By Order of the Ministry of Digital Development, Communications and Mass Media of the Russian Federation No. 511 dated June 2nd, 2025 (the "Order"), additional disclosure requirements have been introduced for information published on accredited IT companies’ websites. The amendments took effect on November 21st, 2025.
Below is a detailed overview of the new requirements as a Q&A.
1. What additional information must be published on the website, and in which cases?
Under Clause 2 of the Order, every accredited IT company's website must contain information sufficient to identify the company, including
In addition to identification data, the website must include a description of the goods or services offered by the company, as well as accurate price information for such goods and services (see additional guidance for providing this information below).
In certain cases, the website must also disclose information on key software tools and certain categories of permits for processing data, including the following:
1) Pursuant to Clause 3 of the Order, the website must contain information regarding the company’s possession of exclusive rights to computer programs and databases, as well as the methods for granting rights to use such programs, in cases where these objects were created:
2) Pursuant to Clause 4 of the Order, the website must contain information on the programming languages, software, or sets of rules and tools used by the IT company for software development or for its programming processes, provided that the company possesses such tools.
3) Pursuant to Clause 5 of the Order, the website must publish information sufficient to identify the program in the Domestic Software Register, as well as the methods for granting rights to use such program, if the company is the rights holder of software included in the Domestic Software Register.
4) Pursuant to Clause 6 of the Order, the website must contain information on the company’s possession of a permit to process fiscal data, if the IT company is a fiscal data operator.
2. What additional website-operation requirements does the Order introduce besides the necessary information listed above?
Pursuant to Clause 7 of the Order, the website must operate on a 24/7 basis and allow unrestricted access to the website without registration and without providing personal data.
3. How should information on the prices of goods and services be disclosed?
In accordance with sub-clause "и" of Clause 2 of the Order, the website must contain accurate information on the prices of goods sold, services rendered or works performed.
Disclosure of accurate information presupposes the publication of pricing data that can, in fact, be included in a contract with a counterparty and is not merely a marketing figure (including artificially reduced prices for promotional purposes). Otherwise, the requirement of "accuracy" will not be fulfilled.
At the same time, the Order allows for exceptions in cases where the pricing calculation is subject to a trade secret regime.
Pursuant to Clause 2, Article 3 of the Federal Law "On Trade Secrets", trade secrets may include information of any nature, including financial information, as well as information concerning methods of conducting professional activity, that has actual or potential commercial value due to its being unknown to third parties.
Accordingly, the pricing formula, as well as individual criteria affecting the final price of goods and services for a specific counterparty, may be legitimately protected under a trade secret regime, which eliminates the necessity of publishing the precise pricing formula in such cases.
At the current stage, it is difficult to assess how the exemption related to trade secrets will be applied. Most likely, this concerns situations in which the business model presupposes the execution of a non-disclosure agreement prior to disclosing information on the prices of goods sold or services rendered. It is important to note that this relates specifically to a trade secret regime, and not to any form of confidential information.
Given that the current requirements regarding the publication of accurate pricing remain rather vague, it is recommended, at a minimum, to indicate on the website a minimum threshold price, such as "starting at XXX rubles", along with a statement that the exact price will be determined considering the customer’s requirements. At the same time, the minimum threshold must be accurate to comply with the requirements of the Order.
This approach will reduce the risk of misleading a potential counterparty regarding the price of a potential contract, as the counterparty will be informed that the cost will be calculated based on its specific request.
4. In what form must the required information be presented on the website?
The Order does not regulate the form in which information on the company’s prices for goods and services must be provided.
Under these circumstances, an IT company is entitled to determine independently the format in which such information is disclosed. However, it must be considered that, in accordance with Clause 7 of the Order, once such information is posted, it must be accessible to all website users regardless of registration and without the need for any additional request.
5. Can the trade secret regime be applied to information on prices for services (goods) and to pricing methodology?
Considering Clause 2, Article 3 of the Federal Law "On Trade Secrets", the trade secret regime may be established only with respect to information that is held in secrecy.
Accordingly, the establishment of such a regime is possible with respect to the pricing methodology, such as pricing formulas, but not with respect to the final price communicated to a counterparty (except for situations where the counterparty undertakes non-disclosure obligations before obtaining the price - for example, under an NDA).
6. How should information on the price be indicated if a customized service (work) is performed?
In our view, indicating on the website a minimum threshold price, such as "starting from XXX rubles", together with a statement that the final price will be determined considering the customer’s requirements, may reduce the risk of violating the provisions of the Order.
It is also possible to provide an approximate pricing methodology, considering the trade secret regime established in the company, which will allow website visitors to calculate an accurate price.
7. What are the sanctions for failure to publish the required information on the company’s website?
Considering Clauses 17 and 22 of Russian Government Decree No. 1729 dated September 30, 2022, in the event of non-compliance by a company that is only applying for accreditation, such accreditation may be denied; for an already accredited IT company, such accreditation may be revoked.
The above provisions of Russian Government Decree No. 1729 dated September 30, 2022 contain a direct reference to the necessity of complying with the requirements relating to the publication of information on the company’s official website.
Below is a detailed overview of the new requirements as a Q&A.
1. What additional information must be published on the website, and in which cases?
Under Clause 2 of the Order, every accredited IT company's website must contain information sufficient to identify the company, including
- full corporate name;
- registered address;
- Taxpayer Identification Number (TIN);
- primary and IT-related OKVED activity codes;
- contact details (telephone number and email address).
In addition to identification data, the website must include a description of the goods or services offered by the company, as well as accurate price information for such goods and services (see additional guidance for providing this information below).
In certain cases, the website must also disclose information on key software tools and certain categories of permits for processing data, including the following:
1) Pursuant to Clause 3 of the Order, the website must contain information regarding the company’s possession of exclusive rights to computer programs and databases, as well as the methods for granting rights to use such programs, in cases where these objects were created:
- by the IT company itself; or
- by its subsidiary, if the IT company’s participation interest exceeds 50%; or
- by its parent company or founder, if such participation exceeds 50%.
2) Pursuant to Clause 4 of the Order, the website must contain information on the programming languages, software, or sets of rules and tools used by the IT company for software development or for its programming processes, provided that the company possesses such tools.
3) Pursuant to Clause 5 of the Order, the website must publish information sufficient to identify the program in the Domestic Software Register, as well as the methods for granting rights to use such program, if the company is the rights holder of software included in the Domestic Software Register.
4) Pursuant to Clause 6 of the Order, the website must contain information on the company’s possession of a permit to process fiscal data, if the IT company is a fiscal data operator.
2. What additional website-operation requirements does the Order introduce besides the necessary information listed above?
Pursuant to Clause 7 of the Order, the website must operate on a 24/7 basis and allow unrestricted access to the website without registration and without providing personal data.
3. How should information on the prices of goods and services be disclosed?
In accordance with sub-clause "и" of Clause 2 of the Order, the website must contain accurate information on the prices of goods sold, services rendered or works performed.
Disclosure of accurate information presupposes the publication of pricing data that can, in fact, be included in a contract with a counterparty and is not merely a marketing figure (including artificially reduced prices for promotional purposes). Otherwise, the requirement of "accuracy" will not be fulfilled.
At the same time, the Order allows for exceptions in cases where the pricing calculation is subject to a trade secret regime.
Pursuant to Clause 2, Article 3 of the Federal Law "On Trade Secrets", trade secrets may include information of any nature, including financial information, as well as information concerning methods of conducting professional activity, that has actual or potential commercial value due to its being unknown to third parties.
Accordingly, the pricing formula, as well as individual criteria affecting the final price of goods and services for a specific counterparty, may be legitimately protected under a trade secret regime, which eliminates the necessity of publishing the precise pricing formula in such cases.
At the current stage, it is difficult to assess how the exemption related to trade secrets will be applied. Most likely, this concerns situations in which the business model presupposes the execution of a non-disclosure agreement prior to disclosing information on the prices of goods sold or services rendered. It is important to note that this relates specifically to a trade secret regime, and not to any form of confidential information.
Given that the current requirements regarding the publication of accurate pricing remain rather vague, it is recommended, at a minimum, to indicate on the website a minimum threshold price, such as "starting at XXX rubles", along with a statement that the exact price will be determined considering the customer’s requirements. At the same time, the minimum threshold must be accurate to comply with the requirements of the Order.
This approach will reduce the risk of misleading a potential counterparty regarding the price of a potential contract, as the counterparty will be informed that the cost will be calculated based on its specific request.
4. In what form must the required information be presented on the website?
The Order does not regulate the form in which information on the company’s prices for goods and services must be provided.
Under these circumstances, an IT company is entitled to determine independently the format in which such information is disclosed. However, it must be considered that, in accordance with Clause 7 of the Order, once such information is posted, it must be accessible to all website users regardless of registration and without the need for any additional request.
5. Can the trade secret regime be applied to information on prices for services (goods) and to pricing methodology?
Considering Clause 2, Article 3 of the Federal Law "On Trade Secrets", the trade secret regime may be established only with respect to information that is held in secrecy.
Accordingly, the establishment of such a regime is possible with respect to the pricing methodology, such as pricing formulas, but not with respect to the final price communicated to a counterparty (except for situations where the counterparty undertakes non-disclosure obligations before obtaining the price - for example, under an NDA).
6. How should information on the price be indicated if a customized service (work) is performed?
In our view, indicating on the website a minimum threshold price, such as "starting from XXX rubles", together with a statement that the final price will be determined considering the customer’s requirements, may reduce the risk of violating the provisions of the Order.
It is also possible to provide an approximate pricing methodology, considering the trade secret regime established in the company, which will allow website visitors to calculate an accurate price.
7. What are the sanctions for failure to publish the required information on the company’s website?
Considering Clauses 17 and 22 of Russian Government Decree No. 1729 dated September 30, 2022, in the event of non-compliance by a company that is only applying for accreditation, such accreditation may be denied; for an already accredited IT company, such accreditation may be revoked.
The above provisions of Russian Government Decree No. 1729 dated September 30, 2022 contain a direct reference to the necessity of complying with the requirements relating to the publication of information on the company’s official website.