New restrictions on accounting for online advertising expenses

In 2025, online advertising regulations were significantly tightened. The changes affected not only administrative liability but also tax accounting. Legislators effectively linked the ability to account for advertising expenses to compliance with advertising legislation and restrictions on certain online platforms.

While previously the key to recognizing expenses was their economic justification, this is no longer sufficient. Companies must confirm not only the validity of the advertising campaign and its connection to business activities, but also the legality of the platform itself, the correctness of the advertising labeling, and compliance with special restrictions in force online.

As a result, tax accounting of advertising expenses is gradually evolving into a comprehensive legal and compliance control procedure.

General rules for accounting for advertising expenses

Expenses related to the promotion of goods, works, services, company activities, trademarks, and means of identification are traditionally classified as other expenses related to production and sales.

Advertising expenses include, but are not limited to, the following costs:

• for placing advertisements on the Internet;
• for promotion in social networks;
• for contextual and targeted advertising;
• for advertising integrations;
• to participate in exhibitions and marketing events;
• for the creation and distribution of advertising materials.

However, as before, online advertising is not subject to income tax standards. This means that expenses can be fully deducted if the established conditions are met.

Two key conditions for accounting for expenses

To recognize online advertising for tax purposes, it is now necessary to simultaneously meet two basic criteria.

First, expenses must be economically justified and documented. The company is required to demonstrate the advertising campaign’s connection to its business activities and confirm the actual provision of services.

Secondly, the advertising itself must not violate legal restrictions. This set of requirements has become the main innovation of recent years.

In practice, this means that even actual expenses incurred may be excluded from the tax base if the advertising was placed in violation of the law.

Placing advertisements on prohibited resources

The Company does not have the right to take into account expenses for advertising placed on Internet resources, access to which is restricted within the territory of the Russian Federation.

We are talking, for example:

• about blocked social networks;
• about resources recognized as prohibited;
• about sites to which access is restricted by Roskomnadzor.

Thus, even if an advertising campaign was actually carried out and brought commercial results, tax accounting of such expenses is not possible.

Advertising on the resources of foreign persons and foreign agents

The restrictions also apply to websites of foreign entities that have not complied with the requirements of Russian legislation, as stipulated by Federal Law No. 236-FZ.

In fact, the following sites are at risk:

• those who have not opened a representative office in the Russian Federation despite having the corresponding obligation;
• not complying with the requirements of Russian regulators;
• associated with foreign agents or undesirable organizations.

This means that companies have to evaluate not only the advertising effectiveness of a site, but also its legal status.

Lack of advertising markings

A separate reason for refusing to account for expenses was the lack of mandatory labeling of online advertising.

Advertising information must be submitted to Roskomnadzor in accordance with Article 18.1 of the Law “On Advertising.” Labeled advertising contains:

• ERID identifier;
• information about the advertiser;
• information about the advertising distributor.

If advertising is placed without transferring data to the advertising data operator and without the required marking, the costs associated with it cannot be taken into account when calculating income tax.

Thus, the requirements of advertising legislation directly affect tax consequences.

Strengthening the role of accounting and internal control

Under the new conditions, accounting is no longer limited to simply recording expenses. Companies are effectively obligated to pre-screen advertising campaigns for compliance with the law.

This is especially important when interacting:

• with marketing agencies;
• with bloggers;
• with foreign advertising platforms;
• with digital promotion contractors.

Without internal controls, tax risks increase significantly. Moreover, claims may arise even after a long period of time during a tax audit.

What documents will need to be presented during the inspection?

During a tax audit, the inspectorate has the right to request confirmation that expenses were accounted for legally and that advertising was distributed without violations.

In practice, companies are advised to create a separate set of supporting documents.

It usually includes:

• contract with an advertising contractor;
• certificates of services rendered;
• media plans and placement reports;
• documents confirming the advertising marking;
• ERID information;
• screenshots of advertising materials;
• payment documents;
• analytical or marketing reports.

Of particular importance is the recording of the status of the advertising platform at the time of advertising placement.

Checking the legality of an online platform

Before launching an advertising campaign, companies are advised to independently verify the legal status of the platform.

For this you can use:

• Service for checking access restrictions to Roskomnadzor websites;
• register of prohibited websites;
• list of undesirable organizations of the Ministry of Justice;
• register of extremist organizations;
• FSB list of terrorist organizations.

Such verification becomes an element of tax security, and not just information compliance.

Internal procedures as a way to reduce tax risks

Given the new restrictions, it is advisable for companies to implement internal procedures for verifying online advertising before it is placed.

In practice, this may include:

• preliminary legal verification of advertising platforms;
• control of advertising marking;
• coordinating advertising campaigns with accounting and legal departments;
• storage of supporting materials;
• recording the audit results in corporate documents.

Additionally, many companies are beginning to prepare internal marketing reports or conclusions that reflect the site’s verification for the absence of restrictions.

Practical significance of the new rules

The 2025–2026 changes demonstrate a general trend toward integrating tax control and regulation of the digital environment. Online advertising is no longer viewed solely as a marketing tool; it is now subject to comprehensive legal oversight.

For businesses, this means the need to consider several sets of requirements at once:

• tax;
• advertising;
• informational;
• administrative;
• sanctions.

Errors in this area can lead not only to additional income tax assessments, but also to fines for violating advertising laws.

The modern approach to accounting for online advertising is based on the principle of increased taxpayer integrity. Companies must not only confirm the actual expenses but also prove the legitimacy of the entire advertising infrastructure through which they promote their advertising.

As a result, online advertising becomes not only a marketing process, but also a legal one, requiring coordination between accounting, legal, marketing, and contractors.

The more actively a business uses digital promotion channels, the greater the importance of preliminary legal due diligence of advertising campaigns and the quality of documentation supporting expenses.