With this informational letter, we announce a new position of the Federal Antimonopoly Service of Russia (hereinafter referred to as "FAS") and Roskomnadzor regarding the ban on advertising on Telegram and YouTube channels, as well as on other platforms with restricted access (e.g., VPN services and WhatsApp*).
Ban on advertising on Telegram
On 5 March 2026, one of the Telegram channels published the FAS ruling dated 26 February 2026 on the initiation of proceedings regarding the distribution of advertising for a fitness platform on a Telegram channel. According to the blogger, the advertisement was arranged through a contract, with proper labeling, and in compliance with all necessary requirements.
The case was initiated on the basis of a Roskomnadzor letter regarding identified signs of violation of advertising legislation on the Telegram channel in January and February 2026. The case is scheduled for consideration on 25 March 2026.
According to the information in the published FAS ruling, the publication of advertising on a Telegram channel violates Part 10.7 of Article 5 of Federal Law No. 38 dated 13 March 2006 "On Advertising" (hereinafter referred to as "Advertising Law"), which prohibits the distribution of advertising on information resources of organizations whose activities:
- are declared undesirable on the territory of Russia; or
- are prohibited under legislation on extremist or terrorist activities; or
- are on information resources with access restricted in accordance with legislation on information protection.
According to the FAS position expressed in its ruling, access to the Telegram messenger is restricted by Roskomnadzor under Article 15.3 of Federal Law No. 149 dated 27 July 2006 " On Information, Information Technologies, and Information Protection".
At the same time, the FAS ruling does not contain a reference to any specific document or other source according to which access to the Telegram messenger was officially restricted by Roskomnadzor.
Ban on advertising on YouTube
On 6 March 2026, another Telegram channel published the text of the FAS ruling dated 25 February 2026 on the initiation of proceedings regarding the distribution of advertising for energy bars on a blogger’s YouTube channel in January 2026.
The FAS reasoning regarding the ban on advertising on YouTube channels is similar to the FAS argumentation regarding the ban on advertising on Telegram channels.
Official explanations and comments from FAS and Roskomnadzor
At the time the information about the initiation of proceedings regarding illegal advertising distribution on Telegram and YouTube channels emerged, no official explanations from the authorities were available, while various media outlets received the following comments:
- due to the measures taken to restrict access to YouTube video hosting, VPN services, and the Telegram and WhatsApp* messengers, FAS sees signs of violations of advertising legislation in placing advertising integrations on these platforms;
- FAS reminded market participants about the existing ban on advertising on Instagram* and Facebook*, and also noted that both the advertiser and the advertising distributor are liable for violations of advertising legislation.
- FAS recommended that market participants review the content posted on information resources with restricted access;
- Roskomnadzor, in turn, commented that it considers FAS explanations
exhaustive, thereby, in our view, confirming FAS’s position.
On 10 March 2026, FAS published explanations on advertising legislation enforcement on its website.
In these explanations, FAS reiterated the position previously expressed in media comments and confirmed the prohibition of advertising on YouTube, VPN services, Telegram, and WhatsApp*.
According to FAS explanations: "If Roskomnadzor takes measures to restrict access to information resources in accordance with the law, advertising on such resources is prohibited".
Business community reaction
Part 10.7 of Article 5 of the Advertising Law, which prohibits advertising distribution on information resources with restricted access, came into force on 1 September 2025.
However, until now, there have been no known cases of initiating proceedings or imposing liability for advertising distribution on Telegram and YouTube channels. Consequently, the news of the ban on advertising on these platforms caused a great stir.
Until now, Telegram and YouTube were considered resources that had not been formally blocked by Roskomnadzor.
These platforms were subject to speed restrictions, which formally differ from official access restrictions. Moreover, Telegram and YouTube are not listed in the registry of blocked resources.
Furthermore, when officially registering Telegram and YouTube channels with more than 10 000 subscribers, the following notification from Roskomnadzor still appears: "The channel owner may place advertising based on advertisers' requests".
At the same time, there is an opinion that in the event of legal proceedings regarding the prohibition of advertising distribution on Telegram, FAS and Roskomnadzor may base their position on the 2018 decision of the Tagansky District Court on restricting access to Telegram (case No. 2-1779/2018), as this decision has not been formally reversed.
Potential liability
Please be reminded that violation by an advertiser, advertising producer or advertising distributor of advertising legislation entails administrative liability under Part 1 of Article 14.3 of the Code of Administrative Offenses of the Russian Federation 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 advertising distribution on platforms with restricted access, and the practice of holding market participants liable for violating the advertising legislation.
At the same time, in connection with the new position of FAS and Roskomnadzor, Marillion recommends that market participants conduct an audit of advertising placements, and consider suspending advertising on Telegram, YouTube, and other platforms with restricted access, or incorporate the associated risks in advertising project budgets.
Marillion specialists are ready to assist you in this matter.
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* are owned by Meta Platforms, Inc., which is recognized as an extremist organization in Russia and banned
