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.