current geopolitical situation, social media has become a channel for disseminating 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 (hereinafter "Roskomnadzor") initiated the blocking of "undesirable social networks" to counter the spread of such information. In 2025, the list of blocked social networks expanded, and with it came specific regulations: as of September 1, 2025, it is prohibited to distribute advertising on information resources that are restricted under Russian law.
Which social networks are prohibited for advertising?
According to Part 10.7 of Article 5 of Federal Law No. 38-FZ of March 13, 2006, "On Advertising," the distribution of advertising on information resources of foreign or international organizations whose activities have been declared undesirable in the Russian Federation is prohibited.
The ban applies to:
- Information resources of foreign and international organizations whose activities have been declared undesirable in Russia (a list is maintained by the Russian Ministry of Justice on its website);
- Information resources of public and religious associations, as well as other organizations for which a court has issued a final decision on liquidation or a ban on activities based on legislation regarding the prevention of extremist activity and terrorism (a list can be found on the Russian Ministry of Justice website);
- Information resources to which access is restricted in accordance with legislation on information, information technologies, and information protection.
Social networks currently banned in Russia include:
- Instagram;
- Threads;
- Facebook;
- Twitter;
- LinkedIn;
- Viber;
- Discord;
- Reddit.
What is considered advertising activity?
As stated in Order No. 821/23 of the Federal Antimonopoly Service of Russia dated November 14, 2023, advertising activity includes:
- Paid integrations with influencers or companies, such as stories and posts;
- Free or barter-based advertising;
- Targeted advertising.
Liability for advertising on restricted social media platforms
Since no specific offense category has been introduced yet, Part 1 of Article 14.3 of the Code of Administrative Offenses of the Russian Federation applies: fines are imposed for each individual violation—that is, for every advertising post, story, or reel. Please note that both the advertiser and the advertising distributor are held equally liable.
A temporary exception to the general rule should be noted separately. A so-called "advertising amnesty" is in effect until December 31, 2026: liability measures for distributing advertising do not apply to individuals posting on Telegram and YouTube, despite the restricted access to these resources. However, please note that in March 2026, the FAS of Russia initiated a case against the fashion Telegram channel "Loskutova Maria" due to two advertising integrations posted in January–February 2026. The basis for this was not a lack of labeling, but the very fact of posting on a resource with "restricted" access. In essence, this case demonstrates that even an amnesty valid until the end of 2026 does not guarantee complete immunity.
As the FAS states: "It is obvious that business entities need time to adapt to the new rules and reorient themselves toward other advertising channels. Therefore, a transition period until the end of 2026 is necessary for advertising on Telegram and YouTube, during which liability measures for distributing advertising on such resources will not be applied."
Recommendations from the C Cases team
- Audit your social media accounts and remove any advertising posts (if applicable);
- Use the transition period for Telegram and YouTube with caution, keeping in mind that FAS practice regarding these platforms is still evolving and the advertising amnesty could be reinterpreted by the regulator;
- Develop alternative platforms not restricted by Roskomnadzor for your advertising integrations.
If you, as an advertiser or advertising distributor, need to determine whether a specific post falls under the ban on advertising on social media, audit current advertising integrations and related contracts, adjust content formats in line with the legal positions of regulatory authorities, or assess the risks of administrative liability, the C Cases team can help prepare a "working" set of documents for you and protect your interests in dealings with counterparties and regulatory bodies.
Sources
- Federal Law No. 38-FZ of March 13, 2006 (as amended on December 29, 2025) "On Advertising";
- Code of Administrative Offenses of the Russian Federation No. 195-FZ of December 30, 2001;
- Order of the FAS of Russia No. 821/23 of November 14, 2023 "On Approval of the Guidelines for Compliance with Mandatory Requirements 'The Concept of Advertising'".