This information letter is to inform you of a new position taken by the Federal Antimonopoly Service of Russia (hereinafter referred to as "FAS") regarding liability for distributing advertisements on Telegram and YouTube.
Please be reminded that on 10 March 2026, the FAS website published a clarification regarding a ban on advertising on Telegram, YouTube, and other platforms with restricted access (e.g., VPN services, WhatsApp*, Facebook*).
You can find more information on the positions of FAS and Roskomnadzor regarding the advertising ban on these platforms, as well as on the cases where FAS has initiated proceedings for violations of advertising legislation due to ads posted on Telegram and YouTube channels, in Marillion Information Letter dated 12 March 2026.
In addition to the FAS clarification of 12 March 2026, a new one was published on the FAS website on 25 March 2026. According to this clarification:
- FAS has reaffirmed its position regarding the advertising ban on information resources, access to which is limited in accordance with the laws of the Russian Federation.
- FAS has stated that, in cases of ads placed on Telegram and YouTube, the authority reviews the following:
- the advertising content,
- the date the contract was signed,
- the date restrictions on the platform’s operations were imposed,
- the date the ad was published,
- the grounds for its placement (including contracts and payment orders).
- FAS has noted that market participants need time to adapt to the new rules and transition to other advertising channels.
- Therefore, FAS has announced a transitional period until the end of 2026, during which liability measures for advertising on Telegram and YouTube will not be applied.
- At the same time, FAS has emphasized that this transitional period does not apply to advertising on platforms, access to which had been previously limited (namely, FAS has mentioned Instagram* and Facebook*), nor to advertising via VPN services.
- In the event that advertisements are distributed on the platforms listed above appropriate liability measures will be applied.
It is not clarified whether the transitional period applies only to previously concluded contracts, or whether the transitional period also allows for new contracts to be signed and executed until the end of 2026.
Please be reminded that violation of advertising legislation by an advertiser, advertising producer, or advertising distributor entails administrative liability under Part 1 of Article 14.3 of the Code of Administrative Offenses of Russia in the following amount:
- for officials — from 4 000 to 20 000 rubles;
- for legal entities — from 100 000 to 500 000 rubles.
In addition to fines, FAS may also require the removal of illegally placed advertisements.
Marillion specialists will monitor further clarifications from FAS and Roskomnadzor regarding distribution of advertising on platforms with restricted access, and the practice of holding market participants liable for violating the advertising legislation.
In light of the FAS’s new position, Marillion recommends that market participants conduct an audit of advertising placements on platforms with restricted access, as well as develop a strategy for advertising placements for 2027.
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* are owned by Meta Platforms, Inc., which is recognized as an extremist organization in Russia and banned
