Author: Kirill Kuznetsov, Legal Counsel at Acsour
Effective September 1, 2025, a significant regulatory change will require all personal data operators to provide anonymized datasets to a designated government information system upon request from the Russian Ministry of Digital Development, Communications, and Mass Media ("Ministry of Digital Development").
Purpose of the Reform
The amendments aim to:
Access Requirements
Operators must undergo a compliance audit confirming adherence to Federal Law No. 152-FZ "On Personal Data". The verification procedure (approved under Government Decree No. 702 dated May 22, 2025) includes:
Submission Methods:
• In-person
• Postal delivery
• Via the Gosuslugi portal (where technically available)
Key Audit Criteria:
Processing Timeline:
How Acsour's Legal Team Can Assist
The new framework demands precision in documentation and procedures. We provide end-to-end support:
Proactive adaptation is critical – contact our team to ensure seamless compliance ahead of the September deadline.
Effective September 1, 2025, a significant regulatory change will require all personal data operators to provide anonymized datasets to a designated government information system upon request from the Russian Ministry of Digital Development, Communications, and Mass Media ("Ministry of Digital Development").
Purpose of the Reform
The amendments aim to:
- Establish infrastructure for secure anonymized data exchange between businesses and the state
- Facilitate AI model training using aggregated datasets
- Enhance personal data protection by reducing the processing of identifiable information
Access Requirements
Operators must undergo a compliance audit confirming adherence to Federal Law No. 152-FZ "On Personal Data". The verification procedure (approved under Government Decree No. 702 dated May 22, 2025) includes:
Submission Methods:
• In-person
• Postal delivery
• Via the Gosuslugi portal (where technically available)
Key Audit Criteria:
- Compliance with data protection laws
- Absence of extremist/terrorist affiliations
Processing Timeline:
- 15 business days for review
- Notification of approval or substantiated denial
How Acsour's Legal Team Can Assist
The new framework demands precision in documentation and procedures. We provide end-to-end support:
- Compliance Gap Analysis – Identify potential red flags pre-audit
- Document Preparation – Align submissions with regulatory requirements
- Application Management – Oversee verification timelines and agency communications
- Query Resolution – Draft legally sound responses to regulator inquiries
- Data Disclosure Compliance – Prepare tailored responses to anonymized data requests
Proactive adaptation is critical – contact our team to ensure seamless compliance ahead of the September deadline.
