Changes in Client Communications Under Federal Law No. 41

Contents:

• WhatsApp, Telegram, and Viber are banned — but not for everyone
• Mass automated calls cannot be made unless subscribers have consented to them
• All calls and messages to users must be labeled
• Phone numbers cannot be shared between employees
• Key points about changes in the rules for communicating with clients

On June 1, Federal Law No. 41-FZ, known as the anti-fraud law, came into force. This law significantly changes the rules for interacting with users, aimed at combating fraud. These changes require companies to take a more responsible approach to protecting customer data and increase transparency requirements for communication. The law also aims to reduce the risk of fraudulent activity, which in turn helps increase user trust in services and products.

The law includes many provisions. In this article by the Skillbox Media Marketing team, we examine the key changes in detail. We will tell you about the most significant aspects that can affect your business.

• why WhatsApp, Telegram and Viber are now banned for business;
• why making mass calls has become more difficult;
• how and why to label calls and messages;
• why the old rules of the game with corporate numbers no longer work.

WhatsApp, Telegram and Viber are banned - but not for everyone

Starting June 1, 2025, certain companies will be prohibited from using foreign instant messengers to communicate with clients. This list includes nine popular applications: Telegram, WhatsApp, Viber, Discord, Snapchat, Microsoft Teams, Threema, WeChat and even Skype, which has ceased operations. This innovation is aimed at protecting data and ensuring the security of communications in business. Companies will have to adapt to the new conditions and seek alternative solutions for effective communication with clients.

The ban does not apply to all organizations. It applies only to large companies and companies operating in certain industries. In the legislation, large companies are defined as enterprises that meet established criteria.

• Websites, pages, and services with a daily audience of over 500,000 users;
• Online services with a client base of 100,000 people.

Foreign messengers cannot be used by government agencies, financial institutions, including credit and non-credit organizations, as well as companies with a Russian Federation shareholding of more than 50%. This rule also applies to telecom operators, social media, national payment system participants, classifieds services, marketplaces, and product and service information aggregators, regardless of their traffic and customer base size. The transition to Russian messaging apps is becoming a pressing issue even for those not considered at risk. Government oversight of customer communications is tightening, and while this hasn't yet affected everyone, the timing remains uncertain. If your business is related to B2C, fintech, or the processing of sensitive data, you'll definitely be affected. It's important to understand that the technical transition to Russian messaging apps won't happen overnight, so it's wise to begin preparing in advance. This will help avoid potential problems and ensure the security of your communications in the future. Anton Kartsev is the founder of AlarmCRM, a specialized business process automation solution. AlarmCRM offers customer relationship management tools, enabling companies to effectively organize their work, increasing productivity and improving service. Under the leadership of Anton Kartsev, the AlarmCRM team is actively developing the platform, introducing new features and improving the user interface. This makes AlarmCRM a reliable partner for companies seeking to optimize their business processes and increase profits.

Personal communications are strictly prohibited. Karina Margaryan, IT and IP lawyer at RTM Group, clarifies: "The ban covers all cases where the company provides personal information or consultations to clients through foreign messengers. This includes correspondence between managers and users, sending notifications, order status updates in chatbots, and technical support. For example, VTB and PSB have already announced they will no longer inform their clients through chatbots on Telegram."

Posting on a company's Telegram channel is not considered a violation, asserts Karina Margaryan. Posts in channels and communities constitute publicly available information and are not personal communications. This allows companies to effectively engage with their audiences without the risk of breaking the rules.

For violating the ban, businesses may be held liable under Article 13.11.2 of the Code of Administrative Offenses of the Russian Federation, notes Karina Margaryan. Fines vary depending on the nature of the violation and can significantly impact a company's financial situation. It's important to comply with the established rules to avoid negative consequences and maintain a business's reputation.

• 30,000–50,000 rubles for officials;
• 100,000–700,000 rubles for legal entities.

If a business continues to ignore the ban on using foreign messengers for communication, there is a risk of having its accounts blocked by Roskomnadzor. This could lead to serious consequences for the company, including loss of its customer base and damage to its reputation. It is important to take legal requirements into account and use approved platforms to ensure secure and effective communication.

In April 2025, a precedent was set in Russia when a court held a bank liable for using WhatsApp to transmit a client's personal data. As a result, the bank was fined 200,000 rubles. This case highlights the importance of complying with personal data protection laws and the need to use secure channels for its transmission. Companies must adhere to regulations and standards to avoid fines and reputational damage.

Bulk automated calls cannot be made without subscriber consent.

Starting June 1, 2025, a ban on bulk and automated phone calls to subscribers who have not given consent will come into effect. This means that even automated calls notifying about a courier's arrival time may be in violation of the law. Companies must review their notification and communication strategies to comply with the new requirements and avoid fines. It is important to ensure that customers consent to such calls to minimize risks and maintain consumer trust.

The market expects regulations to emerge that will clarify the concept of mass calls and the procedure for obtaining subscriber consent, notes Karina Margaryan, IT and IP lawyer at RTM Group. It is important to understand that subscriber consent must be clear, informed, and obtained in advance. This will help avoid legal risks and increase customer trust in companies using such communication methods. Regulatory changes will help establish transparent rules for interaction with subscribers and create a more comfortable environment for doing business in the field of bulk calls.

• unambiguously identify the subscriber - that is, allow their identity to be established;
• reliably establish the subscriber's will - that is, clearly confirm their desire to receive calls.

At the moment, it is unclear how exactly this process will be implemented. However, if compared with the consents required to process personal data and to send advertising, it can be assumed that consent for bulk calls should also be formalized separately. This means that it should not be included in other documents. This approach will ensure transparency and compliance with legal requirements.

Subscriber consent can be obtained in various ways. It is important to keep in mind that consent must be clear and unambiguous. For example, subscribers can express consent by subscribing to newsletters, filling out forms on the website, or participating in surveys. It is also possible to obtain consent during telephone conversations or when interacting with clients offline. The key point is to provide information about the purposes for which personal data will be used and the ability to refuse further use at any time. This will help not only comply with the law, but also build trust with subscribers.

• via a special form on the website - the user ticks the appropriate box;
• via SMS - the user provides a one-time code confirming consent;
• offline - the client signs a separate consent form on paper.

In the consent form, it is important to clearly indicate the mass nature of the calls and not confuse them with advertising mailings. Otherwise, it may be difficult to prove that consent was obtained specifically for mass calls, which can lead to legal consequences. This is a critical point for compliance with personal data protection laws and the prevention of potential complaints from users.

Law 41-FZ is an important tool in the fight against growing digital fraud. With the number of online fraudulent schemes on the rise, the relevance of this legislation is heightened. It offers significant benefits to individuals, ensuring the protection of their rights and interests. The law aims to create effective measures to counter threats related to cybercrime and promote greater security in the digital space.

The legislation has generated mixed reactions in the business community, particularly in the context of the ban on the use of foreign instant messaging apps and mass calls. These tools play a key role in sales and marketing. These changes will have a particularly significant impact on B2C companies that actively engage in outbound calls and lead generation. Restrictions on the use of popular platforms may hinder customer engagement and reduce the effectiveness of marketing strategies. This will create additional challenges for businesses, requiring adaptation and the search for alternative solutions to maintain competitiveness.

The share of lawyers auditing companies for compliance with current requirements, including the new law, will increase. This will occur in conjunction with the already well-known and widely applied Federal Law 152-FZ, which regulates personal data protection. It is important to note that compliance with the law is becoming a necessity for businesses, creating a demand for qualified legal audit specialists.

Artur Garayev is the CEO of the IT company Garpun Software and a successful IT entrepreneur. Under his leadership, Garpun Software has achieved significant success in software development and the implementation of innovative business solutions. Garayev is actively involved in the development of the IT industry, focusing on modern trends and technologies, which allows the company to remain competitive in the market. His experience and vision help Garpun Software offer quality services and meet customer needs.

Violation of this prohibition entails administrative liability in accordance with Article 14.3 of the Code of Administrative Offenses of the Russian Federation.

• 10,000–20,000 rubles — for individuals, such as individual entrepreneurs;
• 20,000–100,000 rubles — for officials, such as managers;
• from 300,000 to 1 million rubles — for legal entities.

Fines may be initiated by the Federal Antimonopoly Service (FAS). A user who receives an automated call has the right to file a complaint with the FAS. In this case, the business will need to confirm that it has received the client's consent to make such calls.

Starting September 1, 2025, subscribers will be able to officially opt out of receiving advertising calls and SMS messages by submitting a request to their telecom operator. This innovation will allow users to protect themselves from unwanted advertising, and businesses will no longer be able to contact such customers to promote their goods and services.

All calls and messages to users must be labeled

Starting September 1, 2025, telecom operators are required to provide subscribers with information about the caller. In turn, businesses must transfer the necessary information to the operator for the correct labeling of calls. These changes are aimed at increasing the transparency of communications and protecting users from unwanted calls.

Voluntary call labeling is currently available, but it is provided on a paid basis. In the future, telecom operators will be required to label calls free of charge.

Implementation rules, methods of transmitting information to operators, the labeling format, and other conditions will be determined later, reports Karina Margaryan, IT and IP lawyer at RTM Group. A draft resolution currently exists that provides a general outline of how this system will be organized.

According to the draft resolution, businesses will be required to enter into an agreement with a telecom operator to display information to the caller. This agreement must specify the call category, the numbers belonging to the business, as well as important company information, such as OKVED codes, information from the Unified State Register of Real Estate (EGRN) or Unified State Register of Individual Entrepreneurs (EGRNIP), the full and abbreviated name, and a trademark registration certificate, if any. Ensuring transparent information during calls will help increase customer trust and improve communication between businesses and consumers.

The operator will provide the user with the company name, call category, and additional information, while limiting the text to 32 characters, reports Karina Margaryan. This allows for the effective transmission of key information without overload.

Currently, the law does not establish penalties for violating call labeling requirements. Karina Margaryan believes that potential fines could be comparable to penalties for spam calls. According to Part 4.1 of Article 14.3 of the Code of Administrative Offenses of the Russian Federation, violations in this area may entail certain penalties. This highlights the relevance of the topic of call labeling and the need for its regulation in legislation.

• 10,000–20,000 rubles for individuals;
• 20,000–100,000 rubles for officials;
• from 300,000 to 1,000,000 rubles for legal entities.

The Federal Antimonopoly Service (FAS) may initiate a fine if a user files a complaint about a call that does not meet labeling requirements. It is important for organizations to comply with the rules established by law to avoid negative consequences and penalties. Timely notification of users about calls and appropriate labeling will help avoid misunderstandings and protect their interests.

The obligation to label calls may lead to an increase in prices for communication and financial services. This law will create an additional financial burden on the financial and banking sectors, which in turn may affect the cost of services provided to end consumers. It's important to consider that such changes could impact the competitiveness of businesses and necessitate a review of pricing policies.

The advantages of Federal Law No. 41 include its ability to stimulate the development of more secure software and enhance user protection. However, it's important to assess how this law will function in practice. Disadvantages include ineffective communication, as well as the fact that new funnels and schemes require time for adaptation by both businesses and users.

It's necessary to adapt to new conditions. The ongoing changes mark a transition to a different reality, in which the usual order of things no longer exists.

I recommend outsourcing the services of IT lawyers, intellectual property specialists, as well as IT experts and project managers. These professionals will help you quickly adapt and optimize processes in your company, which is especially important in the rapidly changing digital market.

Elena Melnik is the CEO and founder of the marketing and branding agency EM Studio. With many years of experience in marketing, she successfully develops projects, helping companies build strong brands and increase their market presence. EM Studio offers a wide range of services, including strategic planning, unique content creation, and brand management. Under Elena's leadership, the agency team achieves high results by applying innovative approaches and modern technologies in marketing.

Phone numbers cannot be shared between employees

From September 1, 2025, a ban on the transfer of subscriber numbers comes into force. Exceptions are cases where individuals can transfer their numbers to close relatives and family members. These include spouses, parents, children, and siblings. This law is aimed at protecting consumer rights and simplifying the process of transferring numbers among family members.

For businesses, this means that employees will not be able to transfer colleagues' contact numbers without consent, explains Karina Margaryan, IT and IP lawyer at RTM Group. If a phone number is assigned to a manager, it is important that they interact with clients, which ensures a higher level of security and confidentiality. This approach helps prevent information leaks and maintains client trust.

It is not possible to register a corporate number and allow all employees to use it. Starting January 1, 2025, all corporate numbers must be registered through the Gosuslugi portal. It is also necessary to indicate which employee is responsible for each corporate number. This innovation is aimed at improving control and accounting of corporate communications.

Currently, there are no specific penalties for violating this prohibition. However, as Karina Margaryan points out, liability will be placed on the owners of subscriber numbers.

On March 1, 2026, a new requirement established by Federal Law No. 41-FZ will come into effect in Russia. As part of this change, an anti-fraud platform developed by the Ministry of Digital Development will be launched. This state-run system will collect and systematize data on numbers used in fraudulent schemes. Questions about how the platform will function and how businesses will be able to interact with it remain unclear. It is important to monitor further updates to be prepared for changes in the field of fraud protection.

On March 1, 2026, a new change stipulated by Federal Law No. 41-FZ will come into effect in Russia. On this date, an anti-fraud platform developed by the Ministry of Digital Development will begin operating. This state-run system will collect and process information on telephone numbers used in fraudulent schemes. However, at this point, it is unclear how the platform will operate and what mechanisms for interacting with it will be provided to businesses.

Key Changes to Client Communication Rules

• Foreign messengers—in particular, Telegram and WhatsApp—cannot be used for personal communication. Currently, the ban applies to companies with a client base of 100,000 or more people, projects with a daily audience of 500,000 or more people, and companies from certain sectors, such as banks.
• Bulk calls cannot be made without the consent of subscribers. Consent for bulk calls must be obtained in a way that allows for unambiguous user identification and the establishment of their consent to bulk calls.
• Calls and messages to users must be labeled, and to do this, an agreement must be concluded with the operator and the business data must be transferred to them. The operator will send text up to 32 characters long to users' smartphones: the company name, its category, and additional information.
• You cannot share a single number with multiple employees: even a corporate number must be managed by a single person.

Learn more about laws regulating marketing in other materials from Skillbox Media. Our articles offer detailed information and up-to-date data to help you better understand the legal aspects of marketing and their impact on business. Provide your company with reliable legal information by studying our content.

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• Advertising labeling: what marketers, businesses, and contractors need to know