In 2025, regulations on the use of messaging platforms became stricter. Let’s break down which organizations are prohibited from using messengers for communication, which platforms are banned, and how to work with Telegram without risking fines.
More details in the article.
Who is prohibited from using messengers?
According to current legislation, the following categories are prohibited from using messengers:
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Government bodies
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Credit institutions
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Marketplaces
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Social network owners
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Classified ad services
All other businesses and individuals may continue using messengers without restrictions.
Important: the ban applies only to foreign messengers (WhatsApp, Telegram, etc.). Russian messengers (VK Messenger, Yandex.Chat, Rosa, Kolibri) remain available to everyone.
Telegram and cross-border data transfer
Russia’s Ministry of Digital Development clarified: correspondence between Russian users on Telegram is not considered a cross-border data transfer.
Why is this important?
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Telegram is a foreign company, but it operates in Russia and is required to comply with Russian laws.
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In case of violations, the regulator can impose sanctions: advertising bans, functionality restrictions.
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At the moment, Telegram complies with all requirements, so advertising restrictions (like those on Google) do not apply to it.
What to keep in mind when working with Roskomnadzor and personal data in Telegram and Instagram*
Telegram. More in the article.
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Always obtain consent for personal data processing and publish a privacy policy.
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Consent for marketing communications must be separate and voluntary.
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A public offer is required only if the bot sells goods or services.
Telegram mini-landing pages. More in the article.
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Do not include marketing consent in mandatory checkboxes on mini-landing pages.
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Collect advertising consent as a separate agreement within the bot.
Instagram*. More in the article.
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If sales and registration occur outside of Instagram*, documents in direct messages are not needed.
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If sales occur via Instagram*, we recommend avoiding such transactions and redirecting users to a separate landing page.
Instagram* is designated as extremist, and sales through it carry risks.
Main rule: first determine who is the personal data operator (the one who determines the purposes and means of processing). This operator is responsible for preparing and publishing all necessary documents: consent for processing, privacy policy, public offer. The format may vary — the key is that the user can review them before providing their data.
Initial collection and storage of Russians’ data must take place on servers located in Russia.
If your bot operates on foreign servers:
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Reroute traffic so data first reaches Russian servers.
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Use Russian cloud solutions (Yandex Cloud, SberCloud, VK Cloud).
Article 18, Clause 5 of the Federal Law “On Personal Data”
“When collecting personal data, including via the internet, recording, storage, and processing of Russian citizens’ data must be carried out only on the territory of Russia. Use of foreign servers is prohibited.”
The BotHelp platform is a software product that allows you to create a chatbot and connect it to social networks. BotHelp is not a data center (DC) and does not act as a personal data operator when transmitting data to third-party services.
In the notification to Roskomnadzor, you may list YandexCloud (a Russian cloud solution) as your DC:
More in the article.
How to handle mailings if the user did not consent to marketing
If a user received a lead magnet but did not give consent for receiving marketing mailings, you may not send them advertising — this violates personal data laws and mailing regulations.
We recommend using labels (tags) to distinguish such users. Apply a tag only to those who gave consent for marketing messages, and filter the audience by this tag when sending. This helps avoid violations and maintain legal compliance in your communications.
Roskomnadzor: registration and data submission
For questions on how to fill out an application to Roskomnadzor, it is recommended to contact their support directly to receive up-to-date information and clarifications. Only the agency provides official requirements for formatting and content.
From our side, we provide only the information required of us. All other fields are filled out by the applicant independently, in accordance with Roskomnadzor’s instructions.
We also include a video that covers general points and provides an overview of the process: video
*Owned by Meta, recognized as extremist in Russia.
If you did not find the answer to your question, feel free to contact us in the chat inside your dashboard, message us on Telegram at @BotHelpSupportBot, or email us at hello@bothelp.io.
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