[ncc-services-wg] Issues with the legal entities from the Russian Federation

Hello,

Our company have been a RIPE NCC member for almost 1 year and a few days ago we applied for an additional LIR account, but got a strange request from the RIPE NCC's Customer Services representative that can't be legally fulfilled and that shows that there are errors or inaccuracies in the internal guidelines or documentation regarding the legal entities from the Russian Federation that I would like to clarify.

On 12.09.2016 the Federal Tax Service of the Russian Federation issued the order No. MMB-7-14/481@ "On approval of the form and content of the document confirming the fact of making an entry in the Unified State Register of Legal Entities..." (official copy offered by the Ministry of Justice: https://minjust.consultant.ru/documents/20942).

According to this document the Federal Tax Service has replaced an official company formation confirmation document known as Certificate of state registration (in Russian: "Свидетельство о государственной регистрации") with a new document called Record list (in Russian: "Лист записи") and stopped to issue the Certificates for all the companies incorporated after 01.01.2017. At the same time electronic company formation became very popular in the past few years that means a lot of the companies now have their incorporation documents only in digital format. 

Thus, at this moment we have at least the following 4 types of the documents for the Russian companies that are valid to verify that it is exist and registered as it is required by the RIPE-700 document:

1. Certificate of state registration with a stamp and signature of the Federal Tax Service for the companies registered before 01.01.2017
2. Certificate of state registration with a digital signature of the Federal Tax Service for the companies registered electronically before 01.01.2017
3. Record list with a stamp and signature of the Federal Tax Service for the companies registered after 01.01.2017
4. Record list with a digital signature of the Federal Tax Service for the companies registered electronically after 01.01.2017

But according to our current communication, the RIPE NCC is aware of only the first type of document and requires us (a company incorporated after 01.01.2017) to provide it (and that's simply impossible). Moreover, all the Russian companies can be also freely validated and verified online using the Public Business Register offered by the Federal Tax Service (https://egrul.nalog.ru/index.html) and this extract can also be used as a company existence confirmation. 

So, I would like to ask the RIPE NCC to check the mentioned document and update the internal policies on the Russian entities in accordance with the modern realities.

Regards,
Boris Lomov