Since March 2026, amendments to the law on foreign investment in strategic companies have come into force. Control has become stricter, and requirements have expanded. Here are the key points.
What Has Changed
1.Non-profit organizations (NPOs) are now under control. If an NPO is engaged in strategic activities, transactions involving it must be approved.
2.Acquisition of state or municipal property (if it constitutes fixed assets of strategic enterprises) is now subject to control.
3.The list of strategic activities has expanded:
subsoil use with certain reserve volumes;
extraction of groundwater for commercial sale;
pasture aquaculture;
production of fish products (subject to certain thresholds).
4.Disclosure requirements have tightened. When seeking transaction approval, information about beneficiaries and controlling persons must be provided. Without this, the application will be returned.
5.FAS and Government Commission procedures have been synchronized — this should speed up the process.
New Obligations for Investors
Owning 5% to 50% of shares in a strategic company requires notification to FAS.
Owning more than 50% requires control approval.
Transition Periods
For companies that have just become strategic (e.g., fishing enterprises):
Investor Share
Deadline
Action
5–50%
by December 3, 2026
submit ownership structure information
over 50%
by June 7, 2027
obtain control approval or reduce stake
Risks of Non-Compliance
rejection of transaction approval;
fines;
loss of voting rights by court decision;
forced divestment of shares.
What Businesses Should Do
check whether your company falls under the new criteria;
assess your ownership structure;
if foreign participation exists, file notifications on time;
plan new transactions with the requirements in mind.
How Acsour Can Help
conduct a legal audit of your ownership structure for compliance with the new requirements;
assess whether your transactions or activities fall under the new regulations;
assist in preparing and submitting notifications and applications to the FAS Russia;
advise on transition periods and strategies for bringing your structure into compliance with the law.
Contact us — we will help you navigate the new rules and protect your interests when dealing with foreign investors.