From 1 October 2026: new rules for marketplaces and sellers

What changes

From 1 October 2026 marketplaces, service aggregators and delivery platforms listed in the state register of intermediary digital platforms must deal with sellers, contractors and pickup-point owners under uniform rules that the platform can no longer rewrite unilaterally.

From what date

The main law comes into force on 1 October 2026. On the same day the accompanying amendments to the Consumer Protection Law and the Trade Law take effect, together with administrative fines for breaches of the new rules.

Then comes a phased roll-out. The Ministry of Economic Development must publish the register of platforms no later than 2 November 2026. Secondary regulations that impose mandatory requirements take effect no earlier than 90 days after official publication, so part of the machinery will reach the market only in 2027.

Who is affected

First of all, anyone who sells goods or provides services through large platforms. The Government has classified as intermediary platforms those with an average daily audience of 100,000 users or more and either an annual transaction volume of 50 billion roubles or more, or 10,000 or more sellers with at least one transaction in the previous year. Every major marketplace, ride-hailing service, food delivery and services platform falls within these thresholds.

The law addresses specific groups directly: sellers of goods, including sole traders and the self-employed; contractors providing services through a platform as individuals; owners of pickup points; and buyers. And the platform operators themselves, who now have dedicated supervision by the Federal Antimonopoly Service and Rospotrebnadzor.

Who is not covered: online stores selling only their own goods, banking and financial services, app stores, audiovisual services, public procurement platforms, and bankruptcy and privatisation auctions.

How it was and how it will be

The contract. Previously a seller accepted the platform's standard offer, and its terms could change at any moment, often retroactively. Now the contract must contain an exhaustive list of liability measures, a complaints procedure, the principles behind ratings and search ranking, and the rules for settlements and for calculating the platform's fee. The operator must keep the current version and all previous versions of the contract for at least three years and make them accessible from the seller's account.

Changing the terms. Previously sellers learned about new commissions from a newsletter, sometimes a day in advance. Now the platform must give at least 45 days' notice of tougher liability measures, a higher commission, a change in how the commission is calculated, a reduction in pickup-point remuneration, or changes to the terms of acceptance, storage, delivery and returns. All other changes require at least 15 days' notice. The only exceptions are changes that improve the seller's position or bring the contract into line with the law.

Seller-funded discounts. Previously a platform could cut the price of a product out of the seller's pocket at its own discretion. Now this requires notice at least five working days in advance and the seller's consent in the form set by the contract. The seller may set a minimum price, which counts as a ban on selling below it at the seller's expense. Refusing a discount cannot be grounds for blocking the account, removing a listing, lowering the rating or pushing the listing down in search results.

Blocking and sanctions. Previously a listing could be removed and an account closed without explanation. Now the grounds are limited by the law and the contract, and before applying any measure the operator must send a reasoned notice identifying the breached provisions at least three days in advance. If account access is restricted, the seller must retain access to the contracts, the reconciliation statements and the complaints section. Once the breach is remedied, the measures must be lifted within 48 hours.

Disputes. Previously a complaint to support was a gesture of goodwill. Now a pre-trial complaint through the platform's own system is mandatory before going to court over sanctions, listing removal, account blocking, rating reductions and search-position changes. The operator must respond within 15 days, and if it upholds the complaint it must lift the measures within 48 hours.

The product listing. Previously documentation requirements depended on the platform. Now, for goods subject to mandatory conformity assessment, state registration or labelling, the seller must include in the listing a link to the entry in the relevant register, and the platform must not allow listings without this data. The Trade Law now expressly prohibits any seller from publishing offers for goods without valid certificates, declarations, registration certificates or labelling, as well as unregistered dietary supplements, medicines, medical devices and pesticides.

The buyer. Previously a claim about goods bought on a marketplace had to be addressed to the seller directly, often in another region. Now the operator is treated as an aggregator owner under the Consumer Protection Law and must provide the technical means to submit claims to the seller directly on the platform, refund money through the platform and, where delivery was made through the platform's own logistics, accept the returned goods through that logistics.

Pickup points. Previously the relationship between a pickup point and the platform was governed only by the contract. Now the operator must adopt rules for dealing with pickup-point owners that allocate the risk of damage to and loss of goods, and a reduction in pickup-point remuneration is one of the changes requiring 45 days' notice. Settling with a buyer at a pickup point does not turn it into a retail outlet, unless goods not ordered on the platform are displayed and sold there.

Individual contractors. For couriers, drivers and tradespeople working through a platform as self-employed individuals, the law sets out the features that keep the relationship civil-law rather than employment: an order for a specific job with no work schedule or internal rules, the right to decline an order without penalty, and payment for each order separately. The platform must restrict a contractor's systematic work for a single customer under criteria to be set by the Government.

What to do now

1. Audit your listings. For every product, check whether it is subject to mandatory conformity assessment, state registration or labelling, and add a link to the register entry to the listing. The platform will remove listings without documents itself, and the seller faces a fine.
2. Re-read the platform's contract in its new version. Platforms updated their standard terms for 1 October. Find the list of liability measures, the complaints procedure, the rating and ranking rules and the settlement procedure. Whatever is not in the contract, the platform is not entitled to apply.
3. Set minimum prices. Set a minimum price for each product in your account or switch on the ban on seller-funded discounts. This is the only way to stop automatic promotions without your consent.
4. Keep a log of notices. Record the date of every notice of a contract change and count 45 or 15 days. A change introduced ahead of time can be challenged.
5. Request a reconciliation statement. The operator must provide it within seven working days and update it at least monthly. This is the document where any dispute about money starts.
6. Prepare a complaint template. From 1 October a court will not hear the dispute without a prior complaint through the platform's system. The complaint must include documents showing that the operator's actions were unjustified, so screenshots of notices and correspondence should be kept from day one.
7. Pickup-point owners should request the operator's approved rules of interaction and check them against the allocation of liability for damage to and loss of goods.

What happens if you do nothing

A seller who publishes a product listing in breach of the requirements is liable under the Administrative Offences Code from 1 October: for sole traders and officers a fine of 5,000 to 30,000 roubles, for companies 30,000 to 70,000 roubles, and for a repeat breach up to 50,000 and 200,000 roubles respectively. The listing will be removed, and a removal made to comply with the law cannot be challenged through the pre-trial system.

A seller who has not set a minimum price and does not respond to a discount notice risks a promotion at their own expense on the terms the platform writes into the contract as the form of consent.

A seller who goes to court bypassing the complaint on the platform will have the claim returned and lose time while the listing is not selling.

An operator that breaches the discount procedure faces a fine of 100,000 to 300,000 roubles for the company and 30,000 to 80,000 roubles for officers. Supervision is exercised by the Federal Antimonopoly Service without scheduled inspections, that is, on complaints from market participants, while requirements for listings and pickup points are supervised by Rospotrebnadzor.

What the law does not contain

No clarity on what happens between 1 October and the publication of the register. Under the text, a platform becomes an intermediary platform from the moment it is entered in the register, and the register will appear no later than 2 November. Formally, in October a platform may take the view that the law does not yet apply to it, although the fines for listings under the Trade Law apply to any seller regardless of the register. This is the first question on which case law will emerge.

No procedure for checking listings. The list of registers against which the platform must verify documents, and the procedure for interacting with them, are to be set by the Government. Until those rules appear, each platform checks as it sees fit, and requirements for sellers will differ.

No form of consent to a discount. The law refers to the form set by the contract. This means the platform itself will decide what consent looks like, and one should expect constructions such as "participation in the promotion by default with a right to opt out". Whether such constructions comply with the law will be decided by the antimonopoly service or a court.

No criteria for systematic work for a single customer for individual contractors. The Government will set them for particular sectors; until then the line between civil-law and employment relationships stays where it was.

No direct compensation mechanism for a seller after an unjustified block. The law requires the measures to be lifted within 48 hours, but losses for days of downtime are recovered under the general rules of civil law, and they will have to be proved in court.

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

If your business depends on a platform and you want to get through the first months under the new rules without removed listings and lost promotions, get in touch. The first consultation is free of charge when an engagement agreement is signed.

Legislation: Federal Law No. 289-FZ of 31 July 2025 "On Certain Issues of Regulating the Platform Economy in the Russian Federation"; Federal Law No. 290-FZ of 31 July 2025 "On Amendments to Certain Legislative Acts of the Russian Federation"; Federal Law No. 295-FZ of 4 August 2026 (administrative liability); Government Resolutions No. 54 of 28 January 2026 (platform criteria) and No. 504 of 30 April 2026 (register rules).

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