Russia's insolvency legislation has undergone material amendments affecting the rights of creditors in active insolvency proceedings. International companies holding claims against Russian entities – whether through trade exposure, loan agreements, or intercompany arrangements – face tighter deadlines and revised procedural requirements. Missing these changes may result in claims being excluded from the register entirely.
Russia's amended insolvency legislation, effective from the first quarter of 2025, introduces stricter rules governing proof of debt submissions. The composition and powers of the kreditorov sobranie (creditors meeting). Additionally, the scope of authority granted to the arbitrazhny upravlyayushchy (administrator or liquidator). Foreign creditors must file updated documentation within the periods established under the amended rules or risk losing priority status in the distribution queue.
This alert summarises what has changed, which business categories are directly affected, and what international companies should do immediately to protect their positions.
What changed and when it took effect
Russia's insolvency legislation has long distinguished between reorganisation-type procedures and liquidation-type insolvency proceedings. The 2025 amendments consolidate and tighten several procedural rules that had previously been applied inconsistently across arbitrazhny sud (commercial courts of Russia) jurisdictions.
The key changes fall into three areas.
Proof of debt requirements. Creditors must now submit a more detailed proof of debt package. Documentary evidence of the underlying obligation, its current balance, and any prior enforcement steps must accompany the initial claim. Courts have begun returning incomplete submissions without extension of the original filing period. This is a significant departure from prior practice, where supplementary documents could be filed after the initial deadline.
Administrator and liquidator powers. The amended rules expand the investigative powers of the appointed administrator or liquidator. They may now request a broader range of historical financial records from the debtor and from related parties. This includes transactions completed up to three years before the commencement of insolvency proceedings. Creditors who were also counterparties to transactions in that window may face scrutiny of those dealings.
Restructuring plan approval. The threshold for approving a restructuring plan at a creditors meeting has been adjusted. A qualified majority – rather than a simple majority – is now required for plans that involve debt-to-equity conversions or significant haircuts. This change affects the balance of power between secured and unsecured creditors in complex restructurings.
The amendments entered into force in early 2025 and apply to all insolvency proceedings opened after that date. Proceedings already underway at the effective date are subject to transitional provisions, which courts have begun to apply in diverging ways.
For a broader view of creditor protection tools available under Russian commercial law, see our overview of corporate disputes in Russia.
Who is affected and why it matters now
The amendments affect a defined set of business categories. International companies should assess their exposure against the following threshold criteria.
- Foreign trade creditors holding unpaid invoices or supply-chain receivables against Russian entities currently in insolvency proceedings
- Lenders and bondholders with outstanding loan or bond exposure to Russian borrowers, including intercompany loan structures
- Former joint venture partners whose exit or buyout arrangements created deferred payment obligations now at risk in a debtor's insolvency
- Companies subject to administrator investigations arising from transactions concluded in the three-year look-back window
- Entities with restructuring plan exposure – particularly minority creditors whose voting weight may have shifted under the new qualified majority rule
The risk of inaction is concrete. A creditor who fails to file a compliant proof of debt within the prescribed period loses the right to participate in the distribution of the debtor's assets. There is no general discretion for courts to reinstate late claims. Once the claims register closes, excluded creditors have very limited remedies.
Parallel developments in neighbouring jurisdictions – including similar tightening of creditor procedures in Kazakhstan – illustrate a regional trend. Our alert on insolvency amendments in Kazakhstan sets out comparable changes for companies with CIS-wide exposure.
To receive an expert assessment of your creditor position in Russian insolvency proceedings, contact us at info@ferrazwhitmore.com.
Immediate actions for international companies
Companies with any of the exposures described above should take the following steps without delay.
1. Audit active and potential claims. Identify every Russian counterparty currently in, or approaching, insolvency proceedings. Confirm whether each relevant proceeding was opened before or after the 2025 effective date, since transitional rules differ. Do not assume that prior filings remain compliant under the new documentation requirements.
2. Review proof of debt packages already filed. If a proof of debt was submitted before the amendments took effect, assess whether it meets the updated evidentiary standard. Where proceedings are ongoing, it may be possible to supplement filings – but the window to do so is narrow and court-dependent.
3. Map the three-year look-back exposure. Any transaction with the debtor concluded between early 2022 and the insolvency filing date may be subject to challenge by the administrator or liquidator. Document the commercial rationale and market-rate pricing for those transactions now, before a challenge is raised.
4. Assess voting position in active restructuring plans. If a creditors meeting is scheduled or a restructuring plan has been proposed, recalculate your voting weight under the new qualified majority rules. Minority creditors in debt-to-equity scenarios may find that previously adequate blocking positions are no longer sufficient.
5. Engage local insolvency counsel immediately. The procedural changes require local-law expertise. Engaging a lawyer in Russia with insolvency specialisation – or a law firm in Russia with cross-border creditor representation experience – is essential before the next procedural deadline in the relevant proceeding.
Detailed guidance on the full scope of insolvency proceedings available to creditors is set out in our service overview for insolvency and restructuring in Russia.
About Ferraz & Whitmore
Ferraz & Whitmore is an international law firm based in Lisbon, advising business clients across 46 jurisdictions. Our team combines Portuguese civil law expertise with English common law tradition to deliver cross-border legal solutions in insolvency, restructuring, and creditor rights matters – including proceedings in Russian and CIS jurisdictions. We advise international trade creditors, lenders, and institutional investors navigating insolvency proceedings in high-complexity markets. The firm's insolvency practice covers proceedings across both civil law and common law systems, supported by a network of local counsel in CIS jurisdictions. Our attorneys have advised on cross-border restructuring matters involving administrator-led processes and creditors meeting procedures in Russia and neighbouring jurisdictions. As an international law firm serving clients with CIS exposure, Ferraz & Whitmore provides results-oriented counsel where jurisdictional complexity is highest. To discuss your creditor position in a Russian insolvency proceeding, 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.
Published: April 16, 2026
Author: Anna Chen – Senior Associate, Asia-Pacific, Middle East & CIS