Telegram Moves Towards Establishing a Representative Office in Russia, According to Roskomnadzors List of Companies Needing Localization Compliance

The list of foreign companies required to establish a presence in Russia (operating on the internet within the country) released by Roskomnadzor has been updated with a notification indicating that Telegram Messenger Inc. is preparing to set up a representation in Russia. On the Roskomnadzor website’s page dedicated to Telegram, under the section «Establish a branch, or open a representative office, or create a Russian legal entity,» a note stating «Under consideration» has appeared. Currently, it remains unclear how accurate this information is and when the messaging service will actually establish a presence in Russia.

In the section «Post an electronic form on the information resource(s),» Telegram’s status reads: «Completed.»

Additionally, in the column «Register a personal account on the official website of Roskomnadzor,» it also states: «Completed.»

Since August 18, 2022, Roskomnadzor has taken measures against Telegram that include: «Informing users of the information resource of the foreign entity about the violation by the foreign entity conducting activities on the internet in the territory of the Russian Federation of Russian legislation.»

On July 1, 2021, the law «On the Activities of Foreign Entities in the Information and Telecommunications Network ‘Internet’ on the Territory of the Russian Federation» (Federal Law No. 236-FZ) was enacted. Under this law, foreign internet companies with a daily audience exceeding 500,000 users are required to open authorized offices within Russia.

As of October 2023, Telegram has not responded in any way to the requirement to register in the Roskomnadzor list and comply with the Russian legislation stated in 236-FZ.

For example, the Roskomnadzor list includes the company Apple, which has established its representative office in Russia, as noted.

According to Roskomnadzor data, Viber, Likeme, and AliExpress also have their representations in Russia.