Outlook for 2026 Since 2022, approximately 12% of foreign investors fully exited Russia while nearly 32% of companies either suspended operations or announced such plans. As such companies continue to exit the Russian market, foreign investors will remain entangled in a long and convoluted clearance process imposed by FDI regime restrictions. There were continuous refinements of Russia’s FDI regime throughout 2025 and early 2026, which have resulted in additional hurdles for investors. Among other changes, there are additional procedural hurdles for foreign investors including additional areas (activities) that are deemed “strategic” for FDI review and expansion of definitions. Some of these changes have already been adopted, and Russia’s FDI regime will likely undergo additional amendments. Forced equity and asset transfers are also expected to continue, likely resulting in a growing number of arbitration and court proceedings, including potential investor-state disputes. As foreign investors consider transactions, they must conduct earlier due diligence on whether a target company may qualify as a strategic entity and whether the transaction would require the Sub-Commission’s consent.
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