Last updated: January 31, 2025
What’s new in the law
Recent legislation requires all online advertising displayed in Russia to include specific labeling. Each advertising creative must now have:
An “Ad” label
Information about the advertiser
A link to a page containing detailed advertiser information
Additionally, every ad requires a special identifier from an Advertising Data Operator (ORD) before launch. This identifier is unique to each creative, and all participants in the advertising process – advertisers, agencies, and freelancers – must provide the ORD with details about themselves and their advertising campaigns.
Purpose of the law
The ad labeling system enables monitoring through the Unified Register of Online Ads (ERIR). This registry, accessible to both the Federal Antimonopoly Service (FAS) and Federal Tax Service (FNS), maintains records of:
Advertising creative identifiers
Campaign types and placement platforms
Distribution methods, volumes, and formats
Product and service descriptions
Duration of system placement
Advertising placement contract details
Information about all distribution chain participants, including end advertisers
How this affects your work
The updated Advertising Law (effective September 1, 2022) requires all participants in the advertising distribution chain to ensure complete, accurate, and timely information submission.
Previously, the process was straightforward: an advertiser would assign work to a freelancer (such as a targeting specialist or influencer), who would then place creatives in the advertising system for display.
The addition of the ORD now requires two key interactions:
Pre-launch – submitting information about the planned advertisement, advertiser, and distributor
Post-display – providing campaign statistics within one month after the calendar month of display
New work process
The advertiser (client, end advertiser, or intermediary) assigns work to the freelancer (advertising distributor) through Solar Staff
Either party (as agreed) obtains unique identifiers from the ORD for each advertising creative by providing:
Campaign type and placement platform details
Information about all placement participants, including the end advertiser
Advertising placement contract details
Product and service descriptions
The freelancer incorporates these identifiers into the creatives (text ads, banners, video clips) before campaign launch
The freelancer uploads the labeled creatives to the advertising system (e.g., Yandex Direct advertising account)
The advertising system publishes the user-visible creatives
The second phase involves data transmission to the ORD:
6. The freelancer submits impression statistics per creative and data for certificate generation
7. All participants provide the ORD with placement information and closing certificate data
8. The ORD transfers this information to ERIR
Liability
Violations of online advertising labeling requirements fall under Article 14.3, Part 16 of the Administrative Code. This covers both missing identifiers and improper identifier placement, with fines up to 500,000 rubles per violation. Under Article 38, Part 7 of Law No. 38-FZ, the advertising distributor bears responsibility.
Running ads with tokens but submitting incomplete, inaccurate, late, or missing information to the ORD carries similar penalties up to 500,000 rubles (Article 14.3, Part 15 of the Administrative Code). Both advertisers and distributors may face liability in these cases.
Tax implications are significant: authorities may reject online advertising expenses for tax base reduction. Missing ERIR information allows the Federal Tax Service to assess additional tax and impose penalties (Article 18.1, Part 15 of Law No. 38-FZ).
Changes for companies
Companies must now report data about themselves and all chain participants up to the end advertiser. Advertising distributors submit their information independently.
Changes for freelancers
Individuals and self-employed persons must complete Solar Staff verification, including tax ID (INN) entry in their account. This ensures legal compliance. See our guides on verification and adding your tax ID.
Review the addendum to the offer agreement here.
Where to learn more about ad labeling
Questions? Contact us through the online chat in your Solar Staff account or email [email protected].