Inclusion of marketplaces in the register of intermediary digital platforms

26 Jun 2026
#Analytics
Author
Managing Partner / Patent Attorney of the Russian Federation / Eurasian Patent Attorney

In recent years, there has been a rapid development of the e-commerce market in Russia. Thus, in 2025, online sales already accounted for a fifth of all retail sales in Russia, and by 2026, the total turnover of goods and services through marketplaces and electronic services had already provided over 5% of Russia's GDP. Given the growth rate of the e-commerce market and its importance for the Russian economy, last year, a special law "On Certain Issues of Regulation of the Platform Economy in the Russian Federation" (hereinafter referred to as the Law on the Platform Economy) was adopted, which will come into force in October 2026.

In particular, this law establishes the legal framework for the activities and rules for the functioning of marketplaces - operators included in a special register of intermediary digital platforms approved by the Ministry of Economic Development of Russia (hereinafter referred to as the Register). This means that marketplaces with the status of an operator, as well as their partners (sellers) and owners of pick-up points, will need to work according to the new rules.

Which marketplaces can be included in the Register

As of 2026, there are about 100 active marketplaces in Russia, which include both large multi-platforms (for example, Wildberries, Ozon, Yandex Market, Megamarket) and niche platforms specializing in certain types of goods (Lamoda, Golden Apple, Lemana PRO, etc.).

However, not all marketplaces will automatically be included in the Register and, accordingly, will receive the status of intermediary digital platforms, the activities of which are regulated by the Law on the Platform Economy.

Firstly, the Law on the Platform Economy immediately excludes some trading platforms from its scope. In particular, it does not apply to marketplaces that provide licenses for the use of software, as well as to online stores that sell only the goods or services of the owner of such a store.

Secondly, to be included in the Register, a trading intermediary platform must meet the basic functional criteria, namely, provide the technical ability to place orders (cards of goods, works, services), as well as the conclusion and performance of relevant transactions by partners (sellers) and users (buyers), including payment for goods, work, or services directly through the platform.

Third, it must meet additional criteria that may be established by the Government of the Russian Federation.

Specific criteria for inclusion in the Register

This year, the Government of the Russian Federation, by Decree No. 54 dated 28.01.2026, established additional quantitative criteria that depend on the jurisdiction of the digital platform.

For Russian intermediary digital platforms, a set of the following criteria has been established:

  • Subject composition: the owner of the platform or a person with whom the owner has entered into an agreement on its operation can be a legal entity or an individual entrepreneur registered in accordance with the legislation of the Russian Federation;
  • The average daily audience of the platform for the previous calendar year must be at least 100 thousand users located in the territory of the Russian Federation;
  • Alternative criteria (the platform must also meet at least one of them):
  1. at least 10 thousand sellers who entered into at least one transaction for the sale of goods (works, services) on the platform in the previous calendar year and received payment for the transaction through the platform;
  2. at least 50 billion rubles - the total value of all transactions concluded and paid through the platform in the previous calendar year.

For foreign intermediary digital platforms, a set of the following criteria has been established:

  • Subject composition: the owner of the platform or a person with whom the owner has entered into an agreement on its operation can be a foreign legal entity, a foreign organization that is not a legal entity, a foreign citizen, or a stateless person. At the same time, a foreign organization will not be included in the register if it does not have an advisory branch, representative office, etc. in Russia;
  • The average daily audience of the platform for the previous calendar year must be at least 100 thousand users located in the territory of the Russian Federation;

Additional criteria come into force from 1.10.2026. and valid until October 1, 2032.

Ways to include marketplaces in the Register

According to the Rules for the Formation and Maintenance of the Register, there are two ways to get into the Register:

  1. Thus, government agencies provide data on the work of the marketplace at the request of the Ministry of Economic Development of the Russian Federation, which decides on the inclusion of the platform in the Register based on quantitative criteria. It is assumed that the first in the Register will be the "big four" (Wildberries, Ozon, Yandex Market, Megamarket) - marketplaces, which account for a significant part of the e-commerce market;
  2. Voluntarily, at the initiative of the owner of the platform himself or a person with whom the owner has entered into an agreement on its operation. To do this, you will need to submit an electronic application to the Ministry of Economic Development of the Russian Federation and document that the platform meets the main and additional criteria.

It is planned that the Register will be formed and posted on the website of the Ministry of Economic Development of the Russian Federation by November 2, 2026.

Author
Managing Partner / Patent Attorney of the Russian Federation / Eurasian Patent Attorney