Federal Law 347-FZ "On Amendments to the Federal Law 'On Advertising'" came into effect on September 1, 2022, which makes it mandatory to label all adverts shown to users from Russia.
Ads need to be labeled only if they are geo-targeted in the Russian Federation.
Remember that fines and restrictions can only be introduced as of March 2023. That is why this is the time to sharpen your skills and understand the regulations for filling in the data.
In this tutorial, we will describe:
- Where to fill in data for labeling ads.
- Examples of interaction chains between the advertiser (client) and the advertising system.
- Which data you need to provide.
Read the instructions to the end before you enter the data and find out exactly what you need to submit.
First things first - “Where to fill in the data?”
Labeling information is entered directly in the VK advertising account. This advertising system is an ORD (Advertising Data Operator), and by law it sends the information you enter to the ERIR (Unified Register of Online Advertising). The ERIR is the final stage, which is monitored by Roskomnadzor.
From what we know now, you, as an advertiser or an advertiser's representative, are only required to fill out the information in the advertising system.
Terminology
Client – the one who’s ad is displayed, who sells the product or provides the services. I.e. it is the end client that gets the benefit from the ads in the form of increased sales.
Subcontractor is the one with whom the end advertiser has an agreement for advertising activities, i.e. the agency or the targetologist.
Agreement - an agreement-offer, bilateral agreement, additional agreement or any other document confirming the agreementual relationship between the end advertiser and the counterparty (agency, subcontractor, director, targetologist, etc.).
How to enter data in VK?
- Open the VK ad account
- Click the ad account name
- In the ad account, click the Legal info button – [edit]
- The “full form” will emerge to fill in data
As every VK ad account is registered via Zaleycash by default, there is no need to provide information about Zaleycash.
Examples of filling in data
Let’s take a look at the most common chain, where the client credits the budget directly via Zaleycash.
Example 1. Chain: VK > Zaleycash > Client
Client name – Name of organization, as stated in the EGRUL (Unified State Register of Legal Entities);
Client INN – INN of the organization or SP ID (if the client is a Sole Proprietor);
Client phone number – client phone number;
Agreement number – ask manager to which your account is linked to
If the agency on our end is RBS – 1900013339
If the agency on our end is Profitator – №1900014679
Subject of the agreement – Agreement for the organization of advertising;
Type of agreement – Service Agreement;
Date of agreement signed –
If the agency on our end is RBS – January 1, 2021
If the agency on our end is Profitator – 01.11.2020
Agency tel number (1) – +7 (495) 127-90-57;
Agency tel number (2) – +7 (497) 105-97-07
This is all the data you need to provide for this chain.
If you’re an agency or a directologist, and you’re filling in information for the end advertiser, then the following information is for you.
The main nuance that makes all the difference in completing the Legal info section, is whether you use the client payments to replenish ad budgets, or the client pays to Zaleycash directly.
Let’s look at both options:
- If you do not accept payments from the end advertiser, the end client credits the ad budgets directly to Zaleycash from his current account. In this case, you as the directologist/agency, do not participate in the chain.
- If you do accept payments from clients to your accounts and transfer these funds from your current accounts to Zaleycash, then you do participate in the chain.
In the first case the chain looks the same as we described in Example 1.
In the second case it is different. Let’s take a closer look:
Example 2. Chain: VK > Zaleycash > Subagency > Client
If you fall into this chain, you need to provide information on the Client and the Subagency.
Additionally, you need to check the “Subcontractor” box.
Client name – Name of the client’s organization, as stated in the EGRUL (Unified State Register of Legal Entities);
Client INN – INN of the organization or SP ID (if the client is a Sole Proprietor);
Client phone number – client phone number;
Agreement number – number of agreement between the Subagency and the client;
Subject of the agreement – subject of the agreement between the Subagency and the client;
Type of agreement – type of agreement between the Subagency and the client;
Date of agreement signed – date of agreement between the Subagency and the client;
Subcontractor name – Name of Subagency as per EGRUL;
Subcontractor INN – Subagency INN;
Agency tel number – Subagency phone number.
Example 3. Chain: VK > Zaleycash > Subagency 1 > Subagency 2 > Subagency 3 > Subagency X > Client
Note, that this type of chain is possible, only if each element transfers the payment for the VK ad budget to the following participant, from account to account following the chain of participants.
In this case, in the “full form” information about Subagency X needs to be filled in, since it is the closest to the end advertiser. The remaining chain elements are required to provide information about the agreement and service/work deeds in the ORD VK at the end of the accounting period regulated by Roskomnadzor.
Client name – Name of the client’s organization, as stated in the EGRUL (Unified State Register of Legal Entities);
Client INN – INN of the organization or SP ID (if the client is a Sole Proprietor);
Client phone number – client phone number;
Agreement number – number of agreement between the Subagency X and the client;
Subject of the agreement – subject of the agreement between the Subagency X and the client;
Type of agreement – type of agreement between the Subagency X and the client;
Date of agreement signed – date of agreement between the Subagency X and the client;
Subcontractor name – Name of Subagency X as per EGRUL;
Subcontractor INN – Subagency X INN;
Agency tel number – Subagency X phone number.
After you have completed and saved all the data, you can start configuring the ad campaign.
Once you have entered all the necessary data for configuring the ad campaign — you need to check the “Send data to ORD” box.
The previously filled in information will be transmitted to the ORD only if you check that box.
There are options to exclude yourself from the chain of intermediaries or end advertisers. Contact the manager to discuss this. He will ask additional questions and will provide you with an individual set of instructions
These are the main chain options for data transfer, but they are suitable for most cases.
If you have any questions, or your work model differs significantly from the provided examples, do contact us, explain the details and we will try our best to help.
Note, it is highly likely that in the upcoming months Roskomnadzor will provide additional elaborations and changes in the method of the ORD operation. We will update and supplement this guide.