Starting May 30, 2025, a new clause 10 of Article 13.11 of the Administrative Offences Code (KoAP RF) comes into force. Under this clause, failure to notify Roskomnadzor about the commencement of personal data processing (Federal Law No. 420-FZ of 30.11.2024) will result in fines of 30,000 to 50,000 rubles for responsible persons and 100,000 to 300,000 rubles for individual entrepreneurs and organizations.
Before May 30, the same violation was penalized with fines of only 3,000 to 5,000 rubles under Article 19.7 KoAP RF.
However, there is a partial mitigation: under clause 1 of Article 4.1.1 KoAP RF, for a first-time administrative offence — including in the field of personal data — the fine must be replaced with a warning. Therefore, if a company submits the notification after beginning processing, no fine will be imposed — only a warning will be issued.
If, after receiving a warning, the company still fails to notify Roskomnadzor, it will be fined under clause 10 of Article 13.11 KoAP RF — from 100,000 to 300,000 rubles.
The notification is required for all companies not yet listed in the Register of Operators. You can check your presence in the register at: pd.rkn.gov.ru
Notification is not required if the employer does not use any automation tools when handling employee data. However, if any technical tools are used at any stage of processing, work without notification is not allowed.
Notification forms are approved by Roskomnadzor Order dated 28.10.2022 No. 180 “On the approval of notification forms on the intention to process personal data, changes to such notifications, or termination of personal data processing”.
Notifications can be submitted in the following ways:
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