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Russia's ban on foreign messengers under 41-FZ: who is covered

From June 1, 2025, government bodies, banks, telecom operators and some other organizations in Russia may not use foreign messengers to inform citizens.

Published: 2025-04-08

On April 1, Russia signed Federal Law No. 41-FZ, which creates a state information system to counter offences committed using information and communication technologies, in practice a law against phone and online fraud. One of its provisions, effective June 1, 2025, bars government bodies, banks, telecom operators, owners of goods and services aggregators and several other groups from using foreign messengers to inform Russian citizens. The short answer to the main question: the ban applies only to the organizations listed in Part 1 of Article 15 of the law. Everyone else is not covered by this provision, but it is a good moment for any business to review how it talks to customers.

What happened

The State Duma passed the law on March 25, the President signed it on April 1, and it was published on Russia's official legal information portal. The law is broad: it sets up a government anti-fraud information system and amends the laws on banks, on communications, on the Bank of Russia and others. The ban on foreign messengers is Part 1 of Article 15.

The list of covered organizations was expanded before the second reading. According to Interfax, the Duma's IT committee proposed adding non-bank financial organizations, payment system participants, telecom operators, aggregators, large websites and classified-ad services, and companies with more than 50% state ownership. All of them are in the adopted text.

What exactly is banned

The law does not name specific services. It describes them by features. The ban covers information systems and software that:

  • belong to foreign legal entities and/or foreign citizens;
  • are designed and/or used for exchanging electronic messages exclusively between their users;
  • let the sender choose the recipient or recipients of a message;
  • do not provide for users posting publicly available information on the internet.

The covered organizations may not use such services to inform citizens of the Russian Federation. That is how the provision is worded, and that is the scope in which it should be read.

Who is covered

The list in Part 1 of Article 15 is closed and has seven items.

#Who
1Government bodies and their subordinate organizations, local governments and their subordinate organizations, the Central Bank, state extra-budgetary funds
2State companies, state and municipal unitary enterprises, public-law companies, business companies with more than 50% state and municipal ownership
3Credit institutions; non-bank financial organizations engaged in activities listed in Part 1 of Article 76.1 of the Bank of Russia law; national payment system entities
4Telecom operators
5Owners of goods (services) information aggregators
6Owners of websites and apps where users run personal pages that may carry advertising, with more than 500,000 daily users in Russia
7Owners of classified-ad services with more than 100,000 daily users in Russia

Item 2 covers companies where the combined stake of the Russian Federation, its regions and municipalities exceeds 50% of the charter capital. According to Interfax, the non-bank financial organizations in item 3 include, for example, insurers, non-state pension funds, microfinance organizations, pawnshops, securities market professionals and investment platform operators.

When it takes effect

Part 1 of Article 15 has no separate effective date, so it comes into force together with the law as a whole, on June 1, 2025 (Part 1 of Article 16). That gives covered organizations less than two months.

If your company is not on the list

If you do not belong to any of the seven groups, this provision does not apply to you. Still, it is a good reason to check how much your business depends on a single messenger. The risk usually lies less in the law than in how conversations are organized:

  • History lives in phones. Agreements, orders and contacts sit in managers' personal chats. When an employee leaves, the customer history leaves too.
  • One channel, one point of failure. An account can be blocked, a service can change its business terms, and some customers simply do not use it.
  • No overall picture. Management cannot see how many requests came in, how many went unanswered and how deals ended.

The rule that removes these risks: a customer is a record in your CRM, and messengers, SMS, email and website chat are ways to reach them. Then changing or losing a channel does not mean losing a customer.

Where to move communications

For covered organizations the question is more pressing: notifications that now go through foreign messengers have to move to other channels by June 1. The right mix depends on what you tell customers.

ChannelGood forLimitations
SMSCodes, statuses, short notificationsPaid per message, little room for text
EmailDocuments, invoices, detailed messagesNot read right away, some mail ends up in spam
Customer portalOrder history, documents, requestsCustomers log in themselves, needs a separate alert channel
Your own app with pushFrequent notifications for regular customersCostly for a small base, the app has to be installed
Website chatQuestions and consultationsWorks only while the customer is on the site
Russian messaging servicesA familiar chat formatCheck how many of your customers actually use them

Which channels are acceptable for your particular organization is worth confirming with a lawyer: the law gives the features of a service, not a list of allowed and banned ones.

We have built such owned channels more than once. For a roadside service company for freight transport, we built a portal for customers, suppliers and managers and an API for its mobile app. For a company that verifies utility meters, we built a CRM with a mobile app for iOS and Android with push notifications. In both cases customers and staff work in the company's own digital services connected to its business system.

When there are several channels, they need to come together in one place. We solved this in our own product, DialIQ: conversations from Telegram, WhatsApp, SMS and website chat arrive in one window, an AI operator answers from the company's knowledge base and hands complex conversations to a person, and REST API and webhooks pass conversations to the CRM. Covered organizations can use it as one window for website chat and SMS; others, as a way not to depend on a single messenger. Compliance with the law depends on which channels a company uses to inform citizens, not on the tool that brings those channels together.

What this means for business

For banks, financial organizations, telecom operators, aggregators, large platforms and state-owned companies, this is an urgent task with a clear deadline of June 1. The sooner it is clear which notifications go where, the lower the chance that some customers stop receiving them after that date.

For everyone else, this provision changes nothing directly. But if customer conversations live in one messenger and on employees' phones, that is worth fixing regardless of the law: connect your channels to a CRM and keep the customer history there.

What to do before June 1 if you are covered

  1. Inventory your channels. List everything the company uses to message citizens: bulk notifications, triggered messages from the CRM, chatbots, managers' work phones. For each channel, record who owns the service.
  2. Check against the law. With a lawyer, compare each service with the features in Part 1 of Article 15 and decide which channels stay and which need replacing.
  3. Notification templates. Rewrite texts for the new channels: SMS needs short wording, email and the customer portal allow more detail.
  4. Integrations and scenarios. Switch notification sending in the CRM, business systems and bots to the new channels and test them on test customers before June 1.
  5. Scripts and customers. Update guidelines for managers and tell customers in advance where they will now receive notifications.

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