Ban on promoting VPNs: what it means for websites, bloggers, and users
Since March 1, 2024, Roskomnadzor Order No. 196 has been in force in Russia. It specifies the criteria for “information about means and methods for providing access to information resources to which access is restricted.” In plain language, these are the criteria for promoting tools that bypass blocking.
The order is aimed at public content: articles, guides, videos, posts. It does not cover the mere use of a VPN, but the distribution of materials that advertise or explain in detail how to bypass blocking specifically for prohibited resources. This difference is important.
Below we will review this neutrally: what exactly falls under the ban, what does not, and what websites, bloggers, and ordinary users should pay attention to. This is not legal advice; for a specific case, it is recommended to check with a lawyer.
In brief
- Roskomnadzor Order No. 196 entered into force on March 1, 2024.
- It regulates public dissemination of information, not VPN use.
- The ban covers advertising and detailed instructions for bypassing access restrictions to prohibited resources.
- Neutral mention of VPNs in news or an educational context is not covered.
- For bloggers and websites, the risk is a fine and/or inclusion of the page in the registry.
- For ordinary users, the order does not directly introduce new restrictions.
What Order No. 196 regulates
To understand what falls under the ban and what does not, it is necessary to distinguish the categories of information listed in the order.
Information describing bypass methods
Detailed instructions on “how to configure a VPN client / proxy / other tool in order to open a specific prohibited resource” are a typical example of content covered by the order. The more specific the connection to a prohibited resource, the higher the risk.
Information advertising bypass tools
Advertising specific services with statements such as “bypasses blocks on X, Y, Z” also falls under prohibited promotion. Placing such advertising on a website or in a publication may be qualified as a violation.
Information calling for use
Calls such as “bypass blocks” or “be sure to use a VPN to open prohibited content” fall under the order. A detailed analysis of the wording is available in the review on Garant (Гарант).
What is excluded
The order provides exceptions: scientific, statistical, and expert information. This also includes neutral information about the existence of VPNs, discussion of the technology, and news content without calls to action or instructions for accessing prohibited resources. This is the formal boundary, but enforcement for a specific material may be ambiguous.
What falls under the ban and what does not
| Content type | Covered by the order | Comment |
|---|---|---|
| Detailed instructions for accessing a specific prohibited website | Yes | High risk of qualification as promotion |
| VPN advertising with a promise to “bypass blocks” | Yes | Direct promotion of bypass tools |
| Call to “bypass blocks” | Yes | Falls under the wording of the order |
| Neutral news mention of a VPN | No | Falls under the exception for informational materials |
| Scientific / expert discussion of the technology | No | Direct exception in the order |
| Personal VPN use by an individual | Not regulated by this order | The order concerns public information |
How to check right now
If your material is debatable in content, you should first consult a lawyer and only then publish it. A self-assessment using a checklist is useful, but it does not replace a legal opinion on a specific text.
But the availability of a specific website or service is a technical question, and it can be checked with tools. Freedom Checker shows the real availability picture across different operators and regions. The text of Order No. 196 is published in ConsultantPlus (КонсультантПлюс) for those who need the primary source.
What is allowed and what is not: a practical review
For bloggers, the main risk is a fine and/or inclusion of the page in the registry of prohibited information, followed by blocking. In practice, the risk is higher for content directly tied to prohibited resources and containing clear instructions.
For websites, the risk is the same, plus liability for the resource owner. For ordinary users, the order does not directly introduce new restrictions: it regulates public dissemination of information, not personal use of services.
What to pay attention to
- The order regulates content, not VPN use.
- The more specific the connection to a prohibited resource, the higher the risk.
- Advertising with a promise to bypass blocks and instructions fall under the ban.
- News and expert content in a neutral tone are excluded.
- Business blogs and media should maintain an editorial checklist.
- Enforcement of the order may be clarified by official explanations and court practice.
- This article is a general overview, not legal advice. For a specific material, consult a lawyer.
Conclusion
Roskomnadzor Order No. 196 regulates public information, not use of the technology. For bloggers and websites, it creates real risks when publishing materials that are directly tied to prohibited resources and explain in detail how to open them. Neutral information and scientific discussion are excluded.
For an ordinary user, the order does not directly create new bans. For a specific case, especially if it concerns business or publications, it is worth consulting a lawyer.