International letters rogatory directed at Russian authorities in the technology and software sector: key developments in 2027

Following amendments to the administrative handling of international letters rogatory that Russian authorities began implementing in late 2026 and which are reshaping practice in early 2027, foreign creditors seeking to trace and recover assets tied to technology companies and software businesses operating in Russia face a materially different procedural landscape. The changes affect how Russian courts and the Ministry of Justice process incoming rogatory requests, the categories of information considered disclosable in the technology and software sector, and the timelines within which responding authorities are prepared to act. For foreign creditors already engaged in cross-border recovery, understanding the current position under Russian law is not a planning exercise but an operational necessity.

Until recently, the standard approach to international letters rogatory directed at Russian authorities treated requests for information about technology-sector entities in the same procedural channel as any other commercial matter. Requests transmitted through bilateral mutual legal assistance frameworks or under the CIS Minsk and Chisinau conventions were processed by the Ministry of Justice before referral to the competent court or authority, with technology companies and software vendors receiving no sector-specific treatment.

That position has shifted in two identifiable ways since late 2026.

First, Russian authorities have applied heightened scrutiny to rogatory requests that seek disclosure of source code, software architecture documentation, licensing agreements, and technical specifications held by Russian software companies. In practice, this means that requests which, before this period, might have been processed as standard commercial evidence requests are now assessed against a broader set of considerations relating to the sensitivity of the information sought. The prevailing approach among the receiving authorities has been to require more detailed justification of relevance from the requesting party before the request is transmitted to the relevant court or company.

Second, requests directed at technology companies that hold or process data on behalf of Russian users are subject to a layered referral process that was not uniformly applied in prior years. Where a rogatory request touches on data held by a platform, payment processor, or software-as-a-service provider with Russian operations, the responding authority has in a number of recent matters referred the request not only to the court of competent jurisdiction but also to the relevant data protection and communications regulator for a parallel assessment. This adds a procedural stage that foreign creditors' advisers had not previously needed to account for in their timelines.

Before this period, foreign creditors could reasonably plan for a response horizon of several months under the standard mutual legal assistance channel. Under the current practice, matters involving technology-sector disclosures are taking materially longer – in some cases extending the effective response window beyond what earlier frameworks suggested. That extension is not codified in any single rule; it is the aggregate effect of the new scrutiny and referral steps described above.

The change does not affect the fundamental legal basis for letters rogatory directed at Russian authorities. Russia's obligations under its bilateral mutual legal assistance treaties and under the CIS multilateral frameworks remain in place. What has changed is the administrative practice through which those obligations are discharged in technology-sector matters specifically.

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" "The practical effect of these changes is not that Russian authorities are refusing engagement, but that the evidentiary and procedural threshold for technology-sector requests has risen. Foreign creditors who do not adjust their submission strategy accordingly risk losing months in a recovery timetable where time is rarely on their side." — Elizaveta Razina, Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners

The changes described above have uneven impact depending on the nature of the debt, the character of the Russian counterparty, and the type of asset being traced.

Foreign trade creditors whose Russian debtors operate primarily as software development businesses, platform operators, or technology intermediaries are most directly affected. In these structures, the principal recoverable assets are frequently not physical assets or real property but intellectual property rights, software licence receivables, domain registrations, intercompany receivables from affiliated entities, and payment platform balances. A rogatory request is often the only available mechanism to establish the existence and location of these assets, since they are not readily visible through public registry searches alone.

For creditors holding security over technology-sector assets – for example, a pledge over a software licence portfolio or a claim against a distributor with predominantly digital revenue – the new procedural layer means that the evidentiary preparation for a rogatory request must be more substantial from the outset. A request that is returned for supplementary justification, or which is held pending a parallel regulatory assessment, can delay the entire enforcement sequence at precisely the stage where the debtor has the greatest incentive to dissipate or restructure available assets.

Creditors with offshore asset positions connected to Russian technology businesses face a compounding difficulty. Where a Russian software entity has transferred IP rights or licence revenues offshore, often to CIS-adjacent holding structures, a rogatory request directed at Russian authorities may be one step in a multi-jurisdictional tracing chain. The delay introduced by the new scrutiny framework in Russia does not pause parallel proceedings elsewhere; it simply narrows the window within which Russian-sourced evidence can usefully inform those proceedings.

Under Russian insolvency legislation, preferential transfer claims may be pursued for transactions completed in the period preceding a bankruptcy filing – a window that creditors who delay initiating their tracing and rogatory strategy frequently underestimate. For technology-sector creditors, the combination of a longer rogatory response timeline and a fixed lookback period for avoidance claims makes early instruction of Russian counsel not merely advisable but directly connected to recovery outcomes.

If your recovery strategy depends on information held by Russian technology companies or software businesses, make an enquiry before delays in the rogatory process affect your position: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

The practical implication of the developments described above is that the standard approach to letters rogatory in technology-sector matters – submitting a request through the relevant mutual legal assistance channel and monitoring for a response – is no longer adequate as a standalone strategy.

Three adjustments are advisable for creditors currently engaged in, or considering, recovery proceedings against Russian technology companies.

First, the evidentiary burden within the rogatory request itself should be treated as a substantive exercise rather than a procedural formality. Russian authorities applying heightened scrutiny to technology-sector requests will look for clear articulation of why the specific information sought is material to the underlying claim, why it is held by the named respondent, and why disclosure through the rogatory channel is the appropriate mechanism rather than alternative means. Requests that do not address these points risk extended delays or referral back to the requesting party. Working with Russian counsel to structure the request from the outset – rather than engaging local counsel only after a first submission has been returned – is a material time saving.

Second, creditors should map the parallel referral risk before submitting. Where the request touches on data held by a platform or software provider with Russian user-facing operations, the probability of a referral to the relevant regulatory authority should be treated as high under the current practice. This does not prevent eventual disclosure, but it requires that creditors' advisers account for a longer timeline in their overall enforcement planning and in any concurrent insolvency proceedings where evidence milestones are live.

Third, given the interaction between rogatory response timelines and the time-sensitivity of asset tracing more broadly, creditors should consider whether parallel tracing steps – public registry analysis, analysis of intercompany structures through EAEU-jurisdiction public filings, direct court applications for interim measures in Russia – can be advanced contemporaneously rather than sequentially. Letters rogatory directed at Russian authorities in the technology and software sector remain a valuable instrument, but they should sit within a coordinated tracing strategy rather than function as the sole method of evidence gathering.

Open questions remain as to how the current scrutiny approach will be applied to requests involving technology companies with mixed Russian and CIS operations, where the information sought straddles multiple regulatory perimeters. Court interpretation of these cases is at an early stage, and the position may develop further during 2027.

For context on the procedural framework applicable to letters rogatory directed at Russian authorities more generally, see our analysis at International letters rogatory directed at Russian authorities — procedural framework and our comparative review at Comparative analysis: international letters rogatory across CIS jurisdictions.

The firm's Asset Tracing & Recovery practice advises foreign creditors on evidence-gathering strategy in Russian proceedings, including the preparation and submission of rogatory requests. Further cross-border recovery matters are listed at /matters/.

Q: What specifically changed in the handling of international letters rogatory directed at Russian authorities in the technology sector?

A: From late 2026 onwards, Russian authorities have applied heightened scrutiny to rogatory requests seeking disclosure of technology-sector information – including software documentation, licensing records, and platform data. Requests are now assessed for detailed relevance justification before transmission to the relevant court or company. Where a request touches on data held by a platform or software provider, a parallel referral to the relevant regulatory authority has become a regular procedural step. The result is an extended effective response timeline compared with prior practice, without any change to the underlying legal framework for mutual legal assistance.

Q: Which foreign creditors are most affected by these changes?

A: Creditors whose Russian debtors operate as software businesses, platform operators, or technology intermediaries are most directly exposed. These debtors' principal recoverable assets – IP rights, licence receivables, payment platform balances, intercompany receivables – are typically not visible through public registries and must be established through rogatory or equivalent evidence-gathering procedures. Creditors with offshore asset positions connected to Russian technology businesses, or those relying on rogatory evidence within active insolvency proceedings, face the greatest timeline pressure from the extended scrutiny framework.

Q: What should foreign creditors do now to protect their position?

A: Three steps are advisable. First, treat the evidentiary preparation for any rogatory request as a substantive exercise – work with Russian counsel to structure the request fully before submission rather than after a return. Second, map the parallel regulatory referral risk before filing, and build the extended timeline into enforcement planning and any concurrent insolvency proceedings. Third, pursue parallel tracing steps – public registry analysis, EAEU-jurisdiction filings review, Russian court applications for interim measures – contemporaneously rather than sequentially. Firms advising clients with Russian technology-sector exposures are encouraged to confirm their Russian counsel relationship before the recovery timetable becomes urgent.

For an initial assessment of your rogatory strategy and recovery options in the Russian technology sector, make an enquiry: info@vetrovpartners.com | WhatsApp/Telegram: +7 (983) 510-38-76

• International letters rogatory directed at Russian authorities — procedural framework
• Comparative analysis: international letters rogatory across CIS jurisdictions
• Asset tracing and recovery in Russian insolvency proceedings

Vetrov & Partners is a Russian boutique law firm established in 2009. The firm is recognised by Pravo-300 – Russia's principal legal directory – for eight consecutive years, and is listed as a trusted adviser by the German Consulate General in Novosibirsk.

The firm's Asset Tracing & Recovery practice advises foreign creditors, distressed investors, and foreign law firms on evidence-gathering strategy, cross-border enforcement, and IP-linked asset tracing in Russian proceedings. With over 1,000 matters handled since inception, the team combines deep procedural knowledge of Russian courts – including the arbitrazh courts of the Siberian and Ural federal districts – with direct partner involvement on every engagement.

Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom

This publication is provided for informational purposes only and does not constitute legal advice under Russian or any other applicable law. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Vetrov & Partners is a Russian-qualified law firm. For matters governed by foreign law or requiring local admission in another jurisdiction, we collaborate with trusted counsel in the relevant jurisdiction. For advice regarding your particular situation, please contact info@vetrovpartners.com.

— Elizaveta Razina Senior Lawyer, Practice Lead — IP Enforcement, Vetrov & Partners vetrovpartners.com/razina/