Digest of Changes in Legislation and Law Enforcement Practice: July – August 2026

Dear colleagues,

We present a fresh overview of the latest changes in legislation and law enforcement practice covering July – August 2026.

1. Payment Situation

1.1. Bank Deposits of Non-Residents from Unfriendly Countries: Special Procedure and Exceptions

Presidential Decree No. 95 of 05.03.2022 establishes a special permitting procedure for fulfilling obligations to foreign creditors from unfriendly countries if the amount of obligations exceeds 10 million rubles per month (or the equivalent in foreign currency). This procedure involves either obtaining permission from the Government Commission, or crediting funds to special accounts of type “C”.

By the Decree of the President of the Russian Federation dated 01.06.2026 No. 377, the list of obligations subject to Decree No. 95 was expanded. From June 1, 2026, a special procedure was also applied to the obligations of banks to return deposits (deposits) and pay interest on them in favor of foreign creditors from unfriendly countries.

On July 14, 2026, the Bank of Russia published official explanations that clarified the application of Decree No. 377 to bank deposits:

• The threshold of 10 million rubles is applied individually to each depositor (and not in the aggregate for the bank). If the obligations to a specific depositor in a calendar month do not exceed 10 million rubles, the special procedure is not applied.
• If the threshold is exceeded, the obligations are fulfilled by crediting funds to the C-type account; the use of such funds is possible only in authorized areas or on the basis of a special permission of the Government Commission.
• The rules apply exclusively to bank deposit contracts and do not affect bank account or correspondent account contracts.
• In case of early or urgent return of the deposit, as well as when paying interest, a special procedure is applied. At the same time, before the maturity of the obligation, the bank is not obliged to change the status of the deposit (convert it into an account of type "C").
• The decree does not apply to foreign citizens who have a residence permit in the Russian Federation, as well as to Russian companies whose members include persons from unfriendly countries.

Decree of the President of the Russian Federation dated 04.08.2026 No. 550 in Decree No. 95 made additional changes that significantly narrow the scope of the special order in relation to bank deposits. According to the new version, the rules of Decree No. 95 do not apply to obligations on bank deposits (deposits):

• deposited by individuals who are foreign creditors from unfriendly countries;
• introduced by branches, permanent missions and other separate or independent structural subdivisions of organizations – foreign creditors, provided that the place of registration of such subdivisions is the Russian Federation.

In addition, Decree No. 550 grants these individuals, as well as branches, representative offices and subdivisions the right to receive funds in rubles that were credited by credit institutions to accounts of type “C” in the period from June 1, 2026 until the date of entry into force of this Decree (ie until August 4, 2026). Decree No. 550 entered into force on the date of its official publication.

Thus, at present, a special procedure under Decree No. 95 is reserved for bank deposits of non-resident legal entities from unfriendly countries (except for their branches and representative offices registered in the Russian Federation), but does not apply to deposits of non-resident individuals and deposits of Russian subdivisions of foreign organizations. Previously blocked in accounts of type “C” ruble funds of these categories of depositors are subject to issuance.

1.2. Reminder from the Federal Customs Service on the Rules for Exporting Cash Currency

The FCS of Russia reminded that from March 2, 2022, there is a temporary ban on the export of cash foreign currency from Russia in the equivalent of more than $ 10,000. At the same time, the ban does not apply to exported cash in Russian rubles (subject to the rules of customs declaration).

In accordance with the Decree of the President of the Russian Federation dated 25.03.2026 No. 193, the procedure for exporting cash to the EAEU countries has been limited since this year. Now, when exporting cash in the amount of more than $10,000, a written declaration will also be required, and if the amount exceeds $100,000, confirmation of the origin of the funds is required. Filing a declaration does not entail payment of fees.

The explanations of the FCS also describe in detail the procedure for declaring and provide a list of airports that allow the export of cash currency in accordance with the current procedure.

2. Supply Situation

2.1. Clarifications from the Federal Tax Service on the Operation of the SPOT System

In the letter, the Federal Tax Service answered frequent questions of the Eurasian Economic Commission and foreign trade participants about the procedure for the functioning of the national system for confirming the expectation of goods (SPOT), launched from June 1, 2026. Key clarifications:

• Technical support: a round-the-clock support service for the applicant’s service and a Federal Customs Service hotline are organized.
• Security payment is not required for certain categories of goods: return packaging, goods for testing and research, for participation in exhibitions, under lease / leasing agreements, as well as for goods sold to individuals through electronic trading platforms (ETP). For them, a Document on the upcoming delivery (DPPP) is issued without payment.
• The QR code has no expiration date, the route is not specified in the DPPP, the vehicle can be replaced before crossing the border without creating a new DPPP.
• When transiting goods through the territory of the Russian Federation to third countries, registration of DOP and QR code is not required.
• The carrier must have a visualized reference to the QR code and present it at the request of the regulatory authorities.

Recall that the adaptation period (without making security advances) for Armenia, Kazakhstan and Kyrgyzstan operated until June 30, 2026, for Belarus continues to operate until October 31, 2026.

See also in the media.

3. Other Changes

3.1. Taxes

3.1.1. Official: Postponement of the Reduction of the VAT Exemption Threshold under the Simplified Tax System

On July 4, 2026, the President of the Russian Federation signed Federal Law No. 228-FZ, which postpones the reduction of the annual revenue threshold for VAT exemption for business on the simplified taxation system (simplified tax system). As we informed earlier, from January 1, 2026, the threshold was reduced to 20 million rubles, and it was planned to gradually reduce it to 15 million in 2027 and to 10 million in 2028. Now the threshold of 20 million rubles will remain until 2029.

Further reduction of the threshold has been postponed: to 15 million rubles from 2030, to 10 million rubles from 2031.

3.1.2. Discussion: Exclusion of Trade from the Simplified Tax System?

The Ministry of Finance of Russia requested the position of business associations on the issue of excluding wholesale and retail trade from the list of activities for which simplified tax system can be applied (see media 1, 2). The reason was the appeals of the regions about “tax migration” – registration of sellers working through marketplaces in subjects with reduced simplified tax system rates without real activity there.

According to expert estimates, falling budget revenues from such schemes can reach 75 billion rubles in 2026. The business opposes the complete exclusion, offering to focus on suppressing fictitious registration.

A final decision has not yet been made.

3.1.3. Expansion of the Scope of Controlled Transactions: New Low-Tax Jurisdictions

From January 1, 2026, the updated provisions of subitem 3 paragraph 1 of Article 105.14 of the Tax Code of the Russian Federation came into force (introduced by Federal Law No. 425-FZ of 28.11.2025). Now the transaction is recognized as controlled (without interdependence of the parties), if the total turnover with the counterparty exceeds 120 million rubles. per year and the counterparty is registered in a jurisdiction with a profit tax rate of 15% or lower.

This significantly expands the perimeter of control: transactions with independent counterparties from the UAE, Kuwait, Qatar and other Middle East countries fall under it.

There is no official list of such jurisdictions, taxpayers will have to determine rates independently, requesting information from counterparties. Errors in qualifying threaten transfer pricing fines.

It is important to take into account that according to open sources (see media 1, 2), the tax service has intensified inspections of the TP, paying attention not only to intra-group, but also to foreign trade transactions with independent persons from 91 jurisdictions included in the offshore list of the Ministry of Finance, as well as with products from the special list of the Ministry of Industry and Trade (oil, metals, fertilizers, jewelry).

Recall that fines for violations have increased significantly since 2024: for failure to provide notice of controlled transactions – up to 100,000 rubles, for failure to provide documentation for TP – up to 1 million rubles. The Federal Customs Service seeks to resolve most issues at the analytical stage before the on-site inspection.

Our previous detailed reviews on transfer pricing are available via links 1, 2.

3.1.5. VAT in Case of Changes in Tax Rates under Long-Term Contracts

04.08.2026 was adopted Federal law of 04.08.2026 No 293-FZ. The key principle of VAT application: when tax rates change, VAT is not automatically transferred to the buyer. If the buyer cannot accept the tax for deduction, and the parties have not changed the price of the contract, the amount of VAT is calculated based on the value of the contract, invoices are not issued.

3.1.6. Tax Monitoring: Will It Become Mandatory for SEZ Residents?

The government commission approved a bill obliging large and medium-sized residents of special economic zones (SEZs) to switch to tax monitoring within 2 years from the date of conclusion of the agreement (see media 1, 2). For refusal may be provided for termination of the agreement.

See our earlier review on tax monitoring.

3.1.7. Updated Register of Double Taxation Treaties

In July, the Russian Ministry of Finance has traditionally updated the register of agreements on the avoidance of double taxation. As we informed earlier, information on suspension/denunciation has been added to the register.

From January 1, 2027, the Agreement between Russia and Germany of May 29, 1996 (and the Protocol thereto) is fully suspended. Germany notified Russia of this on June 26, 2026. This means the elimination of foreign tax credits, the risk of double taxation and the inability to claim reduced rates at source on dividends, interest and royalties. It should be noted that the German Federal Ministry of Finance uses the term “suspension” rather than “denunciation”, which means temporary non-application.

See more details in our review.

It is also worth mentioning that Spain included the Russian Federation in its national list of “non-cooperative tax jurisdictions” – in terms of the presence in the Russian Federation of special tax regimes for companies with registration in certain administrative regions. The decision comes into force on December 28, 2026. This does not lead to the abolition of the double taxation treaties between Spain and the Russian Federation, but means stricter tax controls, increased verification of the origin of funds and greater attention to transactions related to Russian companies by the Spanish tax and banking authorities. Recall that Russia was included in the “black list” of the EU from January 29, 2026.

3.2. Corporate Law and Transactions with Unfriendly Persons

3.2.1. Reverse Buyback of Assets under Options

04.08. In 2026, the Federal Law No. 319-FZ dated 04.08.2026 was officially adopted, introducing grounds for the judicial termination of the right of foreign investors from unfriendly states to repurchase Russian assets sold after 22.02.2022. For judicial refusal, confirmation of simultaneous fulfillment of the following conditions is required:

• Investor behavior: public support of unfriendly actions, discrediting the Russian Armed Forces, financing of terrorism, a statement on the termination of activities in the Russian Federation, etc.
• Financial parameters: the repurchase price deviates from the market by 25% or more, or the acquirer has made a significant investment in the asset.

The claim can be filed by the acquirer (it is not necessary to wait for the exercise of the option) or the profile FOIV (with the permission of the board). The case will be heard by the Moscow Region Arbitration Court. The investor has the right to demand compensation within a year, while the court can reduce it or refuse it completely.

See more details in our review.

3.2.2. Relaxations for Corporate Procedures

On July 10, 2026, the Ministry of Finance published official explanations from 01.07.2026, which specified the cases when the permission of the Government Commission for transactions with unfriendly persons is not required (under Decree No. 618):

• Amendments to the charter of an LLC related to the formation, definition of competence or termination of powers of management bodies (for example, the creation of a Board of Directors).
• Repayment of the treasury share (change in the size of the participant’s share as a result of repayment of the share owned by the LLC itself, and a decrease in the authorized capital).

See more details in our review.

3.2.3. Review of the Supreme Court of the Russian Federation No. 8/2026: Transactions with Unfriendly Counterparties

On June 22, 2026, the Thematic Review of the Supreme Court of the Russian Federation No. 8/2026 was published, which significantly changes the approach to risk assessment.

Among the key conclusions of the review, the following should be noted:

• Splitting payments (for tranches up to 10 million rubles to circumvent Decree No. 95) is recognized as an abuse of the right (Article 10, 168 of the Civil Code of the Russian Federation) and entails nullity. In the text of the review, the splitting of payments is mentioned in the context of settlements under credit agreements. However, we cannot exclude the risk that the position will be extended to royalties, dividends or other settlements.
• Real estate transactions involving a person under the control of an unfriendly person (participation of more than 50%) are void without the permission of the Executive Committee, even if carried out between the Russian seller and the buyer.
• Assignment of the right of claim (cession) to a friendly person, made in order to bypass accounts of type "C" or "O" is void.
• Settlement agreements that provide for the payment of money not directly to an unfriendly person, but to his representative in circumvention of the permitting procedure, cannot be approved by the court and are void.
• Limitation of liability of banks: the bank is not liable for losses of the client if the transfer was blocked by the intermediary bank in an unfriendly country due to sanctions imposed later, provided that the sender bank is in good faith.

See more details in our review. We also recommend reviewing the full text of the document.

3.2.4. Draft Law on Limiting Subsidiary Liability

The State Duma introduced a bill aimed at a more balanced regulation of the use of subsidiary liability of managers / controlling persons.

Among other things, it is proposed to:

• Apply liability only for intentional actions clearly aimed at causing harm to creditors (management errors and business risk are excluded).
• The possibility of writing off subsidiary liability under a number of conditions (completion of the repeated bankruptcy procedure of a citizen, expiration of 10 years from the date of adoption of the judicial act, good faith behavior).

The bill is under consideration.

In this context, we also recall that in November 2025, the Supreme Court approved a review of the prosecution of controlling persons for the debts of abandoned companies (excluded from the USRLE).

Key findings:

• Controlling persons may be brought to subsidiary liability in case of exclusion of the company from the USRLE, if as a result of their behavior, settlements with creditors of the specified company became impossible;
• The creditor is not obliged to prove the bad faith of the controlling persons, the burden of proof lies on them;
• A lawsuit can be filed even without trying to prevent the company from being excluded from the USRUL;
• The limitation period begins from the moment when the creditor became aware of the exclusion of the company and the controlling person;
• The mere fact of having the status of a sole participant or director does not constitute a basis for liability; it is necessary to prove the real influence and causality.

3.3. Regulation of Cryptocurrencies

11.08.2026 was published almost 300-page Federal law “On digital currencies and digital rights” No. 282-FZ (signed 04.08.2026), establishing the rules for the circulation of cryptocurrencies in Russia. The main provisions come into force from September 1, 2026, the transition period will last until July 1, 2027.

The law introduces 5 categories of regulated organizations (exchanges, brokers, management companies, depositories, exchangers). After July 1, 2027, transactions with cryptocurrency will be possible only through regulated organizations, banks are obliged to refuse other operations. Payment for goods and services with cryptocurrency within the country is prohibited, but it is allowed to use for operations within the framework of foreign trade.

In parallel, laws on the taxation of cryptocurrencies and on liability for illegal transactions are being developed.

See our article on cryptocurrencies in Russian Business Guide magazine here.

3.4. Migration Sphere

A detailed description of the changes is available in our full review.

Below is a brief summary of the main changes:

3.4.1. Digitalization of Registration

• Since June 30, 2026, the Digital Profile of a Foreign Citizen (Decree No. 735) has been formed. It is a single electronic database of documents, employment, education, insurance, offenses and restrictions on entry.
• From July 1, 2026, as part of the experiment (until December 31, 2027), a mobile application “Public Services RuID” was launched to submit an application for entry to the Russian Federation for citizens of visa-free countries (recommended 72 hours before entry). The QR code is valid for 90 days.
• From 01.09.2025 as part of the experiment in Moscow and the Moscow region, the application "Amina" – the official state application for remote migration registration – was put into operation (see also the application information page). With its help, the foreigner submits a notification of the place of stay, and the application automatically transmits to the Ministry of Internal Affairs data on the geolocation of the smartphone. Mandatory registration in the application "Amina" is subject to foreigners from visa-free countries who came to Russia to work.

The experiment started on September 1, 2025 in Moscow and the Moscow region and will last until September 2029 (based on Federal Law No. 121-FZ).

At the same time, from 01.09.2026, Amina will also become mandatory for visa-free foreigners who are in the capital region for more than 90 days for non-working purposes (study, guest visit, long trip to relatives).

• From October 1, 2026 (data transfer) and from January 1, 2027 (full work), an automatic exchange of information between the Federal Tax Service, the Ministry of Internal Affairs and the SFR is introduced.

3.4.2. New Rules on the Subsistence Minimum and Taxes

From 01.01.2027, Federal Law No. 241-FZ and Federal Law No. 242-FZ of 26.07.2026 come into force, which

• Obliges migrant workers to support themselves and their dependents at a level not lower than the regional subsistence minimum. Lack of confirmed income is the basis for revocation of a patent, TRP or residence permit.
• introduces the obligation to pay a new fixed advance payment on personal income tax when working for individuals: 1700 rubles / month, 1200 rubles / month. – under a patent from legal entities, with an increasing coefficient of 50% for each dependent.

3.4.3. Significant Increase in Requirements for Highly Qualified Specialists

26.07. In 2026, Federal Law No. 241-FZ was officially adopted, which increases the basic income requirement for foreign highly qualified specialists by almost 3 times.

The basic minimum wage threshold for maintaining the status of the HQS is increased from 750,000 rubles / quarter (250,000 rubles / month) to 717,000 rubles / month. The new requirements come into force from 01.03. 2027. The reduced threshold (358 500 rubles / month) can be applied for narrow categories (scientific workers, teachers, SEZ residents, accredited IT companies, Skolkovo participants and innovation centers).

In addition, a requirement for annual indexation of the amount of remuneration of the HQS is introduced.

3.4.4. Other Changes

It is important to take into account that from September 1, 2026, new forms of notifications come into force (Order of the Ministry of Internal Affairs of Russia from 12.05.2026 No. 290). At the same time, the notifications will now require a separate consent to the processing of personal data. State duties for legally significant actions in the migration sphere are also significantly increased.

We recommend employers to analyze the situation with HQS, assess the possibility of raising wages to new thresholds and consider alternative options for registration (quota, TRP, residence permit, list of professions).

We have prepared a consolidated overview of the main migration changes and recommendations; the text is available here.

3.5. Identification of Domain Administrators through ESIA

Federal Law No. 569-FZ of December 29, 2025 from September 1, 2026 introduces mandatory identification of domain name administrators in the Russian national domain zones .ru, .rf and .su through the Unified Identification and Authentication System (ESIA) – the portal "Gosuslugi". The requirement applies to all administrators, including foreign nationals and companies. For individuals, a confirmed account on the Gosuslugi is required; for legal entities, registration of the company in the ESIA and the connection of an authorized employee are required.

Without passing the identification, the administrator loses the ability to extend the domain, make changes to the settings or transfer rights. At the same time, the domain will continue to work until the end of the registration period, but after its expiration, it will go to the waiting status, and then it will be released.

We recommend an inventory of all domains in the .ru, .rf and .su zones, check the administrator’s data and, if necessary, urgently update them or change the registrar (if the current one is not integrated with the ESIA).

See also more details in our review.

3.6. Tax Secrecy on Gosuslugi

Since August 1, 2026, the tax secrecy regime has been extended to documents and information from the personal account of the taxpayer on the Gosuslugi portal. Also abolished the obligation of the Federal Tax Service to massively send paper tax notices: now they are sent in electronic form through public services (by default), paper remain only for those who are not registered on the portal.