Concise and to the point with ALRUD: HR & DIGITAL (№ 20)

Concise and to the point with ALRUD: HR & DIGITAL (№ 20)

27 March 2025

New rules for foreigners purchasing SIM cards


From ****01 January 2025****, the procedure for foreigner citizens purchasing SIM cards has changed. The relevant amendments were introduced under ****Federal Law No. 303-FZ dated 08 August 2024**** to Federal Law No. 126 “On Communications” dated 07 July 2003.

According to the new rules:

  • a foreigner or stateless person can conclude a contract for mobile communication services only ****in person at a cellular shop****;

  • to conclude such a contract, the insurance number of an individual personal account (****SNILS****), a ****Gosuslugi**** account, and proof of identity using biometrics registered in the ****Unified Biometric System**** are required;

  • the contract specifies a unique device number of 15 characters – an ****IMEI****;

  • each person can use up to ****10 SIM cards****, including ****corporate**** ones.

These changes do not apply to Russian citizens.

Those foreigners who already have a SIM card must visit a ****cellular shop**** before ****01 July 2025**** and confirm their ****identity****.

If a foreigner has already been issued more than ****10 SIM cards****, they will have to ****terminate**** the excess contracts. Otherwise, starting from ****01 July 2025****, ****telecom operators**** will be required to ****suspend**** the service of all SIM cards that have not been confirmed on time.

Note that restrictions have also been introduced for Russian citizens. For example, each person can apply for no more than ****20 SIM cards****, including ****corporate**** ones.

The first known case of the application of Article 272.1 of the Russian Criminal Code


The police detained a 20-year-old employee of a cellular shop who is suspected of ****transferring the personal data**** of Honored Artist of Russia Yaroslav Dronov (popularly known as Shaman) to a third party, taking advantage of their ****official (job) position****. The suspect also transferred the personal data of another customer the same way. Criminal cases have been initiated for both acts under ****Clause “г” of Part 3 of Article 272.1 of the Russian Criminal Code****.

Recall that, as of ****11 December 2024****, the new ****Article 272.1 of the Russian Criminal Code**** has been introduced, stipulating liability for violations involving ****digital information containing personal data**** (Information).

In particular, (1) the illegal ****use**** and (or) ****transfer**** (dissemination, provision, or access), (2) ****collection**** and (or) storage of Information obtained through ****unauthorized access**** to the means by which it is processed or stored or any other interference in the functioning thereof, or in any other ****illegal interference**** may entail:

  • a fine of up to ****RUB 300,000**** (approx. USD 3,563, EUR 3,248) or the sum of income for up to ****1 year****;

  • either compulsory labor or imprisonment for up to ****4 years****.

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Note: please be aware that all information provided in this letter is based on an analysis of publicly available information as well as our understanding and interpretation of legislation and law enforcement practices. Neither ALRUD Law Firm nor the authors of this letter bear any liability for the consequences of any decisions made in reliance upon this information.

If you have any questions, please, do not hesitate to contact us.

Sincerely,
ALRUD Law Firm

Lesnaya st., 7, 12th fl., Moscow, Russia, 125196
Т: +7 495 234 96 92, Т: +7 495 926 16 48, info@alrud.com
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