Russia: tax service sends requests about foreign accounts after the 2025 data exchange

In brief

• According to business press reports of 22 October 2026, individuals are receiving demands and requests for explanations about foreign accounts, citing the automatic exchange for 2025 that took place in September.
• The Federal Tax Service has confirmed the process officially: if a person has not declared income or a controlled foreign company reported by another country, a risk flag is raised and an inspector deals with the taxpayer.
• Automatic exchange runs with 71 states and 9 territories under the tax service list in force since December 2025. EU countries, the UK, the US and Switzerland are not on it.
• You usually have 5 working days to reply. Not replying costs RUB 5,000 under the Tax Code; an unfiled account notification costs up to RUB 5,000 under the Administrative Offences Code.
• If you spent more than 183 days outside Russia in 2025, the account rules of the currency law do not apply to you, but you need to be able to prove it.

What is happening: the tax service is matching 2025 exchange data

Russia has taken part in the automatic exchange of financial account information since 2018. A bank in another country asks the client for their tax residence, once a year reports the accounts of non-residents to its own tax authority, and that authority sends the data to the client's country of residence. The package includes the name, date of birth, account number, year-end balance and income: interest, dividends, proceeds from selling securities. We describe the standard in the glossary entry on CRS.

In March 2026 Deputy Head of the Federal Tax Service Yulia Shepeleva explained how the service handles these data; the interview was published on the tax service website on 30 March 2026. According to her, the service first identifies the people reported by another country, then checks what they declared themselves. If income from the account is missing or a controlled foreign company has not been notified, a risk flag is triggered: an automatic check that creates a task in the system, after which an inspector contacts the taxpayer. In 2025 the tax service received exchange data from almost 60 countries.

The scale is also known from official figures. According to the deputy head, in 2024 about 700,000 Russian tax residents had accounts outside Russia, and the number of accounts in exchange countries exceeded 2 million, up 12% year on year. The number of accounts that individuals reported themselves grows by 31% a year on average.

The news of 22 October continues this work. According to business press reports citing tax advisers, Russians are receiving demands about foreign accounts in which the tax service directly refers to the automatic exchange for 2025 that took place in September 2026. The tax service has not published official statistics on the number of such letters, so I will not estimate the scale of the mailing.

What this means for you. If you hold a bank or brokerage account in an exchange country, the tax service most likely already knows its number, balance and income for 2025. The only question is whether this matches your notifications, reports and tax return.

Who receives the requests

Not every holder of a foreign account receives a request. Judging by how the tax service describes its work, a letter arrives when data from abroad do not match its own records. Typical situations are:

• No notification of account opening. The bank reported the account, but the tax office has no notification, which a resident must file within a month of opening. How to file it is described in detail in our article on notifying the tax service of a foreign account.
• No report on movement of funds. Turnover on the account in 2025 exceeded RUB 600,000, but no report was filed by 1 June 2026. The tax service itself has called this a common mistake: people forget that a report is required even for an account in an exchange country if turnover is above the threshold.
• Undeclared income. Interest on a deposit, dividends or gains from selling securities through a foreign broker were left out of the 3-NDFL return for 2025.
• Unreported foreign company. The account belongs to a company you control, but no notification about it has been filed. The glossary entry on CFCs explains what a controlled foreign company is.
• Disputed residence. The person considers themselves a non-resident, but the tax service has doubts. In this case, according to its management, the service requests border crossing data from the FSB Border Service.

A separate word about foreigners and nationals of other countries who live and work in Russia for more than 183 days a year. They are Russian tax residents too, and data on their accounts at home may arrive through the same channels if their country exchanges information with Russia.

What this means for you. If you filed everything on time and declared your income, a request is usually closed with a short reply and copies of documents. The problem arises where the notification or report does not exist at all.

Which countries send data to Russia in 2026

The list of jurisdictions is approved by the tax service. The current one is Federal Tax Service Order No. ED-7-17/883@ of 14 October 2025, registered by the Ministry of Justice on 10 December 2025. It contains 71 states and 9 territories. Kenya, Moldova, Mongolia, Papua New Guinea, Senegal, Thailand, Trinidad and Tobago, Uganda and the territory of Sint Maarten were added. Bermuda, the British Virgin Islands, Gibraltar and the Turks and Caicos Islands were removed; according to press reports, these territories themselves suspended exchange with Russia.

What matters most for the reader is what the list leaves out. There is not a single EU country on it, nor the UK, the US or Switzerland. The tax service says so openly: it does not currently exchange financial information with many unfriendly countries, but, according to its management, the geography of accounts has shifted towards neutral and friendly countries, and exchange with them is in place. These include the UAE, Turkey, Kazakhstan, Armenia, Singapore, Hong Kong, China, Thailand, Qatar and Saudi Arabia, as well as Norway, Monaco, Andorra, Liechtenstein and most Caribbean countries.

No exchange does not mean no obligations. For an account in France, Cyprus, Georgia or Serbia, the notification and annual report are required in any case, and the report is due whatever the turnover: the RUB 600,000 exemption applies only to EAEU and exchange countries. We covered the restrictions for Russian nationals at EU banks in the article on an EU bank account without a residence permit.

What this means for you. If your account is in the UAE, Turkey, Kazakhstan or Armenia, assume the tax service already has its 2025 data. If the account is in the EU, there are no exchange data, but the reporting duty is the same, and the tax service can check it in other ways.

What the requests ask and how long you have to reply

There is no single form of letter for exchange data. The tax service uses the ordinary tools of the Tax Code, and the type of document determines the deadline.

• Notice to appear and give explanations. The right to summon a taxpayer for explanations comes from Article 31(1)(4) of the Tax Code. The letter usually asks you to explain the origin of the account and income, confirm whether the notification and reports were filed, and provide documents.
• Request for explanations during a desk audit. If you filed a 3-NDFL return and the data from abroad contradict it, under Article 88(3) of the Tax Code the tax office asks for explanations or corrections. The deadline is five working days.
• Demand for documents. If the tax office requests documents from you during an audit, the deadline is ten working days (Article 93 of the Tax Code). A demand under Article 93.1 concerns transactions: it is fulfilled within five working days during an audit and within ten outside one. If you cannot gather the documents in time, you can notify the tax office within the same period and ask for an extension.
• A call or a message in your online account. In 2025 the tax service began reminding account holders in their online accounts to file a report if turnover exceeded RUB 600,000. Such a reminder is not a demand in itself, but I would not ignore it.

Deadlines in the Tax Code expressed in days are counted in working days. The count starts from the day you receive the document: for the online account this is the day after it is sent, and for registered mail the sixth working day after dispatch.

What happens if you do not reply. Under Article 129.1 of the Tax Code, failure to report information, including failure to provide explanations, is fined RUB 5,000, or RUB 20,000 for a repeat within a year. Under Article 126 of the Tax Code, each document not provided costs RUB 200. The amounts are small, but silence almost always leads to the next step: the tax service will decide on its own that you are a resident and owe tax.

Three obligations for a foreign account and the fines

A request based on exchange data almost always comes down to three obligations. The first two are set by Article 12 of Currency Regulation Law No. 173-FZ, the third by Chapter 23 of the Tax Code.

Account notification. Under Article 12(2) of the law, a resident notifies the tax office of opening, closing or changing the details of a foreign account no later than one month after the event. For late filing, Article 15.25(2) of the Administrative Offences Code sets a fine of RUB 1,000-1,500; for not filing at all, under part 2.1, RUB 4,000-5,000.

Report on movement of funds. The annual report is filed by 1 June of the following year under rules approved by Government Resolution No. 1365. It is not filed for an account in an EAEU or exchange country if credits or debits for the year did not exceed RUB 600,000. Filing up to 10 days late brings a warning or RUB 300-500, up to 30 days RUB 1,000-1,500, more than 30 days RUB 2,500-3,000. Breaching the filing rules costs RUB 2,000-3,000, a repeat breach RUB 20,000.

Tax on income. A Russian tax resident pays personal income tax on all income, including interest and dividends abroad. The 3-NDFL return is filed by 30 April and the tax is paid by 15 July. An unfiled return is fined 5% of the unpaid tax for each month, but no more than 30% and no less than RUB 1,000; non-payment is fined 20% of the amount, or 40% if intentional. Rates are currently 13% to 22%; what may change for dividends and interest is covered in our news item on the bill raising tax on deposits and dividends to 22%.

If the account belongs to your foreign company, a CFC notification is added. Individuals file it by 30 April; the fine for not filing is RUB 500,000 per company, and RUB 50,000 for an unfiled notification of participation in a foreign organisation. The changes to CFC rules under discussion for 2027 are described in the news item on the 2027 tax reform.

What this means for you. The administrative fines for accounts are small. What costs real money is something else: tax on undeclared income, late-payment interest, a 20% penalty and, for company owners, RUB 500,000 for each unreported CFC.

How to reply to a request: step by step

Foreign statements and residence certificates often need a sworn or notarised translation. Where large sums and a complex structure are involved, I would bring in a specialist in tax coordination between countries before replying.

183 days: how tax residence changes your obligations

This is where most confusion arises. The law has two different 183-day counts, and they do not coincide.

Tax residence. Under Article 207(2) of the Tax Code, a tax resident is a person who was physically in Russia for at least 183 days within 12 consecutive months. The final status for a year is determined by the calendar year. A resident pays personal income tax on worldwide income at 13-22%; a non-resident pays only on Russian income, usually at 30%. The rule is explained in detail in our article on the 183-day rule, and the general principles in the piece on what tax residence means.

Currency exemption. Article 12(8) of Law No. 173-FZ states that the notification and reporting requirements do not apply to individuals who spent more than 183 days outside Russia during a calendar year. Nor do those who stayed abroad for more than 183 days in the reporting year file the annual report. Here the count is of days outside Russia, not inside, and only by calendar year.

The reverse is also written into the law. If you previously did not file notifications because you lived abroad, and in a given year you spent 183 days or fewer outside Russia, you must notify the tax office of all accounts by 1 June of the following year and start filing reports. Example: a person lived in Dubai in 2023-2024, returned in 2025 and spent 120 days abroad. The notifications for the UAE accounts were due by 1 June 2026.

What this means for you. If you were abroad for more than 183 days in 2025, the answer to an exchange-based request is not excuses but evidence of non-residence. If fewer, you are most likely an ordinary resident with all the obligations.

If you are no longer a Russian tax resident

Many recipients have lived abroad for years. A bank in another country may have recorded Russia as the country of residence based on old data, such as a Russian passport and address at account opening. The data then go to Russia even though you have long since left.

What I would do in this situation. First, reply to the request and confirm your status: copies of passport pages with border stamps, a residence permit, a lease, a tax residence certificate from the other country. What this document is and where to get it is explained in the glossary entry on the tax residence certificate. Bear in mind that the tax service can check your statements against Border Service data.

Second, update your tax residence with the bank itself. If you are resident in the UAE, Cyprus or Serbia, the bank should know this from the self-certification form. The account data will then go to the country where you actually live, not to Russia. This is not a way to hide an account: you are simply giving the bank the correct country. How to confirm UAE residence is explained in our article on UAE tax residence; for Serbia and Georgia there are separate pieces on Serbian residence and on Georgian residence.

Third, remember your Russian income. A non-resident is exempt from Russian tax on foreign income but pays tax on rent from a flat in Russia, dividends from Russian companies and the sale of Russian property. And if you own a foreign company, CFC rules apply only to tax residents, but notifications for the years of residence remain your obligation.

According to official information, the tax service has postponed the launch of an automated system for determining tax residence until at least 2027. For now status is checked selectively when there is a reason: income, data from abroad, discrepancies in a return. Automatic exchange provides exactly such a reason.

What this means for you. Non-residence is a lawful position, but it has to be proven. Gather documents on your days abroad and your residence in the new country in advance, not after the third letter from the inspectorate.

What not to fear and what matters

The tax service says publicly that its goal in currency control is not the number of fines for late reports but detecting illegal currency transactions. Its management described the approach this way: a person who is late with a notification or report should be warned rather than fined. This is not a rule of law and cannot be relied on in every case, but the tone is telling.

The limitation period for currency law offences under Article 4.5 of the Administrative Offences Code is two years; for tax offences it is three years under Article 113 of the Tax Code. So requests about 2025 remain entirely realistic in 2027.

More serious than reporting fines are illegal currency transactions. If an account received money that the law does not allow to be credited abroad, the fine under Article 15.25(1) of the Administrative Offences Code is 20% to 40% of the transaction amount. So when replying, it matters not only that the account exists but where the money on it came from. If proving the origin of funds is difficult, a source of funds file will help: it is useful both for the tax service and for a foreign bank.

For those who hold part of their assets in cryptocurrency: the rules for crypto exchanges and wallets are changing separately, and we covered the deadlines in the news item on the P2P ban from 2027.

What to do now

• List all foreign bank accounts, brokerage accounts and e-wallets for 2025 with opening and closing dates.
• Count your days outside Russia in 2025. More than 183 - gather proof; fewer - check your notifications and reports.
• Check in your online account which account notifications the tax service already sees.
• If a notification or report has not been filed, file it now without waiting for a letter.
• Check your 2025 return: interest, dividends and gains from selling securities abroad.
• If the bank has recorded you as a Russian resident but you live in another country, update the bank form.
• If you need a new account in the country where you live, open it with the correct residence from the start.

If you are only planning a move and a change of residence, start by choosing the country: a comparison is in the article on the best countries for tax residence. Residence conditions for families with children are described in the guide to residence for families, and the programme for investors in the Emirates on the page UAE residence by investment. A country overview is in the section on the UAE. If it is easier to discuss everything at once, book an online consultation.

How this article was prepared

The article is based on primary sources: the interview with Federal Tax Service Deputy Head Yulia Shepeleva published on the tax service website on 30 March 2026; Federal Tax Service Order No. ED-7-17/883@ of 14 October 2025 listing the states and territories for automatic exchange (registered by the Ministry of Justice on 10 December 2025); Article 12 of Federal Law No. 173-FZ on Currency Regulation and Currency Control as amended on 4 August 2026; Articles 31, 88, 93.1, 113, 119, 122, 126, 129.1, 129.6 and 25.14 of Part One and Articles 207 and 228 of Part Two of the Tax Code; Articles 4.5 and 15.25 of the Administrative Offences Code. Information on the October 2026 requests and their references to the September exchange comes from business press reports and tax advisers dated 22 October 2026; the tax service has not published official statistics on such requests. This article does not replace advice on your own situation.