From September 1, 2025, changes to russian legislation came into force, further restricting freedom of speech, access to information, and civil society activities. This includes, in particular, increased liability for access to “prohibited content,” a complete ban on educational activities for the so-called “foreign agents,” restrictions on advertising on independent platforms, and the imposition of russian digital services on mobile device users. 

Despite the fact that these norms were formally adopted for application on the territory of the russian federation, the kremlin traditionally extends their effect to the temporarily occupied territory of Crimea. This creates additional risks for the inhabitants of the peninsula – both for activists, journalists, educators, and ordinary Internet users. 

In this article we together with representatives of CrimeaSOS – lawyer Viktor Vuika and international advocacy expert Artem Oliinyk tell what exactly is changing in the legal field of the russian federation, why this poses a threat to the residents of occupied Crimea, and how innovations can be used for repression.  .  

VPN, banned materials and censorship: how Crimean residents can be punished for viewing the “wrong” content

On September 1, a regulation came into force in the russian federation, which introduces administrative liability for intentional search and access to “extremist” materials from the federal list. At the same time, control over the use of VPN services is being tightened – a ban on their advertising is being introduced, and the use of a VPN during the commission of a crime is recognized as an aggravating circumstance. 

VPN is not forbidden, but… 

As lawyer Viktor Vuika explains, the innovation does not prohibit the mere fact of using a VPN service. It is prohibited to advertise such services – that is, to share referral links, name specific services on blogs, social networks, or recommend them. However, a simple discussion of VPNs, without mentioning specific names, is not a violation. 

 “A VPN is not illegal as such. But if the investigation proves that a person used it to conceal illegal activity, this will be taken into account as an aggravating circumstance,” – Viktor comments. 

Advertising of VPN services will be monitored by the Federal Antimonopoly Service (FAS). It will issue resolutions on violations – they can be appealed in court. If an individual entrepreneur or legal entity is held liable – in arbitration, if it concerns an individual – in a court of general jurisdiction. The statute of limitations for such cases is two years from the date of distribution of the advertisement. 

What a person may face for “extremist” materials? 

A separate innovation is fines for intentionally viewing or searching for “extremist” materials on the Internet. The fine ranges from RUB 3,000 to 5,000 (UAH 900-1,500). But investigators must prove the intent in order to punish a person. 

“It must be established that the person was aware that he/she was viewing prohibited material, purposefully searched for it, perhaps even using workarounds. Without this, there is no element of the offense,” – the lawyer notes. 

However, in practice, it can be difficult to prove the absence of intent, especially if the person used a VPN or regularly visited blocked resources. In addition, even scientific or educational searches can fall under suspicion – for example, a student who searches for works by authors from the “prohibited list” may appear under administrative proceedings. 

What exactly is prohibited from reading or viewing? 

According to the legislation of the russian federation, the following materials can be recognized as extremist: 

• websites, books, songs, videos from the official register of the Ministry of Justice of the russian federation: https://minjust.gov.ru/ru/extremist-materials/ 
• materials that “justify violence”, “incite social hatred” or “justify national/racial superiority”; 
• content mentioned in the law “On Counteracting Extremist Activity” – these are often vaguely formulated criteria that allow the law to be interpreted arbitrarily. 

“In fact, the law obliges a person to check the entire federal list of prohibited materials before reading something. This is physically impossible. And therefore, everyone becomes a potential violator,” – emphasizes Viktor Vuika. 

Consequences for the residents of Crimea 

The conditions created by the new regulations pose real risks for activists, journalists, students, teachers, and other social media users. Especially under occupation, where there is systematic political persecution and control by special services. 

Activists and journalists can be prosecuted for subscribing to banned channels or even for privately storing materials. Students may be punished for using sources for their studies if they are deemed extremist. Ordinary users can fall under suspicion simply for using a VPN or visiting blocked platforms (Instagram, Facebook). 

These changes are another tool for expanding censorship and strengthening digital control, the lawyer emphasizes. If before they were persecuted for words, now they are persecuted for reading. And this may become a new stage of pressure on the residents of the occupied territories, including Crimea. тати новим етапом тиску на мешканців окупованих територій, включно з Кримом. 

“Foreign agents” must remain silent: a complete ban on educational activities

From now on, individuals and organizations recognized in the russian federation as “foreign agents” are completely prohibited from engaging in any educational activities – not only with minors, as was the case before, but with any audience, regardless of age. 

What does this mean in practice? 

As noted by Crimea SOS lawyer Viktor Vuika, this norm actually makes any public activity impossible for people and organizations with the status of “foreign agent”, including in occupied Crimea. 

“Courses, lectures, trainings, consultations, publications on social networks – all of this is now under a direct ban when it comes to a ‘foreign agent’,” – explains Vuika. – “Even just sharing knowledge or experience in a public space is already a violation.”

This means that those Crimean activists, human rights defenders or journalists who do not conduct formal educational activities, but who speak out publicly, comment, explain, and hold online events, are also under attack. Even if there is no official decision yet on recognition as a “foreign agent”, informal persecution is still possible. 

Who can be banned from working or speaking out and for what?

In russian legislation, a “foreign agent” can mean not only organizations that receive funding from abroad, but also any individual who is under the so-called “foreign influence.” The following persons can be recognized as such:  

• persons who collaborated with “foreign agent” media; 
• those who received grants or payments from abroad (even on a freelance basis); 
• people who participated in international events, projects or trainings; 
• activists who publicly express a position that differs from the official kremlin line.

What are the consequences for the inhabitants of the peninsula? 

New restrictions make it impossible: 

• to conduct online lectures and webinars (even on Zoom or YouTube); 
• to publish educational materials on social networks; 
• to participate in public campaigns related to human rights, historical memory, analytics, etc.; 
• to organize courses, trainings, even free consultations. 

“In fact, the educational sphere in the russian federation – and, accordingly, in the occupied Crimea – is coming under full state control. Foreign agents are not only prohibited from sharing knowledge, but also have their licenses revoked; they are prohibited from receiving funding, and using the simplified taxation system,” – the lawyer adds. 

The new restrictions are another step towards the information isolation of the occupied territories, where alternative sources of knowledge, independent voices, analytics, or critical thinking are being pushed out under the threat of persecution. This directly threatens Crimean activists, human rights defenders, journalists, and anyone working on educational or analytical topics. рналістам і всім, хто працює з освітніми чи аналітичними темами. 

One can’t advertise anywhere: how the ban on promotion on Instagram and Facebook will hit Crimean bloggers and entrepreneurs

A ban on any advertising on social networks deemed “extremist” or “undesirable” has also come into effect – primarily, this concerns Instagram and Facebook. Violation entails fines even for a single advertising post, story, or barter mention. 

This innovation directly affects Crimean users, especially the self-employed, small businesses, and bloggers who still use these platforms to promote their services or products. 

What can they be fined for? 

The law provides for the following fines: 

• self-employed persons – up to RUB 2,500 (about 750 UAH); 
• individual entrepreneurs – up to RUB 20,000 (over UAH 6,000); 
• legal entities – up to RUB 500,000 (up to UAH 150,000).

The following are prohibited:

1. any paid integrations with bloggers; 
2. targeted advertising; 
3. free advertising or barter cooperation (for example, a gift for a mention); 
4. promotional posts or stories that contain trigger marketing phrases: 

– “One place left”, 

– “Price is in the profile header”, 

– “Promo code for -30% – in the profile header”, 

– “Make it before the end of the month”. 

Risks for Crimean residents – not just for business 

Despite the fact that this is primarily about advertising, there are also risks for ordinary users who promote their services even informally – for example, craftsmen, tutors, photographers, consultants who use Instagram as a tool to attract clients. 

Bloggers who still have an audience on Instagram or Facebook are also at risk. Even if they don’t receive payment for integrations, common phrases with advertising elements can be considered a violation. 

“Formally, even the call to “write in direct messages” or “there is space left to record” can already be regarded as advertising. This creates a constant risk for those who have not stopped being active on prohibited platforms,” -​​ lawyer Viktor Vuika comments. 

What is allowed? 

Despite the strict framework, not all mentions of one’s services or activities on social media will be considered advertising. The law and government clarifications indicate what will not be considered as advertising:

• a story about oneself, experience, examples of work; 
• analytical or informational materials; 
• personal blogs without a call to buy something; 
• links to other resources (for example, Telegram), without direct advertising wording. 

Examples of “safe” phrases: 

“Sharing my experience in the field of…” 

“This is how I solve client cases” 

“More – in my Telegram” 

“The risk begins when there is a promotion of a service, an attempt to generate interest, even without payment – barter or just a reminder also fall under the ban,” – the expert emphasizes. 

What does this mean for Crimea?

Like previous changes, this norm is another tool to put pressure on any independent or uncontrolled activity. In Crimea, it can be used as a formal pretext for administrative persecution of people who remain in contact with the outside world through Instagram, Facebook, or other “undesirable” platforms. 

“On the one hand, these social networks have no alternative. On the other hand, even their tacit use as a business tool becomes dangerous,” concludes Viktor Vuika. 

Sovereign Internet and virtual panopticon: why it violates International Law

CrimeaSOS international advocacy expert Artem Oliinyk explains why the new russian bans are not just a matter of internal control, but a large-scale violation of basic human rights and international law. 

For context, we should focus more on what the russian federation seeks to achieve with its actions, in particular within the framework of the national project of a sovereign information space, looking back at the successful example of China in this area.  

First of all, such a level of information control can indeed be effective in preventing social instability and preventing the instant spread of “explosive” messages among the population. However, knowing the previous practices of the russian federation and the frequent violation of human rights by official authorities, such changes in the legislation of the russian federation cause justifiable concern.  

“The technical side of the issue is that the current edition of the list of extremist materials has about 5,000 items, which include almost everything – from videos and books to individual fragments, songs and graphic images,” – says Artem Oliinyk.  

According to him, this list is constantly updated, which will have 2 hypothetical consequences for russia and for the temporarily occupied territories of Ukraine. First, the russian federation will have to communicate this to people so that they are aware of this list, the consequences of searching and using it, and the need to regularly check the list’s content to avoid problems with the law.  

Second, the russian system will have to weed out isolated cases from systemic ones, since it is unlikely that the law enforcement system will be able to comprehensively approach the task of monitoring and fines across all regions, given the hypothetical number of such cases.   

Ukrainians who find themselves under occupation should be as careful as possible and not put themselves in danger, as even an innocent request can turn into a series of problems for them. However, it cannot be ruled out that russian security forces will find the necessary “requests” and materials themselves if a particular citizen seems “suspicious” to them.  

“While the war continues and the russian federation publicly withdraws from international agreements, ignoring the decisions of international bodies and the world community, people should take care to protect themselves during the occupation and avoid persecution, without even giving formal reasons for special attention to themselves,” – warns Artem Oliinyk. 

It is clear that the restrictions and discriminatory norms contradict the laws and international obligations of the russian federation, but the country explains the imposed restrictions with its own legislation, motivated by national security issues. russia views foreign agents as a threat that should be identified and limited as much as possible. According to current law, in addition to educational activities, foreign agents cannot be members of election commissions, panels of judges, they are prohibited from conducting independent anti-corruption expertise, in any way influencing the election process, organizing public events, making donations to political parties, exercising public control, etc. All of this is designed to push individuals to the periphery so that their content and authority are levelled in society and cannot constitute either an alternative or even a visible opposition to the regime.  

According to the advocacy expert of CrimeaSOS, the main problem lies in the actual application of russian legislation in uncontrolled territory, which further complicates the possibilities of protecting our citizens, who are being held liable under the new norms. Each country develops and applies its own legislation as it deems necessary, including imposing restrictions on certain categories of persons. The significant difference lies in the fact that these changes to the law of the russian federation and sanctions act not only for the security of russia, but are used as a legalized tool of political pressure on citizens who disagree with the regime’s policies.

The practice of banning social networks and other information platforms is not new and is often used around the world. Vkontakte and Odnoklassniki have been banned in Ukraine for many years, Telegram is blocked in China, and discussions are ongoing in the US around blocking TikTok, so this is also part of the domestic policy of these countries.  

“We are not so much interested in the blocking of American services, but russia’s attempts to develop its own networks and fill the information space from scratch or close to it. The russian elite is greatly enriched by such a project, expanding the national market to replace the already established foreign one, taking over long-term control over flows and finances,” – Artem explains.  

The introduction of analogue resources allows for the emergence of a new galaxy of elites and an entrepreneurial class loyal to the russian authority hierarchy. Of course, “nurturing” younger followers is only an indirect advantage over the primary goal of sovereignty in the information space.  

Today, we can say that the generation and promotion of such political or media content in the russian space will be limited as much as possible, instantly detected and deleted. Thus, Moscow is solving a number of tasks thanks to new changes, primarily aimed at controlling and monitoring society, and only then – at new sources of income that foreign corporations previously received.  

Back in 2016, the UN Human Rights Council adopted a Resolution on the Promotion, Protection and Enjoyment of Human Rights on the Internet, which effectively confirmed the equivalence of human rights in real life and online. However, it should be recognized that detecting and preventing violations of these rights becomes more difficult. Human rights violations will only increase with the trend towards sovereignization of the information space – states will monitor and punish, and a virtual panopticon threatens to become a close reality.  

Changes in russian legislation that came into effect on September 1 are another stage in the systematic construction of total digital and information control. Despite the fact that these innovations are officially presented as “protecting national security,” in practice they significantly restrict basic freedoms – access to information, freedom of speech, education, privacy, and entrepreneurship. 

What is particularly dangerous is that these norms are also applied on the occupied Crimean peninsula, violating international law and putting the local population under even greater pressure. In such conditions, it is critically important to inform people about new risks and restrictions – and at the same time to seek an international response to the russian federation’s attempts to legalize a digitally repressive regime not only within the country, but also in the occupied territories.