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MYTH OF THE MONTH

Myth of the month: from 1 October businesses must register a state e-mail

All September entrepreneurs have been told that from 1 October they urgently need a state e-mail, or else fines and missed letters. I opened the text of Federal Law No. 271-FZ of 26 July 2026 and checked every claim of this myth against it. Below: where it came from, what the law actually contains and what is genuinely worth doing.

Published
30 September 2026
Author
Vladimir Kovalev
Topic
IT, telecoms and digital
Reading
11 min

The myth

"From 1 October 2026 all legal entities and sole proprietors must register an official e-mail address on Gosuslugi, from 2027 all official correspondence will go only there, and after seven days any letter is deemed received even if nobody opened it." In this form the claim has been circulating in newsletters and Telegram channels all September. Of its four statements one is true, and that one with a caveat.

Where the myth comes from

The source is real: Federal Law No. 271-FZ of 26 July 2026 "On Amendments to the Federal Law 'On Postal Communications' and Certain Legislative Acts of the Russian Federation" adds a new Article 32.1, "Electronic Mail System", to Federal Law No. 176-FZ of 17 July 1999 "On Postal Communications". Three things grow out of it that concern every legal entity and every sole proprietor.

First, Russian Post gets a state electronic mail system through which public authorities, the Bank of Russia, state corporations and state-owned companies will send applications, notices, summonses and demands to the Gosuslugi portal instead of by registered paper letter.

Second, every company, sole proprietor and citizen registered in the unified identification system (ESIA) will get an electronic mailbox on Gosuslugi with its own e-mail address. The address is created by the state, not chosen by the user. For legal entities and sole proprietors the mailbox will be paid.

Third, this address will go into the Unified State Register of Legal Entities (EGRUL) and the register of sole proprietors (EGRIP) as the organisation's official e-mail address. The data will be passed to the register not by the applicant but by the Ministry of Digital Development. It is to this address that the tax service will send documents and notices under Federal Law No. 129-FZ of 8 August 2001 "On State Registration of Legal Entities and Sole Proprietors".

What the law actually says about dates

Article 11 of the law on entry into force, faithfully.

The general date of entry into force is 1 March 2027. From that date the electronic mail system itself operates, public authorities are obliged to send legally significant messages through it to Gosuslugi, and the amendments to the state registration law apply: the e-mail address in EGRUL and EGRIP becomes the address created under Article 32.1.

The provisions on electronic mailboxes of companies and citizens, on sending messages specifically to the mailbox, on the fee for the mailbox and on suspending access for non-payment enter into force later: 1 September 2027. The amendments to the Housing Code on delivering utility bills to the personal account on Gosuslugi start on the same date.

From 1 January 2027 only the "postal" provisions apply: opening hours of post offices and a cap of 1.5 per cent on the fee for delivering pensions and benefits. They have nothing to do with business.

The date 1 October 2026 does not appear in the law. It circulates in the news as the expected deadline by which the Government should adopt the regulation on the electronic mail system and the procedure for creating mailboxes. Those secondary acts have not yet been published, and until they are there is nothing to register and no need to: mailboxes are created automatically, and the procedure and timing are set by the Government.

Who is affected

All legal entities and sole proprietors, with no exceptions by size or line of business. The only exemptions from the fee are public authorities, state and municipal unitary enterprises and institutions, organisations with public powers and the Bank of Russia.

Citizens are affected more gently: receiving messages in the mailbox is free, and only sending is paid. A citizen may restrict the circle of senders from whom they are willing to receive messages, except public authorities and organisations with public powers.

A separate category for which the law already changes the way of working: public authorities, the Bank of Russia, state companies, state corporations and legal entities in which the Russian Federation holds more than 50 per cent. From 1 March 2027 they must send legally significant messages through the electronic mail system to Gosuslugi wherever a law or contract provides for sending such messages through the e-government infrastructure.

What already applies and what does not yet

It was. Official correspondence with a company went to the EGRUL address by registered letter. An e-mail address in the register was optional and given at registration. A legally significant message was deemed delivered under Article 165.1 of the Civil Code of the Russian Federation: when it reached the addressee, including where the addressee evaded collecting it at the post office.

From 1 March 2027. State senders move to the electronic mail system. A message is deemed delivered to Gosuslugi if the organisation or citizen logged into the personal account within seven days of the message being posted. If there was no login, Russian Post must convert the message into a registered letter and deliver it on paper. This is an important clarification: many retellings say that after seven days the message is "deemed received by force of law" without any delivery. Article 32.1 contains nothing of the kind: where there is no login, the law sends the message to paper rather than deeming it served.

From 1 September 2027. The company gets an electronic mailbox with an address the state creates itself. Where a law, other act or term of a transaction provides for sending a legally significant message through the Gosuslugi infrastructure, it must be sent to the mailbox. There are several exceptions: sending through electronic document exchange under the Tax Code, through the multifunctional information exchange service, by another method that records delivery with the addressee's written consent in the contract, and messages under the laws on public services, on citizens' appeals and on state control, as well as the Bank of Russia's supervisory correspondence. The seven-day rule applies to the mailbox too.

For the register. The e-mail address in EGRUL and EGRIP is no longer "if stated in the application" but the mailbox address under Article 32.1, and it is passed to the Federal Tax Service by the Ministry of Digital Development. Under paragraph 6 of Article 11 and paragraph 3.1 of Article 21 of Federal Law No. 129-FZ the registering authority sends registration documents and notices of forthcoming removal from the register to this address. Previously this worked only where an address was in the register; now everyone will have one.

For housing and utilities. Bills for housing and utilities may be delivered to the payer's personal account on Gosuslugi with the payer's consent; such a document is deemed received on the day after posting. For companies owning premises this means that management company invoices will also move to electronic form.

What is genuinely worth doing

  1. Check whether the company has a verified legal entity account on Gosuslugi and which employees have access to it. The mailbox will be created inside that account, and access to it becomes a matter of corporate security rather than convenience.
  2. Appoint someone responsible for the account and describe the procedure in an internal regulation: who logs in, how often, to whom messages are forwarded. From 1 March 2027 the seven-day period runs from the day the message is posted, not from the day the lawyer learns of it.
  3. Review notice clauses in contracts with counterparties. The law allows the parties to agree in the contract on another method of sending legally significant messages that records delivery. If electronic document exchange or corporate e-mail suits you better, the written consent in the contract needs to be in place before September 2027.
  4. Check the e-mail address currently shown in EGRUL. Until 1 March 2027 the tax service keeps writing to it; after that date the register will start moving to state-created addresses and the old address will cease to be official.
  5. Budget for the mailbox fee from September 2027. There is no tariff yet; the Government will set it. For non-payment access to the mailbox is suspended, and that is the only sanction the law names expressly.
  6. If the company owns many properties, prepare the accounts department for bills arriving on Gosuslugi.

What happens if you do nothing before 1 October

Nothing. Not a single provision of Law No. 271-FZ concerning companies and sole proprietors applies before 1 March 2027, the law introduces no fines for not having a mailbox, and the mailbox itself can be neither set up nor missed: the state creates it.

And what happens later if nobody watches

From 1 March 2027 messages from public authorities, the Bank of Russia and state companies will start arriving on Gosuslugi, and an organisation that does not watch its account will receive them on paper with a delay, while on login the period to respond or appeal will run from the seventh day. From 1 September 2027 the mailbox and its fee are added; an unpaid mailbox will be closed, but the duty to receive correspondence does not go away. The law introduces no administrative liability for an "unregistered mailbox", because there is nothing to register: it will appear by itself.

The myth, point by point

"Must register from 1 October": no, there is no registration at all, the address is created automatically and the timing of its creation has not yet been approved. "From 2027 correspondence only goes there": partly, from 1 March 2027 public authorities and state companies move there, while private counterparties may agree another method. "Deemed received after seven days": no, without a login the letter goes to paper. "Fines": no, the only sanction in the law is disconnection of an unpaid mailbox from September 2027.

What the law does not contain

No tariff. The amount, procedure and timing of the fee for the mailbox and for sending messages are set by the Government; there are no acts yet.

No procedure for creating mailboxes. The timing of creation, suspension of access and deletion of mailboxes is also left to the Government, and it is these acts that determine when addresses start appearing in practice.

No replacement of the registered address. The idea of allowing companies to state an e-mail address instead of a physical seat has been discussed in the State Duma since 2023 in separate bills, but Law No. 271-FZ does not implement it: the physical address remains, and the electronic address is added to it.

No duty for private correspondence. Between two commercial companies the law does not force the use of the mailbox if the contract provides another notice method that records delivery.

This material is for information only and does not replace advice on a specific matter.

If you want to bring your contracts and internal regulations into line with the new notification system in advance, get in touch. The first consultation is free when a contract is signed.

Legislation: Federal Law No. 271-FZ of 26.07.2026 "On Amendments to the Federal Law 'On Postal Communications' and Certain Legislative Acts of the Russian Federation" (published 26.07.2026, Articles 1, 3, 6, 11); Federal Law No. 176-FZ of 17.07.1999 "On Postal Communications" (new Article 32.1); Federal Law No. 129-FZ of 08.08.2001 "On State Registration of Legal Entities and Sole Proprietors" (Articles 5, 11, 21); Civil Code of the Russian Federation (Article 165.1); Housing Code of the Russian Federation (Article 155).

Vladimir Kovalev — lawyer, founder and managing partner of Kovalev & Partners LLC

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