Advertising ban on Telegram and YouTube: transition period, legal risks, and implications for businesses

The issue of advertising on digital platforms with limited access has finally entered the realm of practical application. Following the first cases involving advertising on Telegram and YouTube, the antimonopoly authority reaffirmed the general ban on advertising on such platforms, while simultaneously granting market participants a transition period until the end of 2026.

Essentially, this is not about easing regulations, but about giving businesses time to restructure existing promotion models, revise contracts, and transfer advertising activities to other information platforms.

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General logic of the ban

The basic approach is based on the principle that advertising should not be placed on resources with restricted access. If a platform is subject to technical access restrictions, its use for advertising distribution is considered a risk of violating established requirements.

At the same time, the introduced transition period only means a temporary non-application of penalties.

For business this means the following:

• the ban itself remains in effect;
• liability is temporarily not applicable;
• there remains a need to restructure the placements;
• current agreements require revision;
• Archival advertising publications are subject to inventory;
• It is necessary to determine acceptable alternative channels in advance.

Thus, the deferment does not cancel the obligation to bring advertising activities into compliance with the new rules.

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What is required from advertisers now?

For companies, the transition period should be viewed as a period for mandatory legal and organizational adaptation. By the end of the deferment, all long-term advertising campaigns, contracts with bloggers, and media plans must be brought into compliance with the new regime.

Particular attention should be paid to the following issues:

• current accommodation agreements;
• automatic renewal of publications;
• long-term advertising integrations;
• publications that remain available after the end of the campaign;
• payment schedules extending beyond 2026;
• placement within integrated advertising packages.

What is practically important is not only the fact of publication itself, but also the period of time it has been in the public domain.

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Consequences for bloggers and channel owners

For channel owners, bloggers, and other advertising distributors, the new rules are particularly significant, as a significant portion of commercial placements have historically occurred on Telegram and YouTube.

During the transition period it is necessary:

• revise the terms of cooperation with advertisers;
• change the order of placement of long-term integrations;
• provide for time limits for deleting publications;
• adjust the payment procedure;
• identify new platforms for advertising distribution;
• update standard contract forms.

After the transition period has ended, each individual advertising publication may be considered a separate violation.

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Competition issues and the list of acceptable resources

The mechanism for establishing a list of permitted information resources is a matter of particular debate. If access to the advertising market is effectively limited to a limited number of platforms, this impacts the distribution of advertising budgets and the position of market participants.

From the point of view of antitrust regulation, the following are of significant importance:

• criteria for inclusion of resources in the list;
• transparency of the selection procedure;
• equal access for market participants;
• lack of advantages for individual sites;
• impact on the cost of placement;
• concentration of advertising flows.

Insufficient transparency of such a mechanism poses the risk of restricting competition between platforms, which explains the increased attention paid to this issue by market participants and government agencies.

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Practical implications for business

For businesses, 2026 marks a mandatory transition to a new advertising model. The primary objective is not only to reschedule publications but also to completely revise the contractual and organizational structure of advertising activities.

The following have priority:

• checking all distribution channels used;
• revision of contracts with advertising distributors;
• transfer of advertising budgets to permitted sites;
• updating internal rules for advertising approval;
• checking old publications that remain available;
• control over the timing of posting removal.

Under the current circumstances, choosing a promotional platform becomes not only a marketing but also a legal issue. The transition period must be used to completely overhaul the advertising infrastructure, as after its completion, liability risks will arise for each individual placement.