Dear Colleagues,

Updating the information previously provided, we present a fresh overview of recent legislative developments and enforcement practice covering September 2026, as well as changes expected in the coming months.

1. Payments

1.1. New restrictions on taking cash rubles abroad

On 29 September 2026, the President of the Russian Federation signed Decree No. 706, amending Decree No. 193 of 25 March 2026 on the special procedure for taking Russian cash currency abroad. The decree entered into force on the date of signature (see also media reports 1, 2).

Key changes:

• For individuals, the limit on taking cash rubles to EAEU member states has been reduced from the equivalent of USD 100,000 to RUB 1 million; any excess is subject to seizure. Larger amounts may still be taken out only through international airports designated by the Russian Government, with bank documents confirming withdrawal of the funds from an account;
• The restrictions have been extended to Azerbaijan, Tajikistan and Uzbekistan;
• For legal entities and individual entrepreneurs, the ban in force since 1 April 2026 on taking cash rubles to these countries remains in place regardless of the amount; a violation entails seizure of the entire amount. Exceptions apply to international transport where both the point of departure and destination are outside Russia, subject to supporting documents, and to transfers based on notification by the Russian Ministry of Foreign Affairs to support diplomatic missions and consular posts.

The Russian Government, in agreement with the Bank of Russia, has been instructed to approve a procedure for recording cash rubles taken abroad within three months.

The following previously introduced restrictions also remain in force:

• Since 2 March 2022, taking foreign cash currency exceeding the equivalent of USD 10,000 out of Russia has been prohibited;
• The Bank of Russia has extended restrictions on foreign cash withdrawals until 9 March 2027: individuals may withdraw no more than USD 10,000, or the equivalent in euros, from foreign-currency accounts opened before 9 March 2022; residents may receive cash US dollars, euros, pounds sterling and yen only for business travel expenses within the prescribed limits; non-residents may not receive cash in these currencies.

1.2. Non-resident transfers: restrictions retained

The Bank of Russia has retained for six months from 1 October 2026 the ban on transfers abroad from accounts held with Russian brokers and trust managers by non-resident individuals and legal entities from unfriendly states. Funds of foreign investors recorded in type “In” accounts remain exempt.

As a reminder, the Bank of Russia’s general restrictions on cross-border transfers by non-residents from unfriendly countries are currently in place through 7 December 2026 inclusive.

Individuals resident in unfriendly countries who are officially employed in Russia may transfer funds abroad up to the amount of their salary. The ban on transferring funds abroad remains in place for legal entities from unfriendly states; it does not apply to foreign companies controlled by Russian persons.

No decision has yet been taken on the arrangements to apply after 7 December.

1.3. New channels: cryptocurrency settlements in foreign trade

As previously reported, Federal Law No. 282-FZ “On Digital Currencies and Digital Rights” entered into force on 1 September 2026, allowing digital currency to be used for settlements under foreign trade contracts (see our previous overview and our 2024 article on the legalization of cryptocurrencies).

On the same day, according to media reports, Sberbank launched a cross-border cryptocurrency settlement service for corporate clients engaged in foreign trade. Public sources indicate an average transaction cost of 0.3%, no minimum payment amount, transfers between crypto wallets completed within minutes, and automatic generation of documents for currency control purposes (see report).

Legislation on the taxation of cryptocurrency transactions is still being developed. Before using the new channel, we recommend agreeing with your bank on the supporting documents required and reviewing the accounting and tax treatment of such settlements.

1.4. Bank of Russia plans for cross-border settlements

On 11 September 2026, the Bank of Russia published the draft Guidelines for the Development of the Financial Market for 2027–2029.

For foreign trade settlements, the regulator plans to develop alternative settlement mechanisms and payment channels, reduce business costs and gradually lift restrictions on capital movements as the economy adapts.

In addition, according to media reports, the Bank of Russia plans to increase the limit on transfers between legal entities through the Faster Payments System. The timing and specific parameters have not yet been determined; we will monitor developments.

1.5. Digital ruble: the first stage of mass implementation has begun

From 1 September 2026, systemically important banks and banks significant in the payment services market must enable clients to transact in digital rubles. Merchants with revenue exceeding RUB 120 million in the previous year that are serviced by such banks must accept digital ruble payments (see Bank of Russia information). Further stages are scheduled for 1 September 2027 and 1 September 2028.

2. Banking news

2.1. Tax registration through a bank for foreign organizations

From 1 September 2026, under Federal Law No. 416-FZ of 17 November 2025, a foreign organization opening an account with a Russian bank is registered with the tax authority on the basis of the bank’s application. Within five days of receiving that application, the tax authority registers the organization and sends the bank an extract from the Unified State Register of Taxpayers. The foreign company no longer needs to apply to the tax authority itself.

For more on opening and servicing accounts for foreign companies, their Russian subsidiaries and representative offices, see our overview.

See also our overview of the legal forms through which foreign businesses can operate in Russia.

2.2. More banks subject to sanctions

On 23 July 2026, the Council of the EU adopted the 21st sanctions package. In the financial sector:

• The transaction ban was extended to a further 33 Russian credit and financial institutions;
• A bank in Kyrgyzstan connected to the Financial Messaging System (SPFS), as well as three other banks in third countries facilitating sanctions circumvention, became subject to the ban;
• Transactions were prohibited with 14 cryptocurrency platforms registered in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan and Belarus;
• Courts and competent authorities in EU member states were granted the right to refuse recognition and enforcement of judgments arising from claims brought before Russian courts.

On 6 August 2026, the United Kingdom added six Russian banks to its sanctions list: Ozon Bank, Roseximbank, Center-invest Bank, Realist Bank, Stavr Bank and Teleport Bank.

On 18 September 2026, H.R. 5334, the Lindsey O. Graham Sanctioning Russia and Iran Act of 2026, was signed into law in the United States, expanding the statutory basis for sanctions, tariff measures and prohibitions concerning Russia. The practical consequences will depend on the US administration’s implementation decisions. We will monitor developments.

Before making cross-border payments, we recommend checking the current status not only of the payer’s and recipient’s banks but also of correspondent banks.

3. Supply chains

3.1. SPOT: security payments on supplies from Belarus from 1 November

As previously reported (see our previous overview), the System for Confirmation of Expected Goods (SPOT) has operated since 1 June 2026, and security payments have been mandatory for supplies from Armenia, Kazakhstan and Kyrgyzstan since 1 July.

The exemption from security payments for supplies from Belarus entering via the Russia–Belarus border applies through 31 October 2026 inclusive; no information on an extension was available when this overview was prepared.

Accordingly, from 1 November 2026, obtaining a QR code for goods imported from Belarus by road will require a security payment equal to the import VAT and excise duties.

According to information from the Ministry of Finance and the Federal Customs Service, additional budget receipts generated by the system had reached RUB 33.8 billion by 10 September 2026, against an annual target of RUB 50 billion.

The business community’s proposal to replace the security payment with a bank guarantee is to be considered in the autumn. Businesses also propose reducing the revenue threshold for exempting compliant taxpayers from RUB 30 billion to RUB 5–10 billion.

Final decisions on adjustments to the system have not yet been taken.

3.2. Customs monitoring: pilot extended until 2029

Russian Government Resolution No. 1188 of 18 September 2026 extends the customs monitoring pilot until 31 March 2029, previously 31 March 2027. Eligibility has also been expanded: Russian declarants not classified as high-risk may join. Applications will be accepted until 30 September 2028. The resolution enters into force on 19 October 2026.

As a reminder, participants provide customs authorities with remote access to data in their accounting systems and, where risks are identified, have an opportunity to rectify violations themselves before customs control measures are applied.

3.3. Electronic transport documents: no penalties before March 2027

From 1 September 2026, under Federal Law No. 140-FZ, carriers, freight forwarders, consignors and consignees are required to issue transport documents electronically through the State Information System for Electronic Transport Documents (GIS EPD). The requirement covers road, rail and air consignment notes, transport orders and freight forwarding documents.

Paper documents remain available, in particular:

• For military and special cargo transport;
• For transactions with foreign counterparties;
• For transport for individuals’ personal needs;
• For border-area operations and in territories with special status.

According to information from the Ministry of Transport, an adaptation period applies until 1 March 2027: penalties for using paper documents instead of electronic ones will not be imposed. Please note that the ministry announced this adaptation period, but no regulatory act on the matter had been published when this overview was prepared.

3.4. New obligations for manufacturers and importers

A technology levy introduced by amendments to the Federal Law “On Industrial Policy in the Russian Federation” will apply from 1 December 2026. Manufacturers and importers of radio-electronic products will pay the levy.

The Ministry of Industry and Trade has prepared a draft order setting rates, including RUB 746 per laptop and RUB 373 per smartphone; rates are lower for products included in the relevant directory and higher for those not included (see also media coverage). The rates remain at the draft stage.

In addition, from 1 October 2026, manufacturers begin applying identification markings to household and sanitary-hygiene products, including paper towels, toilet paper, toothbrushes and diapers. Registration in the Chestny ZNAK system has been mandatory since 1 September 2026 (Russian Government Resolution No. 656 of 30 May 2026).

4. Other developments

4.1. Taxation

4.1.1. Under discussion: 35% tax on dividends paid into type “C” accounts?

On 24 September 2026, the Russian Government approved the budget package for 2027–2029; the bills are scheduled to be submitted to the State Duma by 1 October. The proposed tax measures are intended to take effect from 2027 (see media reports 1, 2). They include:

• An increase from 15% to 35% in the corporate income tax rate on dividends paid into type “C” accounts to non-residents from unfriendly states;
• Taxation of individuals’ passive income, including dividends, deposit interest, securities transactions and property sales, at progressive rates of 13–22%; income from deposits of up to RUB 1 million would not be taxed;
• VAT at 22% on cross-border e-commerce, with electronic platforms acting as tax agents, and a customs fee of RUB 100 per parcel valued at up to EUR 200;
• Corporate income tax at 15% on passive income of mutual investment funds;
• A tax on additional income arising from increases in world prices for companies extracting solid minerals, at 30%, or 20% for gold producers.

The higher dividend tax rate would affect foreign groups receiving dividends from Russian subsidiaries. As a reminder, the double taxation treaty between Russia and Germany will also be suspended from 1 January 2027 (see our overview and Telegram post).

We recommend taking the proposed changes into account when planning the timing of profit distributions. The parameters may change as the bills are considered; we will monitor developments.

4.1.2. Official: new rules on tax penalties

From 1 September 2026, amendments to Articles 112 and 114 of the Russian Tax Code introduced by Federal Law No. 425-FZ of 28 November 2025 apply: where mitigating circumstances exist, a penalty is reduced by a factor of at least two but no more than ten; previously, there was no upper limit on the reduction (the amendments were introduced by Article 1 of Federal Law No. 425-FZ; see the current version of Article 114 of the Tax Code).

As a reminder, Bill No. 1215257-8 on easing liability for late submission of returns, which we previously reported, has been enacted as Federal Law No. 201-FZ of 26 June 2026:

• The penalty under Article 119(1) of the Tax Code does not apply if a late tax return or calculation shows no tax payable;
• Individuals are not fined for failing to submit a 3-NDFL return upon the sale or gift of real estate;
• Taxpayers may submit evidence of mitigating circumstances together with the late return.

4.1.3. Consideration of tax audit materials by videoconference

From 1 September 2026, Federal Law No. 425-FZ (Article 1; see the current versions of Article 101 and Article 101.4 of the Tax Code) amended Article 101(2) and Article 101.4(7) of the Tax Code to permit participation by videoconference in the consideration of tax audit materials and reports on tax offenses identified outside an audit.

The procedure for such participation was approved by Federal Tax Service Order No. ED-1-2/567@ of 11 August 2026, published on 31 August 2026 and entering into force one month after publication:

• Participants connect from the tax office at the organization’s location or the individual’s place of residence, provided the tax authorities have the technical capability;
• A request to participate by videoconference must be sent to the tax authority considering the materials;
• The tax authority must notify the applicant of the possibility of videoconference participation at least three working days before the hearing;
• In the event of technical failures, consideration is postponed or conducted in person; videoconferencing is not used where the materials contain state secrets.

At the same time, Federal Tax Service Order No. ED-1-2/568@ of 11 August 2026 approved the format and procedure for submitting written objections and supporting documents electronically.

4.1.4. Tax monitoring: new rules for reorganizations

Amendments to the tax monitoring procedure introduced by the same Law No. 425-FZ took effect on 1 September 2026 (Article 1; see the current version of Article 105.26 and the subsequent articles of Section V.2 of the Tax Code):

• Legal successors of reorganized participants may continue tax monitoring without meeting the monetary thresholds if they update the previously submitted documents within one month; the monitoring period is not interrupted by the reorganization;
• The grounds for early termination of monitoring have been expanded, including non-compliance with requirements for information exchange, information systems and internal control systems, and repeated violations of information access procedures.

As a reminder, our previous overview covered the government-approved bill on mandatory tax monitoring for special economic zone residents (see also our Telegram post). The general tax monitoring procedure is described in our overview.

4.1.5. Accounting: amendments to PBU 18/02

Russian Ministry of Finance Order No. 121n of 20 August 2026 amended PBU 18/02 “Accounting for Corporate Income Tax.” The amendments concern accounting for deferred tax assets and liabilities when corporate income tax rates change, and the recognition of income tax relating to transactions included in the period’s comprehensive financial result.

The order entered into force on 29 September 2026. We recommend assessing its impact on the 2026 annual financial statements in advance.

4.2. Corporate law and transactions with unfriendly persons

4.2.1. Temporary management in the event of security violations

Presidential Decree No. 604 of 24 August 2026 “On Measures to Ensure the Security of Critical Infrastructure Facilities of the Russian Federation” empowers the Russian Government, acting on instructions from the President, to introduce temporary management of business entities’ property where critical infrastructure security requirements are violated. The facilities concerned include fuel and energy, industry, communications, transport and logistics, municipal infrastructure and life-support facilities.

Grounds may include, in particular:

• Failure to take security measures, or delays in taking them;
• Ineffective organization of measures to counter unmanned aerial vehicles;
• Delays in restoring a facility’s operation.

Rosimushchestvo is appointed temporary manager unless the Government designates another person. The temporary manager may not dispose of the property. Unlike Decree No. 302, the new mechanism is not limited to assets of persons from unfriendly states.

4.2.2. Bill on creditor protection during reorganization

The Russian Government has submitted Bill No. 1342008-8 to the State Duma to amend Article 60 of the Civil Code. It proposes that a court should reject a creditor’s demand for early performance due to the debtor’s reorganization if the debtor demonstrates that there is no material threat to performance of the obligation.

If adopted, the amendments could facilitate intragroup reorganizations. The bill is under consideration.

As a reminder, the Russian Ministry of Finance previously clarified when corporate procedures in companies involving persons from unfriendly states do not require Government Commission approval (see our overview).

4.3. Migration

As previously reported, a range of migration law changes takes effect in 2026–2027. The principal changes and our recommendations for employers are set out in our full overview and Telegram posts on digital registration, new personal income tax payments and requirements for highly qualified specialists.

4.3.1. Medical examinations: a uniform 30-day deadline

From 1 September 2026, Federal Law No. 162-FZ of 10 June 2026 (Article 1, amending Article 5 and Articles 6, 6.1, 13 and 13.3 of Federal Law No. 115-FZ “On the Legal Status of Foreign Citizens in the Russian Federation”) establishes a uniform deadline for foreign nationals to undergo medical examinations: 30 calendar days from entry into Russia.

It applies to foreign nationals arriving for more than 90 days or for employment, and when obtaining a work permit, work patent or temporary residence permit. Repeat examinations are conducted annually.

Federal Law No. 163-FZ of 10 June 2026 (Article 1, introducing Article 18.11.1 of the Code of Administrative Offenses) introduced administrative liability for violations of the examination procedure: a fine of RUB 25,000–50,000, with possible administrative expulsion.

4.4. Employment relations

The Russian Government approved the working calendar for 2027 by Resolution No. 1187 of 17 September 2026. Days off are moved from 2 January to 5 November, from 3 January to 31 December, and from 20 February to 22 February. There are 247 working days in 2027; standard working time for a 40-hour week is 1,972 hours.

As a reminder, amendments to the Labor Code took effect on 1 September 2026 under Federal Law No. 144-FZ of 25 May 2026:

• The annual overtime limit may be increased from 120 to 240 hours if a collective agreement or sectoral agreement so provides;
• Overtime exceeding 120 hours is paid at no less than double the regular rate;
• The employee threshold for small businesses permitted to enter into fixed-term employment contracts by mutual agreement has been raised from 35 to 70.

4.5. Personal data: new criteria for “adequate” countries

Federal Law No. 265-FZ of 26 July 2026 was published and entered into force on 3 August 2026, changing the procedure for recognizing foreign states as ensuring adequate protection of personal data subjects’ rights. Participation in Council of Europe Convention No. 108 alone is no longer sufficient: a country’s rules must comply with the Convention and ensure personal data confidentiality and security.

Roskomnadzor approves the list of such states; an updated list had not been approved when this overview was prepared.

A country’s status affects cross-border data transfer procedures, including the use of a parent company’s information systems, cloud services and CRM systems.

We will monitor developments.

4.6. Upcoming deadlines

For planning purposes, we summarize adopted and expected changes taking effect in the coming months:

• 1 October 2026: commencement of marking household and sanitary-hygiene products (section 3.4); the procedure for considering tax audit materials by videoconference takes effect (section 4.1.3);
• 19 October 2026: the resolution extending and expanding customs monitoring takes effect (section 3.2);
• 23 October 2026: Bank of Russia Board meeting on the key rate, currently 14%;
• 1 November 2026: SPOT security payments for supplies from Belarus (section 3.1);
• 1 December 2026: collection of the technology levy begins (section 3.4);
• 7 December 2026: expiry of the current Bank of Russia restrictions on non-resident cross-border transfers (section 1.2);
• 1 January 2027: abolition of separate corporate income tax returns for certain separate subdivisions; suspension of the double taxation treaty with Germany; fixed advance personal income tax payments for foreign workers; an increase in the minimum wage to RUB 28,935, subject to enactment; budget-package tax measures, subject to enactment;
• 1 March 2027: new salary requirements for highly qualified specialists, RUB 717,000 per month (see our overview); end of the adaptation period for electronic transport documents (section 3.3);
• 9 March 2027: expiry of the current restrictions on foreign cash withdrawals (section 1.1);
• 1 September 2027: second stage of digital ruble implementation (section 1.5).