Russian Licenses for Narcotic and Psychotropic Substance Circulation Now Take 8 Working Days, Down From 15
Eight working days. That is precisely how much time the licensing authority now has to decide on issuing a license for the circulation of narcotic drugs (NS) and psychotropic substances (PV). For the applicant, this means preparation with no room for a pause: by the time the application is filed, the safes must already be in place, the alarm system tested, and staff cleared.
Previously, this decision took 15 working days, and part of that time was effectively spent fixing minor deficiencies found after the initial assessment. Today, that buffer is almost gone. Non-compliance on the day of the onsite assessment will, with a high degree of probability, result in a denial, and a new application means starting the waiting cycle all over again.
How NS and PV Licensing Worked Until September 2024
The procedure for licensing the circulation of NS and PV is set out in Decree of the Government of the Russian Federation No. 1007 dated June 2, 2022, «On Licensing Activities Related to the Circulation of Narcotic Drugs, Psychotropic Substances and Their Precursors, and the Cultivation of Narcotic Plants» (hereinafter, Decree No. 1007). Until September 1, 2024, the licensing authority made its decision on granting a license within 15 working days. Amending the register of licenses, for instance when adding a new address or a new type of work, took up to 10 working days.
The general law on licensing, Federal Law No. 99-FZ dated May 4, 2011, «On Licensing Certain Types of Activities» (hereinafter, Law No. 99-FZ), sets a maximum term of 45 working days for most licensed activities. The industry-specific regulation on NS and PV licensing had already shortened this term in the past. The current reduction to eight days is more drastic than any previous step.
Applications could previously be filed on paper, and inspectors almost always conducted the onsite assessment in person. That left a buffer for fixing shortcomings. The procedure as a whole tended to stretch out for weeks.
Licensing Deadlines Cut to Eight and Six Working Days
Since September 1, 2024, a new version of Decree No. 1007 has applied, approved by Decree of the Government of the Russian Federation No. 1736 dated October 18, 2023 (hereinafter, Decree No. 1736). The applicant now files the application for a license and the application for amending the register exclusively through the Gosuslugi (State Services) portal, in electronic form.
| Parameter | Before (until Sept 1, 2024) | Now (from Sept 1, 2024) |
|---|---|---|
| Decision on issuing a license | 15 working days | 8 working days |
| Amending the register | 10 working days | 6 working days |
| Method of filing | Gosuslugi or paper workflow | Gosuslugi only, electronic form |
| Format of the onsite assessment | Typically in person | Remote by default, via video link |
For applicants planning to operate in Closed Administrative-Territorial Formations (ZATOs), the current term for both the licensing decision and register amendments is longer than average: 20 working days. The additional vetting by security agencies simply does not fit into an eight-day cycle.
The eight- and six-day terms were set by Decree No. 1736 itself back in 2023, ten months before the separate federal law on this subject appeared. Even then, the general licensing law allowed the standard term to be shortened by an industry-specific regulation, and the drafters of Decree No. 1736 used exactly that option.
Later, in 2024, Federal Law No. 310-FZ dated August 8, 2024, «On Amending the Federal Law ‘On Licensing Certain Types of Activities’ and Certain Legislative Acts of the Russian Federation» (hereinafter, Law No. 310-FZ), was adopted. It fine-tuned the procedure at the level of the general licensing rules that apply to all licensed activities, including the circulation of NS and PV. Part of Law No. 310-FZ took effect on February 5, 2025. From that date, the licensing authority provides the applicant with information on a specific license exclusively as an electronic document bearing an enhanced qualified electronic signature; it no longer issues paper extracts. The licensing authority sends the notice of the onsite assessment and the assessment report to the applicant’s personal account on Gosuslugi, and it must notify the applicant of the assessment report within one working day of the report being finalized.
The same law added a separate ten-day review term for cases where a licensee terminates activity at one of its addresses or gives up part of the work or services previously covered by the license.
By default, the onsite assessment of compliance with licensing requirements is now conducted remotely, using audio and video communication. This rule is already built into the current version of Decree No. 1007. An in-person visit by the inspector remains mandatory only when a new operating address is being added to the register.
Law No. 310-FZ also added a safeguard for applicants to the general licensing law. If the licensing authority fails to meet the set deadline, it must notify the applicant of the denial or the decision no later than three working days after that deadline expires. Separately, the law allows the licensing regulation for a specific activity to provide for an automated compliance assessment, based on data already held in state information systems, without an inspector’s involvement. For the circulation of NS and PV, that regime has not been introduced yet. The provision already lays the groundwork for further cuts to the deadlines.
Faster deadlines do not remove the requirements for storage infrastructure. Decree of the Government of the Russian Federation No. 809 dated April 30, 2022, «On the Storage of Narcotic Drugs, Psychotropic Substances and Their Precursors» (hereinafter, Decree No. 809), still divides premises into categories, while the special storage conditions for narcotic and psychotropic medicinal products are set by Order of the Ministry of Health of Russia No. 1103n dated November 26, 2021, in effect until March 1, 2028. Facility security requirements are set by the joint Order of Rosgvardia No. 335 and the Ministry of Internal Affairs (MVD) of Russia No. 677 dated September 15, 2021. If even one of these elements is not ready on the day of the onsite assessment, the eight-day term becomes a problem for the applicant: there is simply no time left to fix the gap before the assessment ends.
What to Do
Finish the facility’s technical preparation before filing the application. The premises, safes, alarm system, and the contract with the security company must fully meet the storage category under Decree No. 809 and the requirements of the joint Rosgvardia/MVD Order No. 335/677, before the application goes in through Gosuslugi. With an eight-day term, there is no fixing a gap once the assessment has started.
Check your staffing. Make sure the management team includes a specialist with additional professional training in NS and PV circulation, and that the records of their diploma and certificate are current in the state registers. A missing qualification record is one of the most common grounds for denial.
Get an enhanced qualified electronic signature and verify the head of the organization’s personal account on Gosuslugi as a legal-entity account. Every notice, including the onsite assessment report, arrives there, and a missed message can cost several working days.
Prepare for a remote onsite assessment. Check that audio and video communication works at the facility, and mention it in the application for amending the register if this applies to your case. An in-person inspector visit is only required when adding a new address.
Plan for the longer ZATO term. If the facility is in a Closed Administrative-Territorial Formation, plan the filing around a 20-working-day term, and arrange the inspector’s site access in advance.
The eight-day licensing cycle for NS and PV reflects a broader trend of recent years. The state is cutting procedural deadlines while shifting the burden of preparation onto the applicant. There is almost no room left for error. For organizations that close their technical and staffing gaps in advance, the reform saves weeks of waiting. For those counting on finishing the facility after filing, it leaves only a denial and a new cycle from scratch.
Regulatory Framework:
1. Joint Order of Rosgvardia No. 335 and the Ministry of Internal Affairs (MVD) of Russia No. 677 dated September 15, 2021
2. Decree of the Government of the Russian Federation No. 1007 dated June 2, 2022, «On Licensing Activities Related to the Circulation of Narcotic Drugs, Psychotropic Substances and Their Precursors, and the Cultivation of Narcotic Plants» (as amended June 13, 2024)
3. Decree of the Government of the Russian Federation No. 1736 dated October 18, 2023, «On Amending the Regulation on Licensing Activities Related to the Circulation of Narcotic Drugs, Psychotropic Substances and Their Precursors, and the Cultivation of Narcotic Plants»
4. Federal Law No. 310-FZ dated August 8, 2024, «On Amending the Federal Law ‘On Licensing Certain Types of Activities’ and Certain Legislative Acts of the Russian Federation»
5. Federal Law No. 99-FZ dated May 4, 2011, «On Licensing Certain Types of Activities»
6. Federal Law No. 3-FZ dated January 8, 1998, «On Narcotic Drugs and Psychotropic Substances»
7. Decree of the Government of the Russian Federation No. 809 dated April 30, 2022, «On the Storage of Narcotic Drugs, Psychotropic Substances and Their Precursors»
8. Order of the Ministry of Health of Russia No. 1103n dated November 26, 2021, «On Approving Special Requirements for the Storage Conditions of Narcotic and Psychotropic Medicinal Products Intended for Medical Use»