Further reporting requirements for Russian CSOs
The Ministry of Justice plans to make CSO reporting more complicated
These changes will affect non-commercial organisations, public associations, religious bodies, structural sub-divisions of foreign not-for-profit organisations and CSO foreign agents.
Daria Miloslavskaya, head of the Lawyers for Civil Society, believes that the changes to the reporting process will make the work of CSOs more difficult. An analysis of the new changes has been published on the Legal Team website (https://ngo-law.ru/article_120821).
CSOs and public associations
The Ministry of Justice intends to ask CSOs and public associations to provide information on the receipt and expenditure of funds from Russian legal entities owned by foreign citizens or stateless individuals.
There will be a section where targeted receipts from Russian citizens or legal entities acting as intermediaries when CSOs receive assets from foreign countries and their State agencies, international and foreign organisations, foreign citizens, stateless people or persons authorised by them will need to be entered.
Structural sub-divisions of foreign non-profit organisations
When reporting on the amount and sources of funds and other assets, as well as their planned distribution and expenditure, CSOs will have to record details of all money and assets received from Russian citizens, foreign states and their agencies, foreign and international organisations, foreign nationals and authorised persons.
New sections will be introduced for recording information on programmes being implemented, i.e. “Special conditions for programme implementation”, “Target indicators”, “Planned and implemented projects”, “Participants involved in implementing a programme”
The names and addresses of all those taking part, together with timelines, will need to be recorded by CSOs. If no activities took place, adding ticks will be sufficient.
CSO foreign agents
A form will be added on which the goals and objectives for each project, together with its various stages and conditions required for their implementation and funding, should be recorded.
CSOs will also need to report on planned events within each programme and once completed to provide information on each of the nine sections (instead of the six that there are now). As well as the name of the event, its purpose, funding sources and the date it took place, organisations will have to provide a list of participants and contractors to the Ministry of Justice, as well as a complete financial breakdown showing where money was spent and what assets were used. A report must be filled out for each event held.
Information on events that were included in a project but not held during the reporting period should be provided on a separate form.
The draft Orders that will give effect to the changes to the reporting forms for non-commercial organisations and public associations, religious bodies, structural sub-divisions of foreign CSOs and reporting forms for CSOs performing the functions of a foreign agent have been published on the official government website for draft legislation (https://regulation.gov.ru/projects).
Translated by Neil Hailey