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Federal Law No. 425-FZ dated November 28, 2025, introduces important changes to the procedure for reducing fines in the presence of mitigating circumstances. Beginning September 1, 2026, a maximum limit for reducing penalties is established — fines can now be reduced by no more than 10 times.
Previously, the law set only a minimum threshold — no less than 2 times. In practice, courts could reduce fines by tens or even hundreds of times, guided by principles of proportionality and fairness. The new rules introduce certainty but simultaneously narrow the scope for significant penalty mitigation.
Previously, the law set only a minimum threshold — no less than 2 times. In practice, courts could reduce fines by tens or even hundreds of times, guided by principles of proportionality and fairness. The new rules introduce certainty but simultaneously narrow the scope for significant penalty mitigation.
What Exactly Changes
Under the amendments to Article 4.1 of the Code of Administrative Offenses of the Russian Federation:
In other words, even with multiple mitigating circumstances, the fine amount cannot be reduced by more than 10 times from the minimum amount prescribed by the relevant article.
- the lower limit for fine reduction remains unchanged — no less than 2 times;
- the upper limit is now established — no more than 10 times.
In other words, even with multiple mitigating circumstances, the fine amount cannot be reduced by more than 10 times from the minimum amount prescribed by the relevant article.
Why This Matters for Businesses
For entrepreneurs and companies, this means:
- increased risk of actual liability — where fines could previously be reduced by 50 or 100 times, the maximum reduction is now capped at 10 times;
- the need to reassess approaches to tax and legal compliance — relying on a "lenient" approach by courts becomes less justified;
- the importance of timely violation correction — mitigating circumstances (voluntary compensation, cooperation with investigations, absence of severe consequences) remain relevant, but their effect is now limited by the new cap.
What Mitigating Circumstances Are Considered
Under the Code of Administrative Offenses of the Russian Federation, mitigating circumstances include:
- remorse of the person who committed the offense;
- voluntary reporting of the offense;
- prevention of harmful consequences;
- voluntary compensation for damages;
- commission of the offense under strong emotional distress or due to difficult personal or family circumstances;
- commission of the offense by a minor;
- commission of the offense by a pregnant woman or a woman with a young child.
What Businesses Should Do
Given the new rules, companies need to:
- strengthen internal controls over compliance with tax, labor, immigration, and other legislation;
- respond promptly to identified violations, correct them in a timely manner, and compensate for damages;
- establish risk management systems to minimize the grounds for liability itself;
- when disputes arise, build a position that properly considers all mitigating circumstances.
How Acsour Can Help
Acsour experts are ready to:
Contact us — we will help reduce the risks of liability and protect your business from excessive penalties.
- conduct audits of your activities to identify tax, labor, and administrative risks;
- develop internal regulations and control systems to minimize violations;
- advise on the application of new rules for fine reduction.
Contact us — we will help reduce the risks of liability and protect your business from excessive penalties.
