In March 2026, Russia’s Federal Antimonopoly Service (FAS) began opening cases against advertisers and Telegram channel owners. The legal basis is Part 10.7 of Article 5 of the Advertising Law: the agency argues that any advertising on a platform subject to Roskomnadzor restrictions — throttling, call limits — is unlawful.
Here is a calm breakdown of who is exposed, who is currently safe, and what to do right now.
Who faces fines: advertisers, bloggers, Telegram Ads
Advertisers and brands. If you have paid for integrations, seed placements, or banners on Telegram, you are in the risk group. The ERID marking token, required under Russia’s ad-labelling rules, now works against you: it creates a paper trail confirming that you placed advertising on a restricted platform.
Bloggers and channel owners. FAS classifies them as ad distributors. The agency’s position: the author’s legal structure — sole proprietor, LLC, or individual — is irrelevant. Both the client and the placement partner face liability.
Telegram Ads. The messenger’s official advertising dashboard has landed in the same grey zone. FAS draws no distinction between native integrations and platform-managed targeting.
Fines under Part 10.7, Article 5 reach 500,000 rubles per violation.
Who can use Telegram without violating the law
The dividing line is whether content meets the legal definition of “advertising” under Article 3 of the Advertising Law.
Personal blogs and expert content. Writing about your cases, professional observations, or industry commentary — without a direct commercial call to action for a specific paid product or service — does not constitute advertising.
Information about your own services. Writing in your own channel “I am a lawyer, book a consultation” falls under Article 2 of the Advertising Law as information about professional activity, not advertising.
Comparative reviews. Materials comparing multiple products without highlighting one as “the best” and without purchase links generally fall outside the legal definition of advertising.
Content targeting foreign audiences. If your channel is aimed at audiences outside Russia and you do not accept ruble payments, Russian advertising law does not apply to that activity.
What advertisers and bloggers on Telegram should do now
For advertisers
Pause all Telegram placements until the first court rulings land — expected by late March 2026. That window will clarify how courts interpret the FAS position.
Reallocate budgets to platforms with an unambiguous legal status: VKontakte, Odnoklassniki, Yandex Direct.
Review agency contracts. They should include a clause providing for refunds if a placement becomes unlawful due to regulatory decisions. If that clause is absent, the financial risk sits entirely with you.
For bloggers and channel owners
Consider hiding or deleting paid posts from January–February 2026. The statute of limitations for administrative offences is one year; earlier posts are out of reach.
Stop applying ERID tokens to new posts. The token was designed to mark ads as compliant — but on a restricted platform it now serves as the primary evidence of a violation.
Shift from direct sales formats toward expert editorial content. It is harder to monetise immediately, but it substantially reduces legal exposure.
What happens next: Telegram advertising under legal uncertainty
This situation is unusual: operating “by the rules” on popular platforms has become riskier than operating informally. FAS has not yet developed consistent case law, and the first court decisions will define what liability actually looks like in practice.
If you run commercial activity through Telegram, now is the right time to audit your content and contracts — before a formal notice arrives.
Read Also
- Challenging FAS Procurement Decisions: When It Makes Sense
- Serial Litigants in Marketing: When a Consent Checkbox Leads to Court
Need an audit of your channel content or advertising contracts? Get in touch to discuss your situation.