Temporary external administration decree (Russia, 2023)

Russian Presidential Decree No. 302 of 25 April 2023 created a temporary management framework for specified assets connected with persons from states Russia treats as unfriendly. The decree remains in force and amended. It is a countermeasure within Economic statecraft, but temporary management is not automatically a transfer of legal title.

Framework

The decree authorises temporary management when defined triggers are met and identifies assets through annexes and later amendments. The state appoints or identifies a manager with powers over operation and voting or governance specified by the instrument. Ownership, management, voting control, dividend treatment and a later sale are separate legal questions.

The framework relates to Counter-sanctions asset seizure but should not be described uniformly as confiscation. The text and the company-specific annex determine what was placed under management. A later transaction or transfer requires its own instrument.

Amendments through 2026

The official publication record and search chronology show repeated changes to the annexes. Decrees No. 1011 and No. 1012, published on 13 January 2026, amended the framework's company-specific application. Amendments continued after those instruments. Decree No. 492 of 13 July 2026 made further changes to Decree No. 302's company-specific application. These official publications establish that an entry was added, changed or removed as stated; they do not establish a company's valuation or final loss.

As at 30 July 2026, the decree remained part of the current legal architecture, with the official publication chronology current through the 13 July 2026 amendment. Every company claim must identify the operative annex on the relevant date. The status should be refreshed on publication day.

Actors and related measures

The President issues the decree and amendments. Government bodies and named managers implement them. The affected company, shareholder, local subsidiary, creditor and prospective buyer have different legal positions. The Unfriendly states list (Russia, 2022) supplies a related classification but does not itself place an asset under temporary management.

Corporate accounts require entity-level precision. A foreign parent may hold shares in a Russian company while the decree addresses those shares, the subsidiary's governance or another asset. Describing the whole multinational group as seized can therefore overstate the instrument. The named legal entity, asset and annex entry should be reported.

The regime also differs from Federal Law 127-FZ on counter-sanctions (Russia, 2018) and from insolvency, criminal forfeiture or ordinary corporate administration. Corporate withdrawal and private self-sanctioning in Russia (2022-2023) describes private adaptation, not the same public authority.

Attribution and effects

Russian official instruments describe temporary management and stated policy aims. Companies and foreign governments have characterised some applications as expropriatory. Those are attributed legal positions. A claim that title transferred, an asset was sold or a loss crystallised needs the later instrument, transaction record or adjudication.

The mechanism can preserve operations, gain control and create bargaining leverage. Its effect depends on the asset, manager and later disposition. The decree proves the authority asserted, not that every named foreign investor was permanently dispossessed.

A manager's operational decision is not automatically a presidential act. Attribution should follow the actor and document responsible for each step.

Sources

• Russian Presidential Decree No. 302, 25 April 2023.
• Official publication search and amendment chronology, accessed 30 July 2026.
• Russian Presidential Decree No. 1011 amendment, 13 January 2026.
• Russian Presidential Decree No. 1012 amendment, 13 January 2026.
• Russian Presidential Decree No. 492 amendment, 13 July 2026.