Hosting providers and owners of online services available in Russia will need to implement much faster procedures to respond to takedown requests received from Russian authorities to avoid blocking.
In more detail
Roskomnadzor, the Russian internet watchdog, is authorized to demand that local internet access service providers block access to restricted online content for the entire territory of Russia.
Effective from 29 December 2018, owners of websites (or other online services) are required to "immediately" block restricted content upon receipt of Roskomnadzor's takedown notices forwarded by their hosting providers.1 If such takedown requests are not "immediately" complied with, Roskomnadzor is entitled to "immediately" require local internet access service providers to block the relevant pages, websites or other online resources. This means that Roskomnadzor will only need to wait for one calendar day after sending a takedown request before it can proceed with actual blocking.
Previously, in most cases, prior to actual blocking, Roskomnadzor had to send a formal request to the service providers and they had three days to have their clients voluntarily remove or geo-block restricted content.
Hosting providers were required to inform their clients within one calendar day. Owners of websites (or other online services) were required to remove restricted content within one calendar day. If the owner failed to remove the restricted content, hosting providers had one more calendar day to block the content for Russian users.
Potentially, if content to be blocked is available through HTTPS protocol, the blocking of a particular web page may affect the availability of the entire website and/or other online services in Russia.
Although the above amendments change the most commonly used blocking procedure, they do not apply to all categories of restricted content. Other blocking procedures with their own requirements and timeframes remain intact.
What should you do?
- Website owners and operators of other online services should verify that their hosting providers can immediately forward takedown requests and other emails received from "@rkn.gov.ru" on a 24/7 basis.
- Website owners and operators of other online services should also revise their internal procedures for handling takedown requests.
Failure to timely respond to Roskomnadzor can result in your websites or other online services being blocked in Russia. Subsequent unblocking will remain possible, but can take several business days.
- Finally, it would be best to prominently display an abuse contact email on a website. Although Roskomnadzor is not legally required to send any notices directly to website owners, it frequently does so using the contact details published on websites or in WHOIS data.
1. Federal Law No. 472-FZ dated 18 December 2018