Important Requirement for Consent to Personal Data Processing from September 1, 2025 - Sterngoff Audit %
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Important Requirement for Consent to Personal Data Processing from September 1, 2025

25.08.2025
Ms. Olga Grigorieva
General Director

Starting from September 1, 2025, consent for the processing of personal data must be issued as a separate document, distinct from any other information and/or documents that the data subject confirms or signs.

This requirement is established by Article 9 of the Federal Law on Personal Data (Law of 24.06.2025 No. 156-FZ).

If consent is not issued as a separate document, it may be regarded as processing personal data in violation of the legal requirements regarding the content of information included in the consent.

Liability (Part 2, Article 13.11 of the Code of Administrative Offenses of the Russian Federation):

  • for officials — from 100,000 to 300,000 RUB;
  • for legal entities — from 300,000 to 700,000 RUB.