Outreach and Russian law
A plain-English guide for anyone emailing Russian companies: where a business letter ends and unlawful advertising begins, what counts as personal data, and what mistakes cost.
This guide covers the Russian market and Russian law. The European market is a separate market with its own rules (GDPR and national laws such as Germany's UWG); none of the rules below apply there, and Lidarro does not cover it.
Russian law has no B2B carve-out. Advertising sent by email requires the recipient's prior consent, and the sender must prove it (Art. 18(1), Federal Law 38-FZ “On Advertising”). A message is not advertising only if its content is genuinely individual; inserting a name into a template does not count (FAS letter АК/24455/13).
Advertising vs. business letters
Advertising is information addressed to an indefinite circle of persons (Art. 3). The FAS holds that sending to a list does not make the circle definite. A practical test: could the same text be sent to another company unchanged? If yes, treat it as advertising.
Recent practice is strict: in April 2026 the St. Petersburg FAS office treated a commercial offer emailed to a CEO at the address listed in the state register (EGRUL) as unlawful advertising. Case law is mixed.
Personal data (152-FZ)
- Generic company addresses (info@, sales@) are not personal data (case A40-139096/2022).
- A named address with full name and job title is personal data. Direct marketing using personal data requires prior consent (Art. 15) - whether this covers employees in B2B outreach is disputed.
- Since 1 Sep 2025, consent to personal-data processing must be a separate document.
- Since 1 Jul 2025, personal data of Russian citizens must be recorded and stored in databases located in Russia.
- Operators must notify Roskomnadzor and publish a privacy policy.
Fines
| Violation | Rule | Legal entities |
|---|---|---|
| Advertising by email without consent | Art. 14.3(4.1) CAO | RUB 300,000-1,000,000 |
| Processing personal data without legal basis | Art. 13.11(1) CAO | RUB 150,000-300,000 |
| Processing without required consent | Art. 13.11(2) CAO | RUB 300,000-700,000 |
| No notification to Roskomnadzor | Art. 13.11(10) CAO | RUB 100,000-300,000 |
| Using leaked databases | Art. 272.1 Criminal Code | up to 4 years' imprisonment (basic offence) |
Practical rules
- Write to corporate addresses the company published itself.
- Make every email individual: the company's situation, a real reason.
- Identify yourself clearly; never fake the sender.
- Offer a one-line opt-out and honour it immediately.
- Use only lawful sources; never buy leaked lists.
- Keep Russian citizens' personal data in Russia.
Full guide: is cold email legal in Russia
For information only, not legal advice. Status as of 25.10.2026. Check the current wording of the laws and consult a lawyer before launching a campaign.
You can do all of this yourself in Lidarro. Or hand it over to us as a done-for-you service: we build and check the list, write the copy, run the outreach and hand you the leads. We take on the financial risks, including fines.
Pricing depends on your niche and lead value, so we quote individually.