01 August 2025

Anti-terrorism Protection of Facilities in Russia: Legal Requirements and Compliance

August 1, 2025

BRACE Law Firm ©

Over the past few years, geopolitical complications have significantly increased the risks associated with terrorist acts. According to statistics from the Ministry of Internal Affairs (the "MVD"), 269 terrorist acts were registered in January 2025 alone. [1] For comparison, the total number of terrorist acts committed during the entire year of 2024 was 1,191. In 2023, only 410 terrorist acts were recorded;[2] thus, the volume of the terrorist threat increases several times each year.

Drone attacks, with technical equipment that is becoming increasingly sophisticated, have caused a sharp rise in terrorist threats.

This situation dictates strict requirements for ensuring security at any facilities and territories, while physical and engineering-technical protection measures require constant improvement. Currently, the legislative level has established a comprehensive regulatory framework that governs anti-terrorism measures for buildings, structures, and territories.

An objective protection system (facility protection system) may include a range of various security measures:

Physical protection (fencing, checkpoints, and security guards);
Video surveillance and lighting systems;
Access Control and Management System (the "SKUD");
Security and panic alarm systems;
Special protection measures against drones.

Each facility determines the specific composition of necessary anti-terrorism measures individually. This determination considers the facility's industrial purpose, departmental affiliation, risk factors, and the forecasted consequences of a terrorist act (potential human and financial losses). In any case, the protection system must ensure the ability to prevent a terrorist act or, at the very least, minimize its consequences.

Regulatory Framework for Anti-terrorism Protection of Facilities

Federal Law No. 35-FZ dated March 6, 2006, On Countering Terrorism (the "Law No. 35-FZ") establishes the basic foundations for anti-terrorism requirements.

Anti-terrorism protection of a facility or territory means the state of a facility that prevents the commission of a terrorist act or at least reduces the scale of its consequences. Buildings, structures, constructions, territories, or infrastructure (the "facility"), as well as places of mass stay of people, must be under such protection.

According to Article 3(6) of the Law No. 35-FZ, a place of mass stay of people is:

A public territory of a federal territory, settlement, municipal district, or urban district;
A specially designated territory outside of public territories;
A public place of a facility if more than 50 people can stay there simultaneously.

Not only legal entities that own these facilities but also individuals using the facility for entrepreneurial activities must comply with facility protection requirements (Article 5(3.1) of the Law No. 35-FZ).

The specific nature of regulatory oversight for anti-terrorism protection of facilities lies in the lack of total unification: rules and requirements are differentiated for facilities based on their target purpose and industrial departmental affiliation. The Law No. 35-FZ establishes only a general rule that the Government of the Russian Federation (the "Russian Government") sets such requirements (Article 5(2)(4) of the Law No. 35-FZ). Special security requirements are developed for each group of facilities. However, these regulatory documents share the same structure because a unified methodology, approved by Decree of the Russian Government No. 1244 dated December 25, 2013, On the Anti-terrorism Protection of Facilities (Territories) (the "Decree No. 1244"), is applied for their preparation. As a result, several dozen decrees of the Russian Government have been approved to date, regulating anti-terrorism security requirements for buildings, structures, territories, and infrastructure.

Decree of the Russian Government No. 272 dated March 25, 2015, On the Approval of Requirements for the Anti-terrorism Protection of Places of Mass Stay of People and Facilities (Territories) Subject to Mandatory Protection by the National Guard Troops of the Russian Federation, and the Forms of Safety Passports for Such Places and Facilities (Territories) (the "Decree No. 272") is the most general and unified in character. This document applies to any facilities that meet the criteria for mass stay, as well as those protected by Rosgvardia.

Other Russian Government decrees establish protection rules for various groups of facilities depending on their departmental affiliation, industry, and target use. For example:

For trade facilities — Decree of the Russian Government No. 1273 dated October 19, 2017, On the Approval of Requirements for the Anti-terrorism Protection of Trade Facilities (Territories) and the Form of the Safety Passport for a Trade Facility (Territory) (the "Decree No. 1273");
For hotels — Decree of the Russian Government No. 447 dated April 14, 2017, On the Approval of Requirements for the Anti-terrorism Protection of Hotels and Other Accommodation Facilities and the Form of the Safety Passport for These Facilities (the "Decree No. 447");
For industrial facilities under the jurisdiction of the Ministry of Industry and Trade of Russia — Decree of the Russian Government No. 258 dated March 1, 2024, On the Approval of Requirements for the Anti-terrorism Protection of Industrial Facilities (Territories) Under the Jurisdiction or Relating to the Sphere of Activity of the Ministry of Industry and Trade of the Russian Federation and the Form of the Safety Passport for These Facilities (Territories) (the "Decree No. 258");
For agricultural facilities — Decree of the Russian Government No. 836 dated July 13, 2017, On the Approval of Requirements for the Anti-terrorism Protection of Facilities (Territories) of the Ministry of Agriculture of the Russian Federation and Facilities (Territories) Relating to the Sphere of Activity of the Ministry of Agriculture of the Russian Federation and the Form of the Safety Passport for These Facilities (Territories) (the "Decree No. 836");
For children's health camps — Decree of the Russian Government No. 732 dated May 14, 2021, On the Approval of Requirements for the Anti-terrorism Protection of Facilities (Territories) Intended for the Organization of Children's Recreation and Health Improvement and the Form of the Safety Passport for Stationary Facilities (Territories) Intended for the Organization of Children's Recreation and Health Improvement;
For facilities under the jurisdiction of the Ministry of Justice of Russia — Decree of the Russian Government No. 1552 dated September 28, 2020, On the Approval of Requirements for the Anti-terrorism Protection of Facilities (Territories) of the Ministry of Justice of the Russian Federation and the Form of the Safety Passport for Facilities (Territories) of the Ministry of Justice of the Russian Federation;
For healthcare facilities — Decree of the Russian Government No. 8 dated January 13, 2017, On the Approval of Requirements for the Anti-terrorism Protection of Facilities (Territories) of the Ministry of Health of the Russian Federation and Facilities (Territories) Relating to the Sphere of Activity of the Ministry of Health of the Russian Federation and the Form of the Safety Passport for These Facilities (Territories);
For cultural facilities — Decree of the Russian Government No. 176 dated February 11, 2017, On the Approval of Requirements for the Anti-terrorism Protection of Facilities (Territories) in the Sphere of Culture and the Form of the Safety Passport for These Facilities (Territories);
For facilities of the Ministry of Emergency Situations (the "MChS") — Decree of the Russian Government No. 1133 dated August 31, 2019, On the Approval of Requirements for the Anti-terrorism Protection of Facilities (Territories) of the Ministry of the Russian Federation for Civil Defense, Emergencies and Elimination of Consequences of Natural Disasters, Its Territorial Bodies and Organizations Under Its Jurisdiction, as well as the Form of the Safety Passport for These Facilities (Territories);
For facilities under the jurisdiction of the Ministry of Construction of Russia — Decree of the Russian Government No. 1055 dated October 17, 2016, On the Approval of Requirements for the Anti-terrorism Protection of Facilities (Territories) of the Ministry of Construction, Housing and Utilities of the Russian Federation and Organizations Under Its Jurisdiction, as well as the Form of the Safety Passport for These Facilities (Territories).

This is only a small list from the entire volume of regulatory documents establishing the procedure for anti-terrorism protection of facilities for various ministries and federal services.

Special security rules apply to the transport sphere and the fuel and energy complex (the "TEK"). Security measures at transport infrastructure facilities are regulated by Federal Law No. 16-FZ dated February 9, 2007, On Transport Security (the "Law on Transport Security"). For individual types of transport, facility protection rules are established in decrees of the Russian Government. Security at TEK facilities is regulated by Federal Law No. 21-FZ dated July 21, 2011, On the Security of Fuel and Energy Complex Facilities (the "Law on TEK Security").

Despite the large number of regulatory documents governing facility protection measures, they all share a similar structure and common features:

Almost all facilities are subject to categorization;
A facility safety passport must be prepared;
The facility protection regime depends on the level of danger, degree of risk, and the potential scale of consequences from a terrorist act.

Let us consider these aspects in more detail.

Categorization of Facilities: General Rules

Categorization is the classification of facilities into categories upon which the composition of their security requirements depends. While methods of categorization vary for different types of facilities, the general principle remains the same: the potential risk — meaning the scale of consequences if a terrorist act occurs at a given facility — is assessed. Generally, the average number of fatalities or injuries serves as the risk degree criterion, though potential property damage is also evaluated in some cases.

A special commission is created to assign a category, with its composition depending on the industrial and departmental affiliation of the facility. The commission inspects the facility and assesses its level of protection. During the inspection, the commission must:

Identify the most dangerous areas where a terrorist act or other emergency could lead to severe economic and social consequences;
Identify critical elements where a terrorist act or other emergency would prevent the normal functioning of the facility (e.g., lead to an accident or damage);
Conduct a detailed vulnerability analysis of the facility as a whole.

Following the inspection, the commission prepares an inspection and categorization act (the "act", "categorization act", or "inspection act"). This document is prepared in free form and records the category assigned to the facility. Additionally, the commission provides a conclusion on the current state of facility protection and offers recommendations or instructions for improving security measures. The content of the act is always information of limited distribution; therefore, the act must bear a limited access status mark. Categorization acts for trade facilities also constitute a commercial secret.

It is important to note that currently, for certain industries, facility categorization is not mandatory, provided that a category was already assigned to such facilities prior to March 13, 2022: [3]

Sports facilities;
Healthcare facilities;
Cultural facilities;
Hotels;
Trade facilities;
Facilities within the sphere of activity of the Ministry of Education of the Russian Federation;
Facilities of the Ministry of Science and Higher Education of the Russian Federation;
Children's health camps.

For these facilities, the right holder decides on re-categorization at their own discretion.

Industrial (or departmental) categorization of facilities should be distinguished from other classification methods that are also related to security but intended for different purposes and formed under different principles. The most well-known and applied is the classification of emergencies, established in Decree of the Russian Government No. 304 dated May 21, 2007, On the Classification of Natural and Man-Made Emergencies (the "Decree No. 304"). Depending on the territorial scale of the consequences, emergencies are classified as:

Federal: number of dead or injured exceeds 500 people or the amount of material damage is more than 1.881 billion rubles;
Interregional: when the emergency zone extends across several constituent entities of the Russian Federation. The number of dead or injured is more than 50 and less than 500 people, or the amount of material damage is more than 188.1 million rubles in each constituent entity, and the total damage does not exceed 1.881 billion rubles;
Regional: number of dead or injured is more than 50 and less than 500 people, or the amount of material damage is more than 18.81 million rubles but does not exceed 1.881 billion rubles;
Inter-municipal: when the emergency zone affects several municipal districts or urban districts within one constituent entity of the Russian Federation. The number of dead or injured is no more than 50 people or the amount of material damage is no more than 18.81 million rubles;
Municipal: number of dead or injured is no more than 50 people or the amount of material damage is no more than 18.81 million rubles, provided the situation is not local in nature;
Local: a situation within one facility where the number of dead or injured is no more than 10 people or the amount of material damage is no more than 376.2 thousand rubles.

This is a unified method for classifying emergencies that applies at all levels and for various territories and facilities, regardless of industrial and departmental affiliation. However, types of emergencies are not identical to the security categorization of the facility itself; they only serve as a basis for categorization (for example, facilities under Rosgvardia protection are categorized on this basis). Furthermore, this emergency classification is reflected in various regulatory acts governing facility protection. For example, SP 132.13330.2011. Code of Rules. Ensuring the Anti-terrorism Protection of Buildings and Structures. General Design Requirements establishes a classification for the design of capital construction projects regardless of their industrial purpose: [4]

Class 1 (High Significance): if a terrorist act would cause damage on a federal or interregional scale;
Class 2 (Medium Significance): if a terrorist act would cause damage on a regional or inter-municipal scale;
Class 3 (Low Significance): if a terrorist act would cause damage on a municipal or local scale.

Procedure for Assigning Categories to Various Types of Facilities and Industries

Let us examine the various processes for assigning security categories using the example of the most visited, socially significant, and vulnerable facilities.

Categorization of places of mass stay of people (the "mass stay places" or "mass stay facilities"). First, to correctly develop security measures, a mass stay facility must be included in the list of places of mass stay of people. Subsequently, within 30 days, a special interdepartmental commission must be created at the level of the constituent entity of the Russian Federation to conduct the categorization. The commission must perform the inspection of the mass stay place no later than 30 days from its creation date.

The classification of mass stay facilities depends on the number of people who can stay there simultaneously (Clause 10 of the Requirements for the Anti-terrorism Protection of Places of Mass Stay of People to Decree No. 272). Simultaneous capacity is determined based on monitoring results of the mass stay place over a period of 3 days, including working days, weekends, and holidays. Essentially, the facility category depends on the forecasted number of people who might be killed or injured if a terrorist act occurs at that specific location.

There are three categories for mass stay facilities:

Category 1 mass stay place — more than 1,000 people can stay simultaneously;
Category 2 mass stay place — 200 to 1,000 people can stay simultaneously;
Category 3 mass stay place — 50 to 200 people can stay simultaneously.

A mass stay place may be assigned a lower or higher category compared to the formal criteria depending on the number of terrorist acts actually committed over the last year.

The categorization act must be prepared within 10 days after the completion of the mass stay facility inspection.

Categorization of facilities protected by Rosgvardia is based on the forecasted number of facility employees and visitors who might be killed or injured in a terrorist act, also considering potential material damage and environmental harm in the facility's location (Clauses 5–12 of the Requirements for the Anti-terrorism Protection of Facilities (Territories) Subject to Mandatory Protection by the National Guard Troops of the Russian Federation to Decree No. 272).

The normative classification of emergencies established in Decree No. 304 is used as the basis for categorizing facilities protected by Rosgvardia; thus, assigning a category takes into account the territorial scale of consequences:

Category 1 (High Significance) — when the consequences of a terrorist act are of a federal or interregional character;
Category 2 (Medium Significance) — when the consequences of a terrorist act are of a regional or inter-municipal character;
Category 3 (Low Significance) — when the consequences of a terrorist act are of a municipal or local character.

A commission is created for the categorization of such facilities, including facility right holders and representatives of territorial security bodies, Rosgvardia, and the MChS. The procedure and timelines for the commission’s work are similar to the commission for categorizing mass stay facilities: the facility inspection is conducted within 30 days from the commission's creation date. Following the inspection, the categorization act—containing conclusions and recommendations on facility security in addition to the assigned category—is prepared within 10 days.

Categorization of hotels. The timelines for creating a categorization commission for hotels depend on the situation (Clause 9 of Decree No. 447):

If the hotel was functioning on the date Decree No. 447 was adopted — the commission is created no later than 2 months from the date of the said decree’s approval;
If a new hotel is being commissioned — the commission is created within 1 month after commissioning;
If a hotel safety passport needs updating — the commission is created within 1 month from the date of the decision to update the passport.

During the inspection, the commission studies the structural and technical characteristics of the hotel building, evaluates its operational organization, conducts an analysis of security measures, and identifies potentially dangerous areas.

There are 4 danger categories for hotels (Clause 12 of Decree No. 447):

Category 1 danger — if the number of victims would be more than 1,000 people;
Category 2 danger — if the number of victims would be 200 to 1,000 people;
Category 3 danger — if the number of victims would be 50 to 200 people;
Category 4 danger — if the number of victims would be fewer than 50 people.

Categorization of trade facilities. The following must be present in the commission for the categorization of trade facilities (Clauses 15 and 16 of Decree No. 1273):

The facility's security service (persons responsible for physical and engineering-technical protection), employees responsible for operational issues, and other specialists;
Representatives of territorial security bodies, Rosgvardia, and the MChS;
Representatives of the executive body of the constituent entity of the Russian Federation or the local self-government body;
Representatives of specialized organizations in the field of design and operation of technological systems and expert organizations in the field of trade facility security may also be included in the commission.

Trade facilities are divided into 3 categories (Clause 12 of Decree No. 1273):

Category 1 — If the potential number of dead or injured would be more than 1,000 people;
Category 2 — if the potential number of dead or injured would be 201 to 1,000 people (inclusive);
Category 3 — if the potential number of dead or injured would be 51 to 200 people (inclusive).

Based on the prepared act, the trade facility owner must develop and implement a complex of anti-terrorism measures within 2 years from the date of the categorization act's approval (Clause 19 of Decree No. 1273).

Lists of Facilities Subject to Anti-terrorism Protection Requirements

When implementing anti-terrorism requirements, there is one important point that causes many difficulties for organizations in practice. В some industries, anti-terrorism requirements apply only to those facilities included in a special list. If a facility belongs to an industry where such lists are maintained, it is obliged to fulfill anti-terrorism requirements only after being included in the list.

For example, the Ministry of Industry and Trade forms a list of facilities under its jurisdiction for which the requirements of Decree No. 258 are mandatory (Clauses 9, 10, and 68 of Decree No. 258). The Ministry of Agriculture maintains similar lists; moreover, Decree No. 836 explicitly states that far from all facilities are included in the list, but primarily chemically and biologically dangerous ones containing increased risks (Clauses 2, 3, and 4 of Decree No. 836). An agricultural facility located in closed administrative territories may not be included in the list. A separate list — maintained by regional or municipal authorities — is also formed for places of mass stay of people (Clause 2 of Decree No. 272). Protection rules for facilities protected by Rosgvardia also apply only to a specific list of addresses approved by an order of the Russian Government. [5] The anti-terrorism requirements of Decree No. 1273 apply to trade facilities included in a special list approved by regional authorities (Clauses 5 and 7 of Decree No. 1273).

However, there are spheres of activity where no special facility lists are provided. For example, anti-terrorism rules for hotels apply to any hotel facilities, except those that are simultaneously mass stay facilities or protected by Rosgvardia (Clause 4 of Decree No. 447).

Situations may arise where a ministry or its territorial body presents anti-terrorism protection requirements established in a Russian Government decree to a subordinate organization. In such cases, the organization should first clarify whether special facility lists are formed in that industry. If such a list exists but the organization is not included for some reason, the requirements presented to it are unjustified. This does not mean the facility can be completely unguarded: necessary physical and information security measures must be observed in any case. However, if the facility is absent from the list, a category is not assigned, meaning an inspection act is not prepared and a safety passport is not issued.

In some industries, such lists constitute information of limited access and are marked "for official use"; they may even be assigned a secrecy classification (e.g., the list of Ministry of Agriculture facilities (Clause 4 of Decree No. 836)). However, the subordinate organization must be officially notified of its inclusion in the list in any case, because the countdown of the regulatory timelines for preparing the inspection and categorization act begins from that moment. If no such notification has been received, the organization is entitled to independently submit a request to the supervising government body for the information necessary to comply with facility security rules.

Peculiarities of Categorizing Transport Infrastructure Facilities

Anti-terrorism protection of transport infrastructure facilities (the "OTI") has several peculiarities. Unlike ordinary buildings and structures, almost all transport facilities are conditionally divided into two groups: categorized facilities and facilities not subject to categorization (Article 6 of the Law on Transport Security). Security requirements for categorized and non-categorized OTI are different and even established in different regulatory documents. For example:

For categorized OTI of road transport — Decree of the Russian Government No. 1642 dated October 8, 2020, On the Approval of Requirements for Ensuring Transport Security, Including Requirements for the Anti-terrorism Protection of Facilities (Territories), Taking into Account Security Levels for Various Categories of Road Transport Infrastructure Facilities, and for road transport OTI not subject to categorization — Decree of the Russian Government No. 1639 dated October 8, 2020, On the Approval of Requirements for Ensuring Transport Security, Including Requirements for the Anti-terrorism Protection of Facilities (Territories), Taking into Account Security Levels for Road Transport Infrastructure Facilities Not Subject to Categorization;
For categorized OTI of sea and river transport — Decree of the Russian Government No. 1638 dated October 8, 2020, On the Approval of Requirements for Ensuring Transport Security, Including Requirements for the Anti-terrorism Protection of Facilities (Territories), Taking into Account Security Levels for Various Categories of Sea and River Transport Infrastructure Facilities, and for sea and river OTI not subject to categorization — Decree of the Russian Government No. 1651 dated October 10, 2020, On the Approval of Requirements for Ensuring Transport Security, Including Requirements for the Anti-terrorism Protection of Facilities (Territories), Taking into Account Security Levels for Sea and River Transport Infrastructure Facilities Not Subject to Categorization;
For categorized air transport facilities — Decree of the Russian Government No. 731 dated April 21, 2022, On the Approval of Requirements for Ensuring Transport Security, Taking into Account Security Levels for Air Transport Vehicles, and the Recognition as Expired of Decree of the Government of the Russian Federation No. 1604 dated October 5, 2020, and for non-categorized air transport facilities — Decree of the Russian Government No. 2090 dated November 29, 2021, On the Approval of Requirements for Ensuring Transport Security, Including Requirements for the Anti-terrorism Protection of Facilities (Territories), Taking into Account Security Levels for Air Transport Infrastructure Facilities Not Subject to Categorization, and the Recognition as Expired of Decree of the Government of the Russian Federation No. 1603 dated October 5, 2020;
For categorized railway infrastructure facilities — Decree of the Russian Government No. 1633 dated October 8, 2020, On the Approval of Requirements for Ensuring Transport Security, Including Requirements for the Anti-terrorism Protection of Facilities (Territories), Taking into Account Security Levels for Various Categories of Railway Transport Infrastructure Facilities, and for non-categorized railway OTI — Decree of the Russian Government No. 1635 dated October 8, 2020, On the Approval of Requirements for Ensuring Transport Security, Including Requirements for the Anti-terrorism Protection of Facilities (Territories), Taking into Account Security Levels for Railway Transport Infrastructure Facilities Not Subject to Categorization.

Despite the variety of transport types, the criteria for OTI categorization are established in a single document — Order of the Ministry of Transport of Russia No. 358 dated September 7, 2020, On the Procedure for Establishing Categorization Criteria for Transport Infrastructure Facilities (the "Order No. 358"). Quantitative indicators in two risk directions are used to assign a category (Clause 3 of Order No. 358):

The degree of threat of unlawful interference in OTI activities, calculated based on statistical data regarding facts of such interference over the last 12 months;
The potential number of dead or injured people, as well as possible material damage to the facility.

Categorization criteria have been developed for five types of transport (Appendices No. 1–5 to Order No. 358):

For road and road infrastructure facilities;
For air transport OTI;
For railway transport OTI;
For sea and river transport OTI;
For off-street transport OTI (the metro).

Lists of facilities not subject to categorization have also been approved for each type of transport in Order of the Ministry of Transport of Russia No. 331 dated August 28, 2020, On Defining Transport Infrastructure Facilities Not Subject to Categorization by Types of Transport.

The procedure for assigning a category for OTI is established in Decree of the Russian Government No. 1595 dated October 3, 2020, On the Approval of Rules for Categorization and Establishing the Number of Categories for Transport Infrastructure Facilities (the "Decree No. 1595"), and it differs from the standard categorization process for ordinary industrial and departmental facilities. The standard procedure involves the creation of a commission formed for a specific facility, which inspects it and issues a categorization act. A somewhat different procedure applies to transport facilities (Clause 9 of Decree No. 1595):

The OTI right holder (the "applicant") submits a categorization application to the authorized body responsible for ensuring transport security in that transport industry. Such bodies are the federal agencies of the corresponding transport industry, for example, the Federal Road Agency ("Rosavtodor"), the Federal Agency for Railway Transport ("Roszheldor"), the Federal Agency for Air Transport ("Rosaviatsia"), and the Federal Agency for Maritime and River Transport ("Rosmorrechflot");
The application is submitted in paper form; electronic submission is allowed only if both parties (i.e., the applicant and the authorized body) have such technical capability (Clause 10 of Decree No. 1595). Special methodological recommendations for preparing the application may be issued for a particular transport industry;[6]
In addition to information about the right holder, the application must specify information about the facility and its quantitative categorization criteria, taking into account Order No. 358 and the specific nature of the transport type;
The authorized body considers the application and verifies the information, making additional requests to the right holder if necessary;
After verifying all data, the authorized body assigns the OTI category and notifies the applicant within 30 days from the application submission date;
If a category has already been assigned but its indicators and criteria have changed, the right holder must immediately submit an application to change the previously assigned category (Clause 13 of Decree No. 1595).

Peculiarities of Categorizing TEK Facilities

Like other facilities, TEK facilities are subject to categorization to develop correct security measures (Article 5 of the Law on TEK Security). However, the procedure for assigning a category to such facilities (as with transport facilities) differs from the standard one. Categorization rules for TEK facilities are established in Decree of the Russian Government No. 459 dated May 5, 2012, On the Approval of the Regulation on Initial Data for Conducting the Categorization of a Fuel and Energy Complex Facility, the Procedure for Conducting It, and Categorization Criteria (the "Decree No. 459").

The classification of emergencies established in Decree No. 304 serves as the criterion for categorizing TEK facilities: local, municipal, inter-municipal, regional, interregional, and federal, depending on the potential number of victims and the size of material damage.

There are 3 danger categories for TEK facilities (Article 5(2) of the Law on TEK Security, Clause 4 of Decree No. 459):

Low category: if a terrorist act would cause a municipal emergency;
Medium category: if a terrorist act would cause an inter-municipal or regional emergency;
High category: if a terrorist act would cause an interregional or federal emergency.

The following must be present in the commission for the categorization of a TEK facility:

The head of the facility;
Representatives of the Ministry of Energy of the Russian Federation;
Representatives of Rosgvardia;
Representatives of the executive bodies of the constituent entity of the Russian Federation or local self-government;
Employees of the security service and the sensitive/classified department (if one exists);
Employees responsible for civil defense issues (the "GOChS");
Specialists responsible for technological equipment, industrial and fire safety, technical safety and information protection, as well as employees controlling the accounting of hazardous substances and materials at the facility.

Representatives of various specialized organizations may be engaged to inspect such a facility.

The following issues must be analyzed during the categorization process of a TEK facility (Article 5(1) of the Law on TEK Security, Clause 2 of Decree No. 459):

Initial information about the facility: its location, number of employees (including day and night shifts), the specific nature of neighboring locations, the presence of hazardous substances at the facility, and other factors and circumstances important for security;
The status of the TEK facility from a security perspective: critically important or potentially dangerous;
The scale of risks resulting from a terrorist act or other interference;
Critical elements of the facility (these may include, for example, structural and technological elements of the building, hazardous energy units or equipment, storage locations for hazardous substances, or engineering communications). A potential risk assessment must be conducted for each element separately (Clause 17 of Decree No. 459);
Potentially dangerous areas of the facility;
Types of threats and intruder models regarding the facility;
Situational plans of the facility and its engineering communications, technical documentation for buildings, structures, and premises, an action plan for localizing and eliminating the consequences of accidents at the facility, project documentation for the facility, and an industrial safety declaration.

Following the inspection, the commission prepares an act and assigns the corresponding category to the TEK facility, taking into account all identified risk factors.

Facility Safety Passport

A safety passport reflects the level of protection of a facility and contains a list of anti-terrorism measures. [7] Requirements for its development and preparation are regulated under the same principle as the categorization rules — in decrees of the Russian Government separately for each industry or department (Article 5(2)(4) of the Law No. 35-FZ). These rules may vary regarding the composition of persons who prepare and approve the passport, the coordination procedure, and the standard forms of the passport. However, any safety passport must contain information (Clause 8 of Decree No. 1244) regarding:

The facility itself (line of activity, category, name of the right holder, total area);
Employees and (or) tenants;
Potentially dangerous areas and critical elements of the facility;
Risks related to the commission of a terrorist act and an assessment of possible consequences (number of victims, infrastructure damage, material damage);
Measures and methods for ensuring the anti-terrorism protection of the facility (including engineering-technical protection, physical protection, and fire safety);
Conclusions and recommendations;
Other additional information.

The safety passport is prepared after the inspection and the assignment of a category; the categorization act serves as the basis for the passport. The standard deadline for preparing the passport is 30 days from the inspection date, but there are exceptions. For example, for hotels, the passport is developed within 3 months (Clause 37 of Decree No. 447).

The passport, like the inspection act, is classified as information of limited access marked "for official use", while the passport of trade facilities is also endowed with the status of a commercial secret. In exceptional cases, the passport may be assigned a secrecy classification.

Generally, the same authorized persons who participated in the inspection and categorization commission of the facility coordinate the safety passport. The timelines allotted for such coordination may vary: for example, 30 days from the preparation date for trade facilities (Clause 21 of Decree No. 1273) and 20 days for hotels (Clause 41 of Decree No. 447). For mass stay places and facilities protected by Rosgvardia, a multi-stage passport coordination procedure is provided: 10 working days for initial consideration, the same for revision, and 7 working days for approval (Clause 15 of the Requirements for the Anti-terrorism Protection of Places of Mass Stay of People and Clause 16 of the Requirements for the Anti-terrorism Protection of Facilities (Territories) Subject to Mandatory Protection by the National Guard Troops of the Russian Federation to Decree No. 272).

A prepared and approved passport is not an immutable document; it is subject to periodic updates. Specific timelines and grounds for updating are established for facilities in each industry. For example, a trade facility passport must be updated (Clause 25 of Decree No. 1273):

If the main purpose of the facility has changed;
If the area and boundaries of the facility have changed;
If the methods and means of facility protection have changed.

The safety passport of mass stay facilities is reviewed at least once every 3 years. Unscheduled updates are necessary (Clause 19 of the Requirements for the Anti-terrorism Protection of Places of Mass Stay of People to Decree No. 272):

If the purpose and significance of the facility have changed;
Upon changing its boundaries and area;
If the degree of threat of a terrorist act has changed;
If another facility (evidently, a capital construction project) has been erected within the boundaries of the facility itself or nearby.

The passport of facilities protected by Rosgvardia is updated at least once every 3 years (Clause 19 of the Requirements for the Anti-terrorism Protection of Facilities (Territories) Subject to Mandatory Protection by the National Guard Troops of the Russian Federation to Decree No. 272). Unscheduled passport updates are necessary:

If the main type of facility activity has changed;
If its total area and perimeter have changed;
Upon a change in the number of potentially dangerous areas and critical elements;
If the degree of threat of a terrorist act (regarding this facility) has changed;
If the conditions for organizing facility security have changed;
If the conditions for engineering-technical protection have changed.

The safety passport of hotels is updated by default once every 5 years, and an unscheduled change is introduced in the following cases (Clause 43 of Decree No. 447):

If regulatory requirements for the anti-terrorism protection of the population and hotels have changed;
If the crime situation of the given locality or region has changed;
If the development of the hotel territory has changed or its reconstruction was carried out;
After installing new modern technical means of control and protection;
Upon a change in the hotel owner, name, or organizational-legal form;
Upon a change in the officials specified in the hotel safety passport (including if their personal or contact data have changed).

If a safety passport was approved before March 13, 2022, and there are no formal grounds for its update, the right holder is not obliged to introduce changes to it. However, this exception applies only to certain industries and departments (sports and healthcare facilities, cultural facilities, hotels and trade facilities, children's health camps, as well as facilities under the jurisdiction of the Ministry of Science and Higher Education and the Ministry of Education of the Russian Federation).

Liability for Violation of Facility Protection Rules

Administrative and criminal liability is provided for non-compliance with facility protection requirements.

Article 20.35(1) of the Code of Administrative Offenses of the Russian Federation (the "CAO RF") establishes general administrative liability for non-compliance with anti-terrorism facility protection measures, as well as for creating obstacles to the implementation of such measures:

For individuals — a fine ranging from 3,000 to 5,000 rubles;
For officials — a fine from 30,000 to 50,000 rubles or disqualification for a term from 6 months to three years;
For legal entities — a fine from 100,000 to 500,000 rubles.

Regarding facilities of religious organizations, the punishment is slightly reduced: the fine for legal entities ranges from 50,000 to 100,000 rubles, and officials are not subject to disqualification (Article 20.35(2) of the CAO RF).

Sanctions for violating the security conditions of TEK facilities are established in a separate article of the CAO RF (Article 20.30 of the CAO RF), and the punishment depends on the facility's danger category:

For facilities with a low danger category: for individuals — a fine from 3,000 to 5,000 rubles; for officials — from 30,000 to 50,000 rubles or disqualification for a term from 6 months to 1 year; for legal entities—a fine from 50,000 to 100,000 rubles;
For facilities with a medium danger category: for individuals — a fine from 5,000 to 10,000 rubles; for officials—from 50,000 to 70,000 rubles or disqualification for a term from 1 year to 3 years; for legal entities—a fine from 100,000 to 300,000 rubles;
For facilities with a high danger category: for individuals — a fine from 10,000 to 15,000 rubles; for officials — from 70,000 to 100,000 rubles or disqualification for a term from 1 year to 3 years; for legal entities — a fine from 150,000 to 450,000 rubles.

Violation of requirements in the sphere of transport security is also set out in a separate article of the CAO RF, but the punishment depends not on the facility category but on the degree of guilt — meaning factors of intent or negligence are considered (Article 11.15.1 of the CAO RF):

If the act is committed by negligence: individuals face a fine from 3,000 to 5,000 rubles, officials — from 20,000 to 30,000 rubles, individual entrepreneurs — from 30,000 to 50,000 rubles, and legal entities — from 50,000 to 100,000 rubles;
For the repeated commission of a wrongful act that was first committed by negligence, a fine is provided for individuals from 5,000 to 10,000 rubles, for officials — from 30,000 to 50,000 rubles, for individual entrepreneurs — from 50,000 to 70,000 rubles, and for legal entities — from 100,000 to 200,000 rubles. Instead of a fine, an alternative punishment may be applied to legal entities and entrepreneurs: suspension of activity for up to 90 days;
If intent was present in the violation, a more severe punishment applies: a fine for individuals from 20,000 to 30,000 rubles, for officials — from 50,000 to 100,000 rubles, for individual entrepreneurs — from 100,000 to 150,000 rubles, and for legal entities — from 200,000 to 500,000 rubles. Furthermore, the tools or objects used by the violator may be confiscated. Instead of a fine, an alternative punishment may be applied to individuals: administrative arrest for a term of up to 10 days. For legal entities and entrepreneurs, there is also an alternative: suspension of activity for up to 90 days.

Criminal liability in the sphere of facility protection is differentiated by the same principle as administrative liability: different articles of the Criminal Code of the Russian Federation (the "UK RF") are provided for transport facilities, TEK facilities, and other facilities.

As of July 1, 2024, a new rule — Article 217.3 — was introduced into the UK RF, which is dedicated to violations of anti-terrorism requirements for any facilities except for OTI and TEK. A person is held liable under this article only if they have previously been subjected to administrative punishment within the CAO RF for a similar violation two or more times within 180 days. If a criminal act under Article 217.3 of the UK RF is committed by negligence, the person is still subject to liability.

The punishment depends on the severity of the consequences:

If severe harm is caused to human health or damage exceeds 1 million rubles: a fine up to 80,000 rubles (or in the amount of the convict's income for a period up to 6 months) or restriction of liberty for a term up to 3 years. Additionally, the criminal may be deprived of liberty for a term up to 3 years with a ban on holding certain positions or engaging in certain activities for a term up to 3 years;
If the violation caused the death of one person: deprivation of liberty for a term up to 5 years with the deprivation of the right to hold certain positions or engage in certain activities for a term up to 3 years;
If the violation caused the death of two or more people: deprivation of liberty for a term up to 7 years with the deprivation of the right to hold certain positions or engage in certain activities for a term up to 3 years.

Crimes against security rules of transport facilities are established in Article 217.1 of the UK RF. This rule is identical to Article 217.3 of the UK RF in its composition and structure; the principle of classifying punishments and measures of criminal liability coincide. The difference lies only in the industrial affiliation of the facility and the fact that under Article 217.3 of the UK RF, the violator is held liable only after the repeated application of administrative punishment to them, whereas this is not required for crimes in the transport sphere.

For non-compliance with security rules at TEK facilities, liability arises under Article 263.1 of the UK RF:

If severe harm is caused to human health or damage exceeds 1 million rubles: a fine up to 80,000 rubles (or in the amount of the convict's income for a period up to 6 months) or restriction of liberty for a term up to 1 year;
If the crime is committed by a person responsible for ensuring transport security (an employee or a unit) and severe harm is caused to human health or damage exceeds 1 million rubles, the criminal faces restriction of liberty for a term up to 4 years, or forced labor for a term up to 5 years with the deprivation of the right to hold certain positions or engage in certain activities for a term up to 3 years, or deprivation of liberty for a term up to 5 years;
If the specified violations are committed by a group of persons by prior conspiracy or caused the death of one person: forced labor for a term up to 5 years or deprivation of liberty for a term up to 7 years. Additionally, the criminal may be deprived of the right to hold certain positions or engage in certain activities for a term up to 3 years;
If the specified violations were committed by an organized group or the consequences led to the death of two or more persons: deprivation of liberty for a term from 5 to 8 years with a fine up to 1 million rubles (or in the amount of the convict's income for a period up to 3 years) with the deprivation of the right to hold certain positions or engage in certain activities for a term up to 3 years.

Final Conclusions

In the current political situation, compliance with anti-terrorism protection acquires special significance. Facility security rules are established at the federal level and differentiated depending on the facility's purpose and its industrial and departmental affiliation.
However, the general mechanism for developing a protection regime is identical for all types of facilities. The first step is the creation of a commission that conducts a facility inspection and assigns it a danger category. Categorization depends on risk factors and the potential scale of a terrorist act's consequences at that facility: the forecasted number of victims and potential material damage. In transport infrastructure, only certain groups of facilities are categorized.
Based on the inspection results, the commission prepares an act recording the assigned category and providing instructions and recommendations on necessary security measures. On the basis of this act, a facility safety passport — the most significant security document containing the list of anti-terrorism measures for a specific facility — must be prepared. The passport is subject to regular updates and is also updated in the event of changes to the facility's essential parameters (e.g., its purpose) or risk factors.
The timelines for the commission's work and its composition, the procedure for coordinating and approving the categorization act, the classification of categories, and the rules for developing the safety passport vary: for each industry, ministry, or department, a separate regulation is established, which is fixed in decrees of the Russian Government and may be detailed at the regional or municipal level. The protection regime for transport infrastructure and TEK facilities is set out in separate groups of regulatory acts.
Favorable rules apply to certain industries: if a safety passport was approved or the facility had already undergone categorization by March 13, 2022 (and there are no grounds for updating the passport or changing the category), the facility owner is not obliged to introduce changes to such a passport or repeatedly assign a category.
In some ministries and departments, lists of categorized facilities are formed. In this case, the anti-terrorism security regime established at the federal level (inspection act, category assignment) applies to the facility only after its inclusion in the said list. If a subordinate facility is absent from the list, the facility head has no formal grounds for fulfilling industrial anti-terrorism requirements; in such a situation, it is advisable to submit a request for clarification to the supervising government body.

References

[1] https://ria.ru/20250222/prestuplenie-2000941369.html.

[2]https://www.rbc.ru/politics/13/07/2025/687153669a7947a67e3030a3?ysclid=mdsqd1i9bf319768857.

[3] Decree of the Russian Government No. 289 dated March 5, 2022, On Amending Certain Acts of the Government of the Russian Federation in the Sphere of Ensuring the Anti-terrorism Protection of Facilities (Territories).

[4] Order of the Ministry of Regional Development of Russia No. 320 dated July 5, 2011, On the Approval of the Code of Rules "Ensuring the Anti-terrorism Protection of Buildings and Structures. General Design Requirements".

[5] Directive of the Russian Government No. 928-r dated May 15, 2017, On the List of Facilities Subject to Mandatory Protection by the National Guard Troops of the Russian Federation.

[6] Order of Roszheldor No. AI-143-r dated February 27, 2025, On the Approval of Methodological Recommendations for Preparing the Application of a Transport Infrastructure Subject and Providing Information for Categorization and Maintenance of the Register of Transport Infrastructure Facilities and Transport Vehicles, "Methodological Recommendations for Preparing and Filling Out the Application for Categorization of Air Transport Infrastructure Facilities" (approved by Rosaviatsia on October 13, 2022).

[7] Clause 43 of GOST R 70620-2022. National Standard of the Russian Federation. Anti-terrorism Protection. Terms and Definitions (approved and enacted by Order of Rosstandart No. 1721-st dated December 29, 2022).