Decree No. 604: Temporary Administration of Critical Infrastructure Facilities
On August 24, Presidential Decree No. 604 of the Russian Federation, concerning measures to ensure the security of critical infrastructure facilities, entered into force. The document provides for the possibility of introducing temporary administration, under which the owner formally retains title to the asset but loses the ability to possess, use, and manage it.
Which facilities are covered by the Decree?
The scope is broad and includes industrial, fuel and energy, transport, logistics, utilities, and other facilities that are important for the security and stability of the state. The mechanism could potentially also apply to property, interests in Russian companies, and property rights.
The grounds for imposing temporary administration are broadly defined, including, in particular, violations of security requirements, threats to the operation of a facility, ineffective measures to counter UAVs, or delays in restoring operations. At the same time, the criteria for assessing effectiveness and the deadlines for restoration are not expressly defined.
What should businesses do?
Businesses should verify the status of their facilities and the applicable requirements, update their security documentation, keep records of the measures taken and restoration efforts, and review their insurance coverage and ownership structure.
In an environment of uncertain criteria, documented evidence of compliance with the requirements becomes a key element in protecting the owner’s interests.
