We tell you how to comply with creative labeling requirements to avoid fines and release ads without interruptions. The article was updated in 2024.
ERIR, ORD and advertising marking
Who is involved in the labeling process?
General rules for labeling advertising on the Internet
Who transfers data to the ORD?
What data is needed for marking?
Fines for lack of marking
Questions about labeling
Expert advice
ERIR, ORD and advertising marking
Table of Contents
According to the new law, advertising data must be transferred to ERIR — the unified register of Roskomnadzor. It stores information about all digital advertising in Russia: information about the customers of the service, intermediaries, amounts spent, platforms used, and the number of impressions of each creative. The storage period is five years.
Access to the system is obtained through an account in Gosuslugi. Each of the participants in the advertising launch will be able to view only their own data. The full volume of information – from the advertiser to the statistics of impressions – is available to Roskomnadzor and to those who order the promotion of their goods or services. Information cannot be submitted to the system independently; this is done by a separate company – the advertising data operator (ADO). The operator transfers the data to the registry within ten days from the moment the data is received and stores it in its database for a year. The ADO records creatives, keeps track of advertising campaigns and issues a token – a symbolic code – to each creative.
To transmit information via the operator, the advertisement must be marked. To do this, you will need:
1. Register and sign an agreement with ORD.
2. Submit creative for registration.
3. Receive a token (ERID).
4. Add the “Advertisement” mark to the creative and specify the token.
5. Specify the customer’s details (legal entity name and TIN) in the ad.
The new law was adopted to make information about costs and intermediaries available to market participants, to make it easier for the state to audit taxes and combat prohibited content.
All the intricacies of digital advertising placement can be studied on the course “Internet Marketer”. Students practice on real projects: conduct research, write a promotion plan, launch campaigns and analyze the results. Experienced marketers help and give feedback on each independent work.
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Who is involved in the labeling process?
Before the new advertising labeling law, there were three participants in the market:
1. Advertiser – the manufacturer or seller of the product who decided what and how to advertise and paid the costs.
2. An advertising distributor who placed creatives on their own or third-party platforms. For example, a blogger or targetologist .
3. Advertising systems operator – an intermediary between the advertising distributor and the platform that ensures its operation, for example, VK Advertising .
Now two more have been added to them: ERIR and ORD. To launch an advertising campaign, you will have to select an operator, sign a contract, and then record all the information about the campaign in your personal account: from creatives to impression statistics. After that, ORD will send the received data to the registry.
But you don’t always have to choose an operator. There are those that are linked to their platforms: “Yandex Advertising Data Operator”, “VK Advertising Data Operator” and “Ozon ORD”. When launching a campaign on any of these resources, the corresponding ORD automatically marks the advertisement and sends information to the registry.
There are organizations that process data from all platforms, such as blogger ads in Telegram or company information in Google Maps. These are SberAds (formerly “Development Lab”), “First ORD” (VimpelCom), “MediaScout” (MTS), “ORD-A” (analytical platform Amberdata). You can choose one or more companies and sign a contract. Tariffs depend mainly on the volume.
General rules for labeling advertising on the Internet
What needs to be labeled
The criterion of “advertising nature” is subjective and may differ depending on the specific case. For example:
excessive description of the product and its advantages;
calls to purchase a product (indicating the place where such a product can be purchased);
focusing on a product through emotion or design – when it is shown large or highlighted in color.
These criteria include promotional posts, online broadcasts, PR publications, or even the main banner on a website. This also includes almost all contextual , targeted , media , and native advertising on the Internet.
What does not require labeling
The rules do not apply to:
advertisements that were launched on television or radio and then posted on the Internet without changes (but if this is advertising on digital television on the Internet, then the commercials must be marked);
promotion of products in newsletters and pop-up notifications for the internal customer base;
social advertising;
information of a reference and analytical nature.
Content that, according to the Federal Antimonopoly Service , is not advertising does not need to be marked, for example:
texts in search results;
ads on classifieds sites – Yandex Real Estate or Yula;
informational texts about the product on the company’s website; if the manufacturer not only talks about the product, but also encourages you to buy it (for example, “Buy a laptop with a 25% discount”), this is already advertising;
information that is “organically integrated” into works of science, literature, or art (for example, the name of the favorite drink of the protagonist of a novel);
review of the market of goods and services.
How different types of advertising are labeled
The word “advertisement” and information about the product owner are added to the creative. This is the advertiser’s name, OGRN and INN. The location of the information does not matter, the main thing is that it is visible to users. Therefore, when preparing creatives, pay attention to how they are displayed in different formats and advertising systems.
The method for adding an ID code to a token depends on the creative format:
● In a link to a resource: for example, https://resource_address/?erid=NNN, where NNN is a code from a set of letters and numbers.
When publishing illustrations – on top of the illustrations.
In video – on top of the video recording or at the beginning of it.
In the text of the post in the form erid: NNN.
To add code to non-standard creative formats, you can use the ARIR instructions .
Who transfers data to the ORD?
All participants in the advertising chain are now required to transfer their share of information to the ORD. Who exactly will interact with the operator depends on the agreements. These may be customers of the service or advertising distributors, such as platforms. All information is transferred in two stages: before and after the publication of creatives.
If the advertiser does not launch the ad themselves, it is more convenient for them to transfer data through an intermediary, such as an agency or freelancer. Then this must be recorded in an additional agreement to the contract. In addition to the responsibilities of both parties, it specifies the cost of services and the procedure for reimbursing a fine received due to the fault of the counterparty. If there is an NDA, it must be amended so that the information transferred is not considered confidential.
If a company plans to work with ORD without intermediaries, it is necessary to record the corresponding responsibility in the job description and select one or more employees who will mark creatives, track statistics and send them to ORD. Usually, this is done by an Internet marketer , and in large companies also by a contextualist , SEO optimizer and targetologist . Additional responsibilities are prescribed in employment contracts with employees.
What data is needed for marking?
To conduct an advertising campaign, you need to transfer information about it to ORD. The number of creatives and the timing do not matter. Even if it is one banner that is shown on VKontakte for several days, it will still have to be marked.
What to report before publication
Before launching a campaign, the advertiser or intermediary with whom the service customer has entered into an agreement indicates in the operator’s account:
1.● Information about yourself and the counterparty: company name, full name, TIN, OGRN/OGRNIP.
2.● Creative.
3.● Product description: for example, “Rose handmade soap”.
4.● Publication format: for example, a banner or a video clip.
5.● Placement platform. If the creative is placed on several sites of the same advertising network, indicate each of them.
6.● Contract details – parties and obligations of the parties, date of signing, advertising budget.
The operator sends the information to the registry and issues an identifier for each creative. The creative is then placed with a token and the “Advertisement” mark.
What to report after publication
Within 30 calendar days after the ad is shown, a report on the completed campaign must be submitted to the ORD. The advertiser or intermediary and advertising distributor, such as a blogger , sends the following data:
1.● dates of impressions and their number;
2.● expenses for the entire chain of advertising impressions;
3.● documents on the provision of services.
If the advertisement is placed on automated advertising platforms such as VK or Yandex, the campaign data will be sent automatically.
Fines for lack of marking
Fines for lack of marking, submission of incomplete or inaccurate information vary for different groups of persons.
For example, if a blogger registered as an individual entrepreneur posts ten unmarked advertising posts in his VKontakte group, he may be fined from 40 thousand rubles.
Two real cases with fines:
The Telegram channel “Lisa Rulit” was fined for failure to comply with the rules for labeling advertising on the Internet in November 2023. The owner of the channel confirmed that there was indeed no labeling in three cases.
The author of the Telegram channel “My Nizhny Novgorod” received a fine of 2,000 rubles from the FAS for 16 unmarked posts advertising several companies.
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Questions about labeling
Some of the wording in the law is difficult to interpret unambiguously. We have collected answers to several popular questions.
1. Should self-promotion be labeled?
Advertising of your products and services needs to be marked. For example, in order for a blogger to do this in ORD VK, he needs to:
Register with the ORD.
Create a counterparty for marking self-promotion (indicate full name, role, counterparty type, TIN, phone number).
Add information about blogs in the section with sites, add a contract with yourself and a zero sum.
Fill in the creative data and get a token. Then publish the creative.
It is important to choose the right role when creating a counterparty. If the blogger plans to advertise only his or her products or services, then there will be one role – “Advertiser”. If the blog will advertise other companies, then two roles need to be selected – “Advertiser” and “Publisher”.
2. Is it necessary to mark advertising in prohibited social networks?
Yes, it is necessary.
3. Can I use the same ERID across all creatives?
Different creatives must have their own unique ERID identifiers. If the creative does not change or is reposted, you can use one identifier. In this case, the monthly statistics must transfer the total number of impressions with one identifier.
4. Do email newsletters need to be labeled?
Roskomnadzor claims that mailings do not need to be labeled if they are sent to a company’s client base (the circle of recipients is limited) or if the letter advertises its own goods or services.
5. Do old ads (before 2022) need to be marked?
The law does not apply to creatives created before 2022, but it is better to be on the safe side and check that the publication date is indicated on old creatives.
