The government has updated the list of disclosures by issuers to protect against sanctions

Russian Government defined a list of corporate information that stock market participants may still not disclose in order to protect against possible sanctions. Issuers have been allowed not to disclose information to protect against restrictive measures from March 2022.

To the new list included intelligence:

• on the composition of management bodies and control over the financial and economic activities of issuers;
• information about affiliates and subsidiaries, financial investments, operations in foreign currency, transactions, including data that such transactions have not been made;
• information on the segments of the issuer’s activities in terms of information on the provision of services to them, products manufactured, the purchase of goods, the performance of certain works, counterparties, their sectoral and geographical structure.

As explained by the government, the approved norms take into account the need for further development of the capital market and debt financing, which require disclosure. In addition, the updated list contributes to the protection of sensitive data from the point of view of possible sanctions.

The resolution also defines a list grounds, in the presence of which issuers will have the right to limit the disclosure of these data. Among them:

• restrictive measures in force against the company or organization;
• availability of the status of an authorized bank;
• conducting activities on the territory of new regions of Russia.

In March 2022, the government suspended mandatory corporate disclosures by securities issuers until July 1, 2023. From January 2023 Bank of Russia resumed disclosure of financial statements, except for information “sensitive to sanctions risks”.

At the same time, the regulator repeatedly insisted on full disclosure by issuers. However, the Ministry of Finance considers it necessary extend non-disclosure of reporting for some companies. The ministry has already submitted a draft resolution to the government that would allow a number of companies not to disclose certain (mostly non-financial) reports.

Milena Kostereva