On 27 November 2025, Decree of the Government of the Russian Federation No. 1894 “On the Approval of the Rules for Coordinating with the Federal Security Service of the Russian Federation the Participation of Foreign...” (hereinafter referred to as the “FSB Coordination Rules”) was published. It stipulates that civil-purpose scientific research, experimental design, and technological work (hereinafter referred to as “Work”) involving foreign citizens and foreign organizations, as well as Russian organizations whose participants (founders) include foreign citizens and/or foreign organizations, must be coordinated with the FSB in the fields of scientific and/or scientific-technical activities and experimental development. This coordination is carried out by submitting information to the Russian Ministry of Science and Higher Education through the Unified State Information System for Accounting of Research, Development, and Technological Work (EGISU NIOKTR).
The measure implements Federal Law No. 159-FZ “On Amendments to Articles 7-1 and 16 of the Federal Law “On Science and State Scientific and Technical Policy” (hereinafter referred to as the “Federal Law on Amendments”), signed in June 2025.
Entities
According to Clause 2.1, Article 7.1 of the Federal Law “On Science and State Scientific and Technical Policy” (hereinafter referred to as the “Science Law”) (in the version effective from 1 March 2026), information for coordination with the FSB is submitted by entities engaged in scientific and/or scientific-technical activities, as well as entities engaged in innovative activities.
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Entities of scientific and (or) scientific-technical activity |
Entities of Innovative Activity |
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According to the meaning of Clause 1, Article 3 of the Science Law, these include, among others, legal entities whose statutory documents provide for the conduct of scientific and/or scientific-technical activities |
According to the meaning of Article 2 of the Science Law, these include, among others, legal entities engaged in scientific, technological, organizational, financial, and commercial activities aimed at implementing innovation projects, as well as creating innovation infrastructure and ensuring its operation |
At the same time, according to Paragraph 4, Clause 5 of the Regulation on the Unified State Information System for Accounting of Research, Development, and Technological Work for Civil Purposes (in the version effective from 1 March 2026), information on the Work is to be submitted no later than 1 April of the current financial year by the contractors performing the Work under the relevant contracts.
List of areas of Work
According to Clause 3 of the FSB Coordination Rules, the Work subject to coordination are those falling under the list established by Paragraph 3, Clause 4, Article 16 of the Science Law (hereinafter referred to as the “List”). Currently, such a List does not exist. According to the transcripts of discussions regarding the Federal Law on Amendments, the List is planned to be formed based on areas of critical importance for ensuring the national security and economic development of the Russian Federation.
We believe that activities related to conducting pre-clinical and clinical trials of medicinal products, whose purposes differ from those of scientific research and which are subject to separate regulation, should not fall under the requirements of the FSB Coordination Rules.
Similarly, activities involving payments to doctors and clinics with a scientific base as sponsorship for scientific conferences and presentations at such conferences should not be subject to the restrictions, as such contracts lack critical importance for ensuring Russia’s national security.
Effective Date of the Changes
The new rules for coordinating the Works come into force according to the following schedule.
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From 1 April 2026 |
From 1 September 2028 |
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For scientific organizations and higher educational institutions conducting research funded by budgetary allocations within the framework of a state assignment |
For all other organizations performing scientific research (regardless of their legal form and type of ownership) |
We recommend closely monitoring the development of regulatory legal acts adopted to implement the FSB Coordination Rules and the Federal Law on Amendments. Primarily, it is necessary to await the publication of the List and subsequently assess the provisions of contracts with counterparties for their compliance with both the List itself and the definition of scientific activity under the Science Law. If contracts fall under the requirements of the List, the associated risks will involve potential delays in the process of conducting scientific activities with foreign counterparties.