UIS URI (Unified System of Advertising Accounting on the Internet)

Main article: Internet advertising (Russian market)

As of July 2022

• Advertising System Operator - Advertising System
• Advertising Data Operator (ADR) - a special body that receives and processes information for transmission to

a single registry and also generates tokens

• The Unified Register of Internet Advertising (ERIR) is the system of Roskomnadzor. It stores information about advertising collected by all market participants.

As of August 2022

Advertising Data Operators

On October 14, 2022, the Commission under Roskomnadzor determined the list of advertising data operators (ORD). Steel operators:

• "Development Laboratory" (Sberbank),
• Yandex Advertising Data Operator (Yandex),
• VK Advertising Technologies (VK),
• "Ozon ORD" (Ozon),
• "MediaScout" (MTS),
• "First ORD" (VimpelCom),
• ORD-A (AmberData).

2023

Advertising labeling in Telegram: how to promote business without risks and fines

The introduction of mandatory labeling of online advertising in Russia from September 2022 was an important step towards increasing transparency and protecting the interests of consumers, and from September 1, 2023, a fine faces for violations in paragraph 3 of Art. 1 of the Federal Law of 02.07.2021 No. 347-FZ in the field of advertising labeling. Let's figure out how to organize advertising in Telegram channels now and who is responsible for labeling it. Read more here.

Roskomnadzor creates a service for verifying the validity of an advertising identifier

Roskomnadzor (RKN) creates a service for verifying the validity of an advertising identifier (erid). This was announced in July 2023 by the Association for the Development of Interactive Advertising (ARIR).

It is assumed that thanks to the new platform, the platforms will be able to make sure that erid belongs to exactly the advertising that they are offered to place. As noted in the association, the token verification service was developed "at the request of market participants." ILV also announced that users will receive notifications about possible errors with a request to check the correctness of the data in their personal account.

As noted in Roskomnadzor, the law on liability for unmarked advertising is not retroactive and will be applied to violations identified after September 1, 2023. In addition, the document will also be subject to ongoing offenses under existing contracts.

Now Roskomnadzor is considering the possibility of amending regulatory legal acts in terms of limiting the deadline for submitting static data on creativity, which always remains on the Internet, and placing the identifier at the end of the text, the ARIR said in a statement dated July 24, 2023.

Earlier, First ORD (VimpelCom) proposed bringing to the industry discussion an initiative to create a service for public verification of tokens. The reason for this decision was the incident that occurred with the Telegram channel of media manager Georgy Lobushkin.

It was noted that the blogger marked the post on the rating of companies in the field of AI, which prepared the "beeline" as an advertising one. At the same time, VimpelCom claims that they did not order or pay for this integration.

In June 2023, the State Duma in the third reading introduced fines of up to 700 thousand rubles for the lack of labeling of online advertising.^[1]

The State Duma adopted a law on fines for the lack of labeling of online advertising

On June 20, 2023, the State Duma adopted in the third (final) reading a bill on fines for the lack of marking of Internet advertising:

• for individuals up to 30,000 rubles;
• for officials - up to 100,000 rubles;
• for individual entrepreneurs - up to 200,000 rubles;
• for legal entities - up to 500,000 rubles;
• the fine for violation of the law by an advertising data operator (ORD) will be 200,000 rubles for officials and individual entrepreneurs and 700,000 rubles for legal entities.

State Duma deputies adopted in the third reading a bill on fines for the lack of labeling of online advertising

The document provides for amendments to the Code of Administrative Offenses, which imply "the responsibility of advertisers, advertising distributors and operators of advertising systems" for non-compliance with the new provisions of the law on advertising. The law should come into force on September 1, 2023, although industry participants proposed to postpone it at least until the beginning of 2024.

According to one of the authors of the initiative, a member of the State Duma Committee on Information Policy on Information Policy, Information Technology and Communications Anton Nemkin, the adoption of this bill "will allow" to close the shadow advertising market, stop publishing hidden advertising and solve one of the basic problems of the Russian economy - planning and distribution of information flows. "

By June 2023, all participants in the "advertiser - advertising agency - advertising distributor" chain are required to provide information about advertising posted on the network to the ERIR through the ORD. This can be done independently or through special organizations - advertising data operators. They assign identifiers to messages - unique digital designations with which you can monitor the distribution of ads.

In February 2023, Roskomnadzor and the Federal Antimonopoly Service postponed the introduction of fines for non-compliance with the requirements for labeling online advertising, which were planned to be introduced on March 1, 2023.^[2]

2022

FAS and Roskomnadzor divided the areas of responsibility

The Federal Antimonopoly Service (FAS) and Roskomnadzor divided the areas of responsibility for labeling advertising on the Internet. This was announced on November 17, 2022 in the FAS Telegram channel.

It is reported that the antimonopoly regulator will attribute the information to advertising and control the presence of the "advertising" mark and information about the advertiser.

FAS and Roskomnadzor divided the areas of responsibility for marking advertising on the Internet

Roskomnadzor, in turn, will record, store and process information about advertising on the Internet. In addition, the department will take control of sending information about advertising on the Internet to the Unified Register of Internet Advertising (ERIR). The regulator will also establish requirements for software used by advertising data operators when registering advertising on the Internet, maintain a register of advertising data operators and control the assignment of an advertising identifier to advertising on the Internet.

Advertising labeling is a process in which each ad creative is assigned an individual identifier (token). It consists of a combination of 32 characters - letters and numbers. The token generator is still in development, but according to the order of Roskomnadzor N 64, it is known how it should look like this:

"'DDMMGGHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHCH where:

• DD - date of creation of the token;
• MM - month of creation;
• YY - year;
• XXXXXXXXXXXXXXXXXXXXX - ORD Advertising Number.

Before launching the campaign, the advertiser sends ORD creatives (to the advertising data operator - a company that collects information and transmits it to ERIR). ORD assigns labeling to creatives, returns it to the advertiser, and sends the data to the registry. After unscrewing, the advertiser sends the ODR a report that the operator sends to the ERR.

All participants of the chain (advertiser, agency, advertising platform) can get access to information within one year, as well as Roskomnadzor, FAS and FTS.^[3]

Roskomnadzor will temporarily not be fined for the lack of marking of online advertising

On August 15, 2022, it became known that penalties advertizing there would be no digital marking for non-compliance with the requirements of the legislation until March 2023. This was Roskomnadzor stated at a meeting with representatives of the advertising market.

It is expected that during the specified period, the interaction of all participants in the chain on the transfer of information about campaigns launched on the Internet will be debugged.

Market participants will be required to register advertising in the ORD from September 2022. The transition period will last until October 31, after which regular work on labeling online advertising should start.

Mediaskout (MTS), Ozon-ORD, ORD-A (AmberData), ORD-Development Laboratory (Sber ), First ORD (VimpelCom), Yandex and VK are planning to become operators of advertising data. Roskomnadzor^[4]

In Russia, a law was adopted on the introduction of a unique identifier of advertising on the Internet

On July 6, 2022, the State Duma of the Russian Federation adopted a law introducing a unique identifier of advertising on the Internet. This measure will ensure traceability of advertising spread on the Internet and accounting for information about such advertising, Maxim Topilin, head of the State Duma Committee on Economic Policy, told TASS.

According to the document, advertising in the Internet space will be possible only using a unique digital designation that the advertising data operator assigns. The Ministry of Digital Development of the Russian Federation will establish requirements for the identifier, its content, its assignment regulations, as well as storage.

In Russia, a law was adopted on the introduction of a unique identifier of advertising on the Internet

From September 1, 2022, advertisers and advertising distributors will have to transfer information about advertising posted on the Internet to Roskomnadzor. The corresponding changes were made to the Federal Law of 13.03.2006 No. 38-FZ "On Advertising."

Roskomnadzor will create a single base of online advertising to strengthen control over it, as well as to control advertisers and distributors. The obligation to transfer information will not apply to distributors of social advertising. Information can be transmitted independently or through advertising data operators authorized for this by Roskomnadzor.

All operators will be included in the register of advertising data operators. The procedure for transferring information about advertising to the system, as well as the composition of the information transmitted and other nuances, will later be established by the Russian Government. Responsibility for non-transmission or transmission of false information about advertising has not yet been established.

New requirements have been identified for the advertising itself. Advertising placed on the Internet must contain a mark "advertising," as well as an indication of the advertiser and (or) a site with information about it (it is not yet specified what kind of information the site should contain). These requirements do not apply to ads on TV, radio, or Internet broadcasts.^[5]

Who should send advertising data to the system

As follows from the by-laws adopted in May 2022, provide information on advertising posted on the Internet aimed at attracting the attention of advertising consumers located in the Russian Federation must:

1. advertisers (legal entities or individuals, individual entrepreneurs), except those who have an exclusive right to advertising objects and (or) are manufacturers or sellers of goods, information about advertising of which to Roskomnadzor or an advertising data operator is obliged to provide advertising distributors, operators of advertising systems within the framework of contractual obligations with such advertisers;

2. advertisers and operators of advertising systems (legal entities or individuals, individual entrepreneurs) who carry out and (or) organize the distribution of advertising of any advertisers, including in the form of banners, text or text-graphic block, videos, audio recordings, audio and (or) live video broadcasts;

3. advertisers - owners of social networks, audiovisual services, news aggregators, organizers of the dissemination of information on the Internet, including organizers of instant messaging services, search engines operators.

Interaction of the authorized body with operators of advertising data, advertisers, advertising distributors, operators of advertising systems will be carried out using the information system of the radio frequency service (exclusively in electronic format using automatically generated forms of documents in the personal account).

Amendments to the Federal Law of March 13, 2006 No. 38-FZ "On Advertising" will enter into force on September 1, 2022.

2021

The Ministry of Digital Development has developed a procedure for interaction between Roskomnadzor and advertising data operators

In early December 2021, it became known about Ministry of Digital Development of the Russian Federation of procedure for interaction of Roskomnadzor with advertising data operators. The corresponding decree of the Government of the Russian Federation will enter into force on September 1, 2022 and will be valid for six years from that day.

The project approves the criteria for classifying participants in the Internet advertising market as persons obliged to provide information about advertising to the department, the composition of the information transmitted and the procedure for interaction between Roskomnadzor and participants in the Internet advertising market.

The Ministry of Digital Development presented the procedure for interaction of Roskomnadzor with advertising data operators

According to the document, the interaction of Roskomnadzor with advertising data operators is carried out through the IT system. Market participants must transfer data to the department within 30 calendar days from the moment of advertising on the Internet. At the same time, advertising data operators must store them in Russia for at least 5 years from the date of submission of information to Roskomnadzor.

Market participants will be able to enter data into the database both independently and with the help of advertising data operators, which will later be determined in regulatory legal acts. To do this, the system will provide market participants with an online platform for registering and opening a personal account.

From September 1, 2022, participants in the online advertising market will have an obligation to transfer information about the placed advertising to Roskomnadzor. As explained in the Ministry of Digital Development, this is necessary in order to ensure equal conditions for doing business for Internet companies in the market.

According to the document of the Ministry of Digital Development, Roskomnadzor will record, store and process information about advertising distributed on the Internet, including information about advertisers and advertisers of such advertising, operators of advertising systems - companies providing advertising services on Internet sites that belong to third parties.

The transmitted advertising information must contain an advertising identifier, an individual taxpayer number and the main state registration number of the advertiser, the representative of the advertiser, the advertising distributor, the operator of the advertising system and information about the agreement concluded between the advertiser, the representative of the advertiser, the advertising distributor and (or) the operator of advertising systems for the purpose of providing advertising services.

The Ministry of Digital Development has published a list of persons who must provide Roskomnadzor with information about advertising:

• advertisers, information on the acquisition of which the status of a legal entity or an individual entrepreneur is included in the unified state register of legal entities or the unified state register of individual entrepreneurs after August 31, 2022;
• advertisers who own social networks, audiovisual services, news aggregators, organizers of information dissemination on the Internet, including organizers of instant messaging services, search engines operators;
• any other advertising distributors who distribute advertising aimed at attracting the attention of advertising consumers located on the territory of the Russian Federation, on the Internet, etc.

It is noted that information about advertising distributed on the Web sent by the advertising data operator to the authorized body will have to be signed by an enhanced qualified electronic signature of a person authorized to act on behalf of the advertising data operator.^[6]

AT Consulting will develop a unified system for accounting for advertising turnover in Runet

On September 7, 2021, it became known that the Unified System for Accounting Advertising Turnover in Runet for 96 million rubles. will create AT Consulting, which, among other things, acted as an IT contractor for the Ministry of Internal Affairs. Read more here.

The bill on the creation of an advertising accounting system on the Internet was adopted in the third reading

State Duma of the Russian Federation adopted in the third reading a number of bills regulating Internet the sphere. This became known on June 18, 2021. In particular, at a plenary session on June 17, 2021, a bill was adopted in the third reading, which gives Roskomnadzor powers to create and maintain a single Internet accounting systems advertizing from September 1, 2022.

Roskomnadzor, through the processing and analysis of information posted in the advertising accounting information system, reconciles information in the information posted in the specified information system by advertising distributors, advertising system operators, advertising intermediaries, advertising data operators, the explanatory note says.

The obligation of advertising distributors, operators of advertising systems, advertising intermediaries who place advertising on the Internet, to post relevant information in this system is also introduced. At the same time, such a duty will not apply to the operator of social advertising.

Advertising distributors, operators of advertising systems, advertising intermediaries obliged to post information in the advertising accounting information system, will be able to post it independently or through advertising data operators.

A commission will be created by Roskomnadzor to select an advertising data operator. The procedure for its creation and activities, composition, as well as the conditions for selecting an advertising data operator will be established by the Government of the Russian Federation. Roskomnadzor will maintain a register of advertising data operators in a certain order.

A law on measuring the volume of an Internet audience has also been adopted. In accordance with the law, Roskomnadzor, by August 1, 2021, must, in accordance with the established procedure, select an authorized organization to study the volume of the audience with the termination of the powers of a previously selected authorized organization.

The document was developed to ensure the comparability, openness, reliability and completeness of data obtained as a result of research of the audience of TV channels (television programs, TV shows), network publications, audiovisual services, news aggregators and other information resources on the Internet that distribute media products, audiovisual works and other publicly available information.

Research on the volume of the audience on the Internet will be carried out on the basis of the methodology approved by Roskomnadzor. The register of information resources, the volume of the audience of which is subject to research, will also be formed by this department. At the same time, the procedure for maintaining such a register and the list of data included in it will be approved by the government of the Russian Federation.

The owner of the information resource, in turn, will be obliged to ensure the possibility of conducting research and provide the necessary data for this. At the same time, a number of restrictions are established by law for the measuring organization. Including it has no right to use data received from owners of information resources, otherwise than for research purposes, and also cannot distribute advertising.

The implementation of the provisions of the federal law will create an opportunity for cross-media research of the audience of audiovisual works and other information disseminated on the Internet and in other distribution environments, will ensure the comparability of the data received, in which market participants are primarily interested, the explanatory note noted.

The Federal Service for Supervision of Communications, Information Technologies and Mass Media (Roskomnadzor) explained that the law on the Internet advertising accounting system is aimed at creating transparent and fair relations between participants in the Internet advertising market.

{{quote 'This regulation will create the necessary conditions for the further development of domestic Internet resources, ensure equal compliance by all its participants with the legislation of the Russian Federation in the information sphere. If the law is signed, a register of advertising data operators will be created. There will be a special commission to include advertising data operators in this register. The timing of the creation of the commission, the procedure for its activities, the composition and conditions for the selection of advertising data operators will be determined by the government of the Russian Federation, the press service^[7] Roskomnadzor emphasized^[8]. }}

The State Duma adopted a bill on the creation of a system in the first reading

In early June 2021, the State Duma adopted in the first reading a bill instructing Roskomnadzor to create a unified system for registering advertising on the Internet. The department will also select authorized advertising data operators who, using special programs, will track the fact of advertising on the Internet. Data from the system will be transferred to the tax authorities.

The State Duma adopted in the first reading a bill on the creation of a unified information system for accounting for advertising on the Internet (EIS URI). The document was developed by the head of the State Duma Committee on Economic Policy, Industry, Innovative Development and Entrepreneurship Sergei Zhigarev and represents amendments to the law "On Advertising."

This system is necessary to combat the "gray" market: the traceability of advertising on the Internet, automation of the processes of collecting and processing information about advertising posted on the Web, as well as accounting and storage of such information. The creation of EIS URI will be engaged in Roskomnadzor. To ensure the operation of the system, Roskomnadzor will be able to attract the radio frequency service subordinate to it.

The URI UIS will ensure the collection, storage, processing and analysis of information, access to information contained in the system and the provision of such information in electronic form, interaction with other information systems, receipt and use of reliable and up-to-date information, monitoring the reliability, completeness, relevance and timeliness of information placement in the system.

It is assumed that the law, if adopted, will enter into force on July 1, 2022. According to the State Duma Committee on Economic Policy, thanks to the proposed bill, the advertising market will receive an instrument for interaction between advertising agencies and media with the state, and the data that will be stored in the advertising accounting information system can be used to improve the effectiveness of advertising campaigns. In addition, the creation of the URI UIS will significantly limit the possibilities of illegitimate schemes related to tax evasion, and will contribute to the cessation of economic activities of unscrupulous participants in the advertising market.

What information and who should transfer to the system

Information on advertising posted on the Internet, including information on advertisers and advertising distributors, operators of advertising systems, as well as advertising intermediaries, is subject to inclusion in the URI EIS. These are the persons engaged in activities related to the production of advertising for its placement on the Internet and the provision of advertising for placement on the Internet to advertising distributors, operators of advertising systems as an advertiser or in the interests of the advertiser.

The composition of this information will be determined by the Government. Information in the UIS URI will have to be stored for at least five years.

The information contained in the URI UIS is subject to protection in accordance with the legislation on commercial secrets. Advertisers, operators of advertising systems, advertising intermediaries who post advertisements on the Internet aimed at attracting the attention of consumers located in Russia, and meet the criteria that the Government will determine, are obliged to post information in the UIS URI. Such a duty does not apply to social advertising operators.

Advertising Data Operators

Advertisers and advertisers have the right to post information in the UIS URI independently or through advertising data operators - owners of computer programs designed to establish the fact of advertising distribution on the Internet, authorized by Roskomnadzor to record advertising on the Internet and submit information to the UIS URI. Roskomnadzor will establish requirements for advertising accounting systems for advertising data operators - computer programs used by advertising data operators.

To select an advertising data operator, Roskomnadzor will create a commission and maintain a special register. The procedure for creating this commission and the conditions for selecting operators will be established by the Government. The Government will also determine the procedure for interaction between Roskomnadzor and operators and other persons associated with the UIS URI.

Operators of advertising data and other persons providing information in the UIS URI will be responsible for its completeness, reliability, relevance and timeliness of its placement. Roskomnadzor will reconcile the information posted in the UIS URI. On issues of classifying information on the Internet as advertising, Roskomnadzor will interact with the Federal Antimonopoly Service.

Transfer of data to the tax service

Advertisers, advertisers, operators of advertising systems, advertising intermediaries, operators of advertising data, operators of social advertising have the right to access information posted in the UIS URI and directly related to their rights and obligations. Roskomnadzor will also provide access to information from the UIS URI to the Federal Tax Service and other persons in the manner prescribed by the Government.

According to the Association of Communication Agencies of Russia (AKAR), the volume of the Russian online advertising market in 2020 amounted to 253 billion rubles. This is 53% of the total advertising market in media. Finam analyst Leonid Delitsyn notes that in such conditions, the state's attention to this area and the desire to increase the collection of relevant taxes look logical.

In addition, Delicin notes, there is a problem of artificial cheating in Internet advertising. Recently, the American company DoubleVerify, specializing in combating this kind of cheating, held an initial public offering (IPO) on the New York Stock Exchange. According to her estimates, the volume of "twisted" online advertising is 40%. In Russia, this indicator should be even more, Delitsyn believes^[9]

Notes