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Comments on draft acts: what was filed and what was accepted

Nikolay Lobanov

I file comments on draft acts on critical information infrastructure and information security on regulation.gov.ru while the text can still be changed. In 2026 I filed comments on 59 draft acts and standards. The table lists 31 of them with a known outcome; the rest will appear here once the developer responds. The status is taken from the public consultation summary or the developer's written response, not from my own assessment. Topics are given in English, the draft acts themselves are in Russian.

IDDraft actDeveloperStatus
171239procedure for assessing CII categorisation data of research organisationsMinistry of Science and Higher Education5 of 10 marked accepted
171465third anti-fraud package: amendments to the Communications Law and other legislative actsDigital Ministrymarked partly accepted
171019procedure for maintaining classifiers and reference books of the social sector platformMinistry of Labourmarked partly accepted
171058extension of the experiment on identification via the federal identity system (ESIA) on social networks and aggregatorsDigital Ministrynot accepted
171017agreements of IT companies on support for educational programmesDigital Ministry3 of 5 included in the revised draft
170824classifier of software for the register of Russian software: industrial software classesDigital Ministry3 of 6 included in the revised draft
170804continuation of the experiment on assessing the quality of social services through the state services portalMinistry of Labour2 of 6 marked accepted
170976notification procedure for remote sale of medicinesMinistry of Health5 of 6 marked accepted
170737forms for providing information from the state address registerMinistry of Finance2 of 5 included in the revised draft
170933residents' transactions with digital rights and digital currencies, Instruction No. 181-IBank of Russiaresponse received: proposals used in revising the draft
170797requirements for cloud services of the state unified cloud platformDigital Ministry1 of 12 marked accepted, editorial comments partly
170667requirements for security certificates of the national certification authorityDigital Ministry1 of 4 marked accepted, 2 partly accepted
170645model requirements for the plan to deploy technical equipment in freight forwarders' information systemsMinistry of Transport9 of 10 not accepted, editorial comments partly accepted
170530state system of information on athletes' healthFMBA2 of 4 marked accepted, 2 partly accepted
170545functions and powers of operators of the Electronic Budget systemMinistry of Financemarked partly accepted
170443minimum amount of own fundsBank of Russiaresponse received: taken into account within its competence
170442activities of a digital depositoryBank of Russiaresponse received: taken into account within its competence
170418amendments to a Bank of Russia directiveBank of Russiarejected on the deadline, the rest noted
170387amendments to Government Decree No. 372 of 26.03.2025Government5 of 8 marked accepted
170371state information system "Centralised System for Collecting Information of System-112"EMERCOM of Russia9 of 16 marked accepted, 6 partly accepted
170295amendments to Decree No. 861, unified system for the provision of state servicesDigital Ministry6 of 7 accepted
170134cases of termination of a certificateDigital Ministrynot accepted
169883cryptographic protection in state information systemsFSBnot accepted
169315reimbursement of transfers made without the client's consentDigital Ministrypartly accepted
169312criteria for phone numbers showing signs of unlawful activityDigital Ministrypartly accepted
168142information protection in hosting of state information systemsDigital Ministrynot accepted
167110licensing of development and production of means of protecting confidential informationFSTECnot accepted
167663security indicators of information infrastructure objectsFSTEC2 of 4 accepted
166998amendments to FSTEC Orders No. 235 and No. 239FSTECnot accepted
166970licensing of technical protection of confidential informationFSTECmarked partly accepted
166424law on the foundations of state regulation of artificial intelligenceDigital Ministry1 of 8 marked accepted, 4 partly accepted
165538commissioning of communication networks: notification only through the state services portalDigital Ministry3 of 8 technical corrections adopted
154392regulation on protection zones of communication lines and facilitiesDigital Ministrynot accepted on substance; 1 editorial correction marked accepted

Primary sources: the draft law No. 1110676-8 record on sozd.duma.gov.ru and the public consultation summaries on regulation.gov.ru.

Telegram channel "Na stadii obsuzhdeniya": breakdowns of draft CII and information security regulations while they can still be changed, and what was accepted. Mirrored on MAX: "Na stadii obsuzhdeniya", in Russian.

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