Belarus has issued new regulatory requirements for digital services providers. The measures, which entered into force in early 2025, impose licensing obligations, algorithmic accountability duties, and software liability standards on companies offering digital services to Belarusian users. International technology companies that continue to serve the Belarusian market – even from outside the country – now face a direct compliance exposure they cannot afford to ignore.
Belarus's updated technology legislation introduces registration and licensing requirements for foreign digital services providers meeting defined user-volume thresholds. Companies above those thresholds must designate a local representative, comply with data localisation rules, and submit to algorithmic accountability audits within prescribed deadlines. Businesses that fail to act before the applicable compliance deadline risk suspension of access to Belarusian users and administrative penalties under Belarusian digital services law.
This alert sets out what changed, which business categories are affected, and the five immediate steps international companies should take now.
What changed and when it took effect
Belarus's technology legislation was amended to bring the country's digital regulatory regime closer to broader CIS-region trends. The core change is a formal tsifrovye uslugi (digital services) licensing regime that applies to a defined category of providers. The amendments took effect on 1 January 2025, with a transitional compliance window running to 1 July 2025.
The new rules establish three substantive obligations for covered providers. First, technology licensing: companies must obtain or confirm the relevant authorisation before offering regulated digital services to users located in Belarus. Second, algorithmic accountability: providers that deploy automated decision-making tools – including recommendation engines, content moderation systems, and AI-driven personalisation – must document their systems and make disclosure available to a designated supervisory authority. Third, software liability: the legislation sets out a standard of liability for defects or failures in software supplied as a digital service, placing greater responsibility on the provider than prior rules.
For companies with existing intellectual property registrations or technology licensing arrangements in Belarus, these changes interact directly with prior contractual and regulatory positions. Agreements concluded before 2025 may need to be reviewed and amended to reflect the new liability standard.
Who is affected and the compliance threshold
The new digital services rules apply to any legal entity – Belarusian or foreign – that provides digital services to users in Belarus above a defined activity threshold. A company is considered a covered provider if it meets one or more of the following criteria:
- It serves a significant number of active Belarusian users per calendar month, as determined by supervisory guidelines
- It generates revenue from Belarusian users exceeding a prescribed annual threshold
- It processes personal data of Belarusian residents in connection with a digital service
- It operates an online platform that facilitates transactions between third-party sellers and Belarusian consumers
Foreign companies with no physical presence in Belarus are not automatically exempt. The legislation adopts an effects-based test: if a service is directed at Belarusian users – through Belarusian-language interfaces, local currency pricing, or targeted advertising – the provider is treated as operating in-country for regulatory purposes. This mirrors the approach taken in analogous digital services legislation across the CIS region, including parallel developments in Russia's digital services rules.
Covered providers that are foreign entities must appoint an authorised local representative in Belarus. That representative accepts service of regulatory notices on the company's behalf and carries personal administrative liability for certain defaults.
To receive a preliminary assessment of whether your business falls within the threshold criteria, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
The transitional compliance window closes on 1 July 2025. Companies that have not completed the required steps by that date face suspension of access for Belarusian users and administrative fines under Belarusian technology legislation. The following five actions should be initiated without delay.
1. Conduct a threshold assessment. Map all digital services currently directed at users in Belarus. Assess user volumes, revenue, and data processing activities against the published threshold criteria. This assessment determines whether the full licensing regime applies or whether a lighter notification obligation is sufficient.
2. Review existing technology licensing arrangements. Contracts for software supply, SaaS, and platform access concluded before 2025 should be reviewed for consistency with the new software liability standard. Clauses that limit liability below the statutory minimum are now void under Belarusian law.
3. Document algorithmic accountability obligations. If your service uses automated decision-making, prepare a system description document covering the logic applied, data inputs used, and any human oversight mechanisms. This document must be available for submission to the supervisory authority on request. AI Act compliance frameworks developed for EU markets provide a useful structural model, though the Belarusian standard differs in specific requirements.
4. Appoint a local representative if required. Foreign companies above the threshold must formally designate a local representative before the deadline. The representative must be a legal entity or individual resident in Belarus with the authority to accept regulatory correspondence.
5. Assess the interaction with sanctions exposure. For companies headquartered in the EU, UK, or US, any steps taken to comply with Belarusian digital services law must be assessed against applicable sanctions regimes. Engaging a local representative or making payments to Belarusian entities may require authorisation. This dual-compliance risk is among the most underestimated aspects of the new rules. Our AI and technology law practice in Belarus addresses this intersection directly.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising technology companies, platforms, and institutional investors across 46 jurisdictions, including Belarus and the broader CIS region. Our practice covers digital services regulation, technology licensing, algorithmic accountability, and software liability across both civil law and common law systems. As a law firm advising international clients on Belarus matters. We combine on-the-ground CIS regulatory knowledge with the cross-border perspective that companies operating from the EU or UK require when engaging with high-growth and emerging markets. Engaging a lawyer in Belarus with cross-border sanctions experience is essential before taking any compliance steps in the current regulatory environment. To discuss how the new digital services rules affect your operations, contact us at info@ferrazwhitmore.com.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.