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Russia introduces new legal requirements as host of the 2018 FIFA World Cup

With the 2018 FIFA World Cup approaching, Russian authorities continue to introduce new rules and administrative procedures to ensure higher consumer protection and safety standards for businesses involved in preparing for and staging the World Cup. However, not all the new requirements place additional burdens on businesses - some provide relief from generally applicable rules and formalities.

April 2018

The data localisation requirement: will it affect the World Cup?

Since 1 September 2015, the Personal Data Law (Article 18(5) of Federal Law No. 152-FZ dated 27 July 2006 (as amended)), has obliged data controllers processing any personal data of Russian citizens (including recording, structuring, accumulating, storing, rectifying and extracting) be carried out only on databases located in the territory of the Russian Federation. This covers collection in any manner, including via the internet.

This data localisation requirement means it is illegal to process the personal data of Russian citizens using non-Russian ICT Systems without involving a database installed on a Russia-based server. This cannot be surmounted even with a data subject's written consent, and its violation may result in access to webpages being blocked, and to administrative fines.

As a result of the staging of the World Cup in Russia, FIFA and its authorised agencies involved in the preparation and organisation of World Cup events have been granted an exemption (Article 23.1 of the Federal Law No. 108-FZ dated 7 June 2013 (as amended)). The right to record, structure, accumulate, store, change, modify and extract personal data of citizens of the Russian Federation without the use of databases located in the territory of the Russian Federation is granted provided that the collection of such personal data is carried out for the purpose of:

  • voluntary activities of the Russian citizens concerned;
  • selling entrance tickets for World Cup events or documents giving the right to obtain such tickets; or
  • accreditation of persons taking part in the events.

The list of the FIFA-authorised organisations is set out by the Government of the Russian Federation and includes the organisational committee "Russia 2018", a number of state universities and some commercial companies. Of course, FIFA itself is also exempt from the data localisation requirement. Given that fifa.com is the only official source of entrance tickets, Russian data localisation requirements are not really an issue for the World Cup. In fact, they may help prevent the sale of counterfeit tickets and products. Nonetheless, data controllers who are not mentioned in the Government's list and who process personal data of Russian citizens in connection with the staging of the World Cup, should be aware they may be subject to inspection by the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor).

Measures against counterfeit tickets

On 11 November 2017, the board of the Federal Service for Surveillance on Consumer Rights Protection and Human Wellbeing (Rospotrebnadzor) adopted an agenda to prepare for the World Cup with a view to ensuring proper implementation of the applicable legal requirements. The priority tasks of Rospotrebnadzor for the coming months include:

  • banning any sales (including re-sale, distribution, allocation, exchange or other similar activities, whether profitable or not) of tickets to World Cup matches, or other documents giving the right to obtain such tickets, without entering into respective agreements with FIFA or its authorised agencies; and
  • supervision of the use of the 2018 FIFA World Cup trade marks to which FIFA has exclusive rights.

These tasks have significantly increased inspections of businesses engaged in servicing the World Cup. On 15 March 2018, Roskomnadzor included 858 websites containing information on the sale of counterfeit products and entrance tickets to the World Cup in the Unified Register of Prohibited Information. Since then, 822 websites have voluntarily removed the illegal content, while 28 are still expected to do so before the deadline set by Roskomnadzor has passed. Access to the remaining eight websites is blocked due to their non-compliance. Roskomndazor and Rospotrebnadzor will keep monitoring activities involving counterfeit products and entrance tickets, and will take action against any unauthorised reproduction of FIFA's trademarks in a commercial context.

Simplified radio use permit

Roskomnadzor has introduced a simplified authorisation procedure for the use of the radio frequency spectrum in order to promptly review the applications of the organisers and participants of the World Cup. The application for a permit can be submitted online through the applicant's personal account on the special web-portal of the organising committee. Time limits for examination of electromagnetic compatibility and registration of permits for the use of radio frequencies vary depending on the number of days left before the start of the event. For example, if the application was received a week before the first match or later, then one day is allocated for the examination and issuing of the permit. Permits are also issued in electronic form, and registration of radio-electronic equipment is carried out by means of special marks to be attached to the equipment.

As of 1 March 2018, based on the applications received from the organising committee "Russia-2018", Roskomnadzor has already issued 133 permits. It is reported that the majority of permits (67) were issued to operators providing mobile radio services and fixed satellite communication. 43 permits were issued to HBS broadcaster and 23 to the organising committee.

Fan ID

Fan ID is a specially designated card required for access to the stadiums in order to ensure the safety of the events. It is a personal spectator's document issued to foreign citizens, stateless persons and citizens of the Russian Federation who possess an entrance ticket to a match or a document entitling them to obtain an entrance ticket. Fan IDs can be issued both electronically and in paper format through a specialised distribution centre. However, the spectator must present the paper-based ID along with the ticket to enter the stadium and must wear it during the game. A Fan ID can be cancelled where necessary to ensure public security or public order, or where an individual is found to have a record of public order disturbance, either in Russia or abroad (Article 2(28) of the Federal Law №108-FZ dated 7 June 2013).

In addition, a paper Fan ID can be used for visa-free multiple entry to and exit from the Russian Federation, provided that its holder has a ticket to a sporting event and a valid personal identification document (passport or its permissible equivalent). This simplified regime is applicable for the period starting at 00:00 on 4 June 2018 up to 23:59 on 15 July 2018 (local time). Where the spectator has only electronic Fan ID, he or she is entitled to visa-free entry to Russia starting from 18:00 (local time of arrival) on 11 June 2018 until 23:59 on 15 July 2018. However, the ID holder is not entitled to depart from Russia if he or she does not get a paper-based Fan ID upon arrival. As an additional bonus, a Fan ID on paper allows its holder to use public transport in the cities hosting the World Cup on the days of the games and railway transport to get from one hosting city to another free of charge, subject to certain restrictions.

Not all rules have been relaxed

It is notable that simplification of certain legal requirements, such as those outlined above, mostly concern the guests of the World Cup, FIFA and its associated agencies, persons and entities involved in the organisation of the event and the mass media. In other areas servicing the World Cup (for example, hotels, restaurants and ticket sellers), higher requirements and stricter rules have been recently introduced in Russia. Hopefully, Russian regulators and supervising authorities will manage to find a proper balance of regulation in order to ensure the success of the first world football championship ever to be held in Russia.

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Russia introduces new legal requirements as host of the 2018 FIFA World Cup
Anton Nakou

Anton Nakou

Antonina Nurova

Antonina Nurova


Anton and Antonina of Castrén & Snellman International Ltd look at the regulatory environment for the 2018 FIFA World Cup.






"Hopefully, Russian regulators and supervising authorities will manage to find a proper balance of regulation in order to ensure the success of the first world football championship ever to be held in Russia."