Increased Control over Foreign Investments in Russia in Strategic Sectors

On March 8, 2026, Federal Law No. 51-FZ came into force, which significantly expands control over foreign investments in Russia in strategically important sectors.

Now, the regulation applies not only to transactions involving shares of strategic companies, but also to the acquisition of state or municipal property that constitutes fixed production assets used for strategic activities. Additionally, non-profit organizations engaged in strategic activities are now covered by the law if a foreign investor gains control over them or acquires their property worth 25% or more of their book value of assets.

The list of strategic activities has also been expanded to now include:

• Use of subsoil plots (non-federal) with certain volumes of oil, gas, gold, copper reserves, as well as plots containing uranium, rare earth metals, nickel, cobalt, tantalum, niobium, beryllium, diamonds, lithium, and platinum group metals;
• Use of subsoil plots containing groundwater when extracting from 3,000 cubic meters per day, if the water is extracted for sale after treatment or packaging;
• Production of fish products, if revenue from this activity accounts for 50% or more of total revenue, and the company’s assets together with those of its group of persons exceed RUB 800 million;
• Pasture aquaculture with respect to Pacific salmon.

If a foreign investor in a company that produces fish products holds at least 5% of the voting shares (interests) of a company engaged in these new strategic activities, they must submit information about this to the authorized body within 180 days (until September 2026). If the foreign investor holds more than 50%, they must, within 365 days (until March 2027), either obtain approval to establish control or reduce their stake to 50% or less and notify the authorized body accordingly. Failure to comply may result in the loss of voting rights at the general shareholders’ (participants’) meeting.

When obtaining licenses, accreditation certificates, or compliance documents (including in the fields of transportation security, fisheries, and subsoil use), companies are required to disclose information about beneficiaries, beneficial owners, and controlling persons. Foreign investors must also indicate whether they hold a residence permit or another document for permanent residence in a foreign state.

The new law significantly tightens control over foreign investments in strategic sectors. Entrepreneurs need to verify whether their business falls under the new criteria, especially in the areas of subsoil use, fisheries, and fish product manufacturing. It is crucial to submit notifications or petitions within the established deadlines to avoid sanctions, which may include the loss of voting rights or even expropriation. Furthermore, when obtaining licenses and permits, more comprehensive disclosure of ownership structures will be required.