Legal Support in Marketplace Disputes

Federal Law No. 289-FZ “On Certain Matters of Regulation of the Platform Economy in the Russian Federation” enters into force on October 1, 2026. It introduces special rules governing relations between operators of intermediary digital platforms, sellers and other partners.

Before October 1, 2026, these new rules cannot be relied on as requirements already in force. For earlier events, the legal position must be based on the legislation and contractual terms that applied when the specific dispute arose.

If a dispute continues after October 1, 2026, we separately assess which provisions of the new law apply to the specific platform action and period of the relationship.

From October 1, 2026, where the operator unilaterally changes certain material contractual terms — including liability measures, the amount or method of determining the operator’s remuneration, and terms for acceptance, storage, delivery, release, shipment or return of goods — the partner must, as a general rule, be notified at least 45 days before the changes take effect.

For other unilateral changes, the law generally provides for a notice period of at least 15 days. The law contains exceptions, so the applicable period must be assessed based on the nature of the particular change.

From October 1, 2026, a platform operator may reduce the price of goods at the partner’s expense only in the manner and on the terms provided by the agreement and with the partner’s consent as required by law. As a general rule, the operator must notify the partner of the intended price reduction at least five business days in advance.

The partner will be able to set a minimum product price or prohibit sales at a reduced price at the partner’s expense. A seller’s refusal to consent to such a discount cannot itself be grounds for restricting the seller account, terminating a product listing, lowering the rating, worsening search placement or otherwise prejudicing the seller’s interests.

From October 1, 2026, when applying civil-law liability measures to a partner, restricting or terminating a product listing or restricting access to the seller account, the operator must, as a general rule, send a reasoned notice identifying the violated provisions of the agreement or law no later than three days before the measure is applied.

For certain situations, the law allows notice on the day the measure is applied, including where the measure relates to compliance with legislation, enforcement of a court or administrative decision or elimination of unauthorized access to the seller account.

If the circumstances that formed the basis for the restriction are remedied, the law provides for cancellation of the relevant measures within 48 hours from the moment the operator becomes aware that they have been remedied.

To challenge certain operator actions — including liability measures, restriction or termination of a product listing, restriction of a seller account, reduction of rating and changes to a listing’s position in search results — Federal Law No. 289-FZ establishes a mandatory complaint through the platform’s internal pre-trial dispute-resolution system before court proceedings are commenced.

The operator must respond to such a complaint no later than 15 days after it is filed. If the complaint is found justified, the measures applied must be cancelled within 48 hours.

This mandatory procedure begins to apply on October 1, 2026 and must not be applied retroactively to procedural actions completed before the law enters into force.

Where a listing is blocked because of intellectual-property claims, the protected subject matter, rights holder, designation or content used by the seller, product documents and actual manner of use need to be assessed separately. The mere fact that a complaint was submitted does not establish that the claim is justified.