Russian Licensing System
Legal Framework
The Russian licensing system (litsenzirovanie) is governed by the Federal Law on Licensing of Certain Types of Activities (No. 99-FZ of 4 May 2011), which replaced the earlier Law No. 128-FZ of 2001. The law establishes the general legal framework for licensing, defining the types of activities subject to licensing, the procedure for obtaining and maintaining licences, the grounds for suspension and revocation, and the powers of licensing authorities. The law was adopted as part of the administrative reform aimed at reducing the regulatory burden on business while maintaining state control over activities that present significant public risks.
Article 2 of Law No. 99-FZ defines a licence as a special permit (spetsialnoe razreshenie) to carry out a specific type of activity, granted by an authorised state body to a legal entity or individual entrepreneur. Licensing is required only for activities expressly listed in Article 12 of the law. The list includes approximately 50 types of activities, including: educational activities; medical and pharmaceutical activities; transport services (passenger and freight); communications services; private security and detective activities; alcoholic beverage production and sale; and the use of nuclear materials.
Licensed Activities
The closed list of licensed activities in Article 12 of Law No. 99-FZ is subject to periodic revision. The Government maintains the authority to add activities requiring licensing where necessary to protect public safety, national security, or public health. Each licensed activity is subject to specific licensing regulations (polozheniya o litsenzirovanii), approved by Government Decree, which set out the detailed licensing requirements, procedures, and conditions for each activity.
The licensing regulations typically establish: qualification requirements for the licence applicant’s personnel; requirements for premises, equipment, and technical facilities; requirements for the applicant’s financial position; and requirements for internal quality control systems. The licensing authority verifies compliance with these requirements through document review and, in many cases, on-site inspections before granting the licence. The licence is valid for an indefinite term unless the relevant licensing regulation provides for a fixed term.
Licensing Authority
Licensing functions are distributed among federal and regional executive bodies depending on the nature of the licensed activity. The Federal Service for Surveillance in Healthcare (Roszdravnadzor) licenses medical and pharmaceutical activities. The Federal Service for Supervision of Education and Science (Rosobrnadzor) licenses educational activities. The Federal Service for Supervision of Transport (Rostransnadzor) licenses transport activities. The Federal Service for Alcohol Market Regulation (Rosalkogolregulirovanie) licenses alcohol production and sale.
At the regional level, licensing functions for certain activities — including retail sale of alcoholic beverages, passenger transport by bus, and medical activities — are exercised by regional executive bodies. The distribution of licensing authority between federal and regional levels has been adjusted through successive amendments to reflect the centralisation trends in Russian governance, with certain licensing functions shifted from regional to federal level.
Goskatalog
The Unified Register of Licences (Goskatalog) is the centralised information system for licensing in Russia. Maintained by the Ministry of Economic Development, the register contains information on all licences issued, suspended, renewed, and revoked across all types of licensed activities. The register is publicly accessible online and provides information on: the licence holder’s details; the type of licensed activity; the territory of validity; the date of issue and expiry; and any suspensions or restrictions.
The Goskatalog system was developed as part of the Electronic Government programme and is integrated with the Unified Portal of State and Municipal Services (Gosuslugi). Licence applications may be submitted electronically through the portal, and the status of applications can be tracked online. The digitalisation of the licensing process has reduced processing times and increased transparency, though disparities in digital infrastructure across Russian regions have limited the system’s effectiveness in some areas.
Permit Systems
Beyond formal licensing under Law No. 99-FZ, Russian administrative law establishes numerous permit systems (razreshitelnye sistemy) governed by sectoral legislation. These include: construction permits under the Town Planning Code; environmental permits under the Law on Environmental Protection; arms permits under the Law on Weapons; and permits for the use of natural resources under subsoil, forestry, and water legislation.
The distinction between a licence under Law No. 99-FZ and a permit under sectoral legislation is not always clear in Russian administrative practice. Both systems involve state authorisation of specific activities, but licences are generally understood as authorising the carrying out of an entire type of activity, while permits authorise specific actions or uses. The Constitutional Court has held that both licences and permits constitute restrictions on the constitutional right to freedom of economic activity and must therefore be established by federal law.
Digital Licensing
The digital transformation of Russian licensing accelerated with the adoption of the Digital State Administration federal project under the national programme Digital Economy. Electronic licensing procedures were implemented through amendments to Law No. 99-FZ in 2021, providing for: submission of electronic applications through Gosuslugi; electronic document exchange between applicants and licensing authorities; automated verification of applicant data through interagency information systems; and issuance of licences in electronic form with an enhanced qualified electronic signature.
Electronic licensing has significantly reduced processing times. Standard licence applications are now processed within 15 business days (reduced from 45 days for paper applications), and simplified procedures apply for licence renewals and amendments. The digitalisation programme has also enabled the introduction of a prophylactic model of licensing control, in which the licensing authority provides pre-application consultations and identifies potential compliance issues before the formal application is submitted.
Licence Revocation
Licences may be suspended or revoked on grounds specified in Article 20 of Law No. 99-FZ. The licensing authority may suspend a licence where the licence holder has failed to comply with licensing requirements and conditions, has failed to eliminate identified violations within the prescribed period, or has failed to pay the state duty for licence renewal. The suspension period may not exceed six months.
Revocation (annulirovanie litsenzii) is the most severe administrative sanction. Grounds for revocation include: the detection of inaccurate or distorted information in the licence application; the repeated or gross violation of licensing requirements; the failure to eliminate violations leading to suspension; and the refusal to carry out an inspection. Revocation is carried out by the licensing authority in administrative proceedings, subject to judicial review. The licence holder has the right to appeal the revocation to a court under the Administrative Procedure Code (CAS RF).
Self-Regulatory Organisations
In certain sectors, the licensing system has been partially replaced by the self-regulatory organisation (samoreguliruemaya organizatsiya, SRO) model. The Federal Law on Self-Regulatory Organisations (No. 315-FZ of 1 December 2007) establishes the legal framework for SROs in construction, design, engineering, auditing, valuation, and insolvency administration. SROs are non-profit organisations that establish standards and rules for their members, conduct quality control, and impose disciplinary sanctions.
The SRO model was introduced as a deregulation measure, transferring certain supervisory functions from state bodies to professional associations. Membership in an SRO is mandatory for carrying out certain activities — particularly in construction — replacing the individual licensing requirement. SROs maintain compensation funds (kompensatsionnye fondy) to cover losses caused by their members. The SRO system operates under state supervision exercised by the relevant federal body, which registers SROs and monitors their compliance with legislative requirements.