SPIC 2.0 grants local product status. Here’s how manufacturers access Russian procurement without a tender
Three billion rubles in investments can turn a manufacturer into the sole supplier to the state. Not through a tender, not through an auction, and without competing on price with a dozen participants, but via a direct contract. The «local product» status under the Special Investment Contract version 2.0 (SPIC 2.0) locks out foreign competitors from a significant portion of the public and corporate procurement market while simultaneously opening a direct sales channel for the investor.
The mechanism rests on three parallel instruments: the right to enter into a contract without competitive bidding procedures, a price preference when comparing bids, and the automatic rejection of foreign proposals. For a regulatory manager choosing between localizing production or continuing imports, the difference between «included in the registry» and «not included» is measured in the volume of contracts that will remain accessible or inaccessible to the company for years to come.
How Companies Confirmed the Russian Origin of Goods Prior to 2025
Before the rules on national treatment were consolidated, preferences for domestic manufacturers were governed by a dozen scattered legal acts. The key among them was Order No. 126n of the Ministry of Finance dated 4 June 2018, which established the conditions for admitting foreign goods to procurement under Federal Law No. 44-FZ and divided products into two lists. For the first list, the preference amounted to 15% of the contract price; for the second (mostly specialized machinery and transport for national projects), it was 20%.
In parallel, the first version of SPIC was in effect. It required the investor to invest at least 750 million rubles and was not tied to a specific list of technologies. The customer and the investor negotiated terms individually, which stretched contract execution over months and made the outcome less predictable.
The Registry of Modern Technologies, mandatory for SPIC 2.0, appeared later, in late 2020. The Government approved it by Directive No. 3143-r dated 28 November 2020, listing 630 technologies across 15 industrial sectors. Since then, the list has been expanded by government directives several times a year, including in November 2023, July 2025, and November 2025. For an applicant, this created a need to re-verify every time whether their technology fit into the current version of the list.
The point-based system for confirming localization under Decree No. 719 of 17 July 2015 already existed at the time. It did not apply to all product categories. For many goods, Russian origin status was confirmed simply by the fact of knock-down assembly within the country, without requirements regarding the depth of component localization.
The rules governing prohibitions, restrictions, and preferences for procurement under 44-FZ and 223-FZ were regulated by more than twenty separate government decrees, adopted in different years for different industries: separately for medical devices, separately for software, and separately for radioelectronics. Customers had to check the applicability of several documents at once for a single procurement, while a manufacturer aiming for local product status found it difficult to assess the aggregate effect of all measures combined.
Three Market Access Instruments Following the Consolidation of Rules
The legal foundation of SPIC 2.0 is Chapter 2.1 of Federal Law No. 488-FZ dated 31 December 2014, «On Industrial Policy in the Russian Federation» (Articles 18.1-18.6, introduced in 2019). The contract is concluded in relation to a technology from the approved list. The list is set by Directive No. 3143-r in its current edition; the duration of a SPIC can reach up to 15 years for investments up to 50 billion rubles, and up to 20 years for investments exceeding that amount.
Direct access to procurement is granted by Article 111.3 of Law No. 44-FZ dated 5 April 2013, «On the Contract System.» A customer has the right to execute a contract with a sole supplier under Clause 47 of Part 1 of Article 93 of the Law if the investment under the SPIC exceeds 3 billion rubles (or 750 million rubles for a manufacturer listed in the consolidated registry of defense-industrial complex organizations). The Russian legal entity must manufacture the goods within the territory of the country, and their origin must be officially recognized as Russian. The law sets a limitation: the total volume of supplies under such a contract during a calendar year must not exceed 30% of the goods of that description produced by the company during the same period, provided the manufacturer is not included in the defense-industrial complex registry.
The second instrument, the price preference, operates through Government Decree No. 1875 dated 23 December 2024, «On Measures for Granting National Treatment.» This document consolidated previously scattered measures into a unified three-tier system. For goods in Annex No. 1 (151 positions), a complete ban on purchasing foreign products applies. For Annex No. 2 (about 465 positions), the «second one out» rule applies: if there is at least one bid offering Russian or Eurasian goods, all bids containing foreign products are rejected. For all other goods, a 15% price preference is applied: when comparing bids, the price of a Russian participant is reduced by a factor of 0.85, while the contract with the winner is concluded at their actual submitted price.
Calculation example: an importer offers goods for 1 million rubles, and a participant holding local product status offers them for 1.1 million rubles. For the purpose of comparing bids, the price of the second participant is evaluated as 935,000 rubles (1.1 million x 0.85). The participant with local product status wins. The contract itself is nonetheless concluded at the price of 1.1 million rubles specified in their bid.
Direct access under Clause 47 of Part 1 of Article 93 applies exclusively to procurements under 44-FZ, as sole-supplier status is tied to the contract system for state and municipal needs. The bans, restrictions, and preferences under Decree No. 1875 apply more broadly: the document explicitly covers procurement by state corporations, natural monopolies, and state-owned enterprise entities under Law No. 223-FZ dated 18 July 2011. For a regulatory manager, local product status works across two procurement markets simultaneously, regardless of where the SPIC itself was concluded.
The third instrument, the point-based localization system under Decree No. 719, determines the very eligibility to be recognized as a Russian manufacturer for the purposes of Annexes No. 1 and No. 2 to Decree No. 1875. Thresholds increase annually. Solid-state drives (SSDs) and RAM modules were first included in the radioelectronics section by Decree No. 45 dated 27 January 2026 (in addition to the amendments under No. 1997 dated 8 December 2025). For these items, the minimum threshold is set at 45 points from 2026, 60 points from 2028, and reaches 75 points for storage drives and 70 points for RAM from 2030. For gas-insulated switchgear units rated up to 35 kV, the threshold rises to 75 points from 2026, and for equipment over 35 kV, to 90 points.
| Parameter | Before (prior to 2025) | Now (2025-2026) |
|---|---|---|
| Legal basis for preferences | Scattered acts, primarily Ministry of Finance Order No. 126n | Unified system: 44-FZ Art. 111.3, Decree No. 1875 |
| List of technologies for SPIC | Approved in 2020, updated infrequently | Expanded several times a year; most recent amendment in November 2025 |
| Confirmation of localization | Fact of assembly within the country was often sufficient | Point-based system under Decree No. 719; thresholds rise through 2030 |
| Price preference | 15% or 20% under Order No. 126n | 15% under Decree No. 1875 (Art. 14 of 44-FZ, Art. 3.1-4 of 223-FZ) |
| Rejection of foreign bids | Applied selectively by specific categories | Unified «second one out» rule for 465 positions in Annex No. 2 |
Status registration takes place through the State Information System of Industry (GISP). The structure of submitted information and the procedure for maintaining the registry are established by Decree No. 1604 dated 21 December 2017. A manufacturer is obligated to submit an annual report to the Ministry of Industry and Trade by 1 April detailing the actual volume of products manufactured and shipped that are linked to the registry entry. For participants in SPIC 2.0, confirming inclusion in the registry is simplified: instead of annual acts from the Chamber of Commerce and Industry, a copy of the contract and reporting on the progress of technology implementation serve as the basis.
The verification procedure consists of two stages with different timelines. The expertise of the Chamber of Commerce and Industry (an assessment act or an ST-1 certificate of origin) takes from a few days with a complete document package to several months if an on-site facility audit is required. After obtaining the act, the application for inclusion in the Ministry of Industry and Trade registry is reviewed according to regulations within 10 to 30 business days, depending on the product category. The registry entry is valid for 3 years and requires renewal in advance, 3-4 months prior to expiration.
Law No. 44-FZ provides manufacturers with an extra incentive to expand into foreign markets. If, upon expiration of the SPIC, the company has exported at least 10% of the manufactured goods during a calendar year, the federal authority that executed the contract has the right to extend the sole-supplier procurement right for another year. This benefit operates without a new SPIC and without revising the maximum price ceiling previously fixed.
What Can Strip a Company of Its Status
Local product status is not granted permanently. Three scenarios can strip a manufacturer of it, even if production volumes are maintained.
Regulatory point inflation. Localization thresholds under Decree No. 719 rise according to a pre-established schedule: for SSDs, from 45 points in 2026 to 75 points in 2030. A company that met the passing score at the start but fails to increase its share of Russian components risks falling out of the registry during a planned threshold increase, without needing an audit or a competitor’s complaint to trigger it.
Termination of the SPIC. Clause 2 of Part 15 of Article 95 of Law No. 44-FZ obligates the customer to unilaterally terminate a contract with a sole supplier if the special investment contract itself is terminated. Reasons for termination can stem from breaches of investment obligations. These breaches are often unrelated to either the quality or the delivery timelines of the goods supplied under the current procurement contract.
Competition within the registry. The 15% price preference under Decree No. 1875 applies when comparing a Russian bid against a foreign one. If two manufacturers holding local product status participate in the same procurement, the preference neutralizes itself, and the customer selects the winner based on actual submitted price without applying any adjustment factors.
Action Plan
Verify the technology against the current list. Open Directive No. 3143-r in its latest revision on the GISP portal and ensure that the company’s technology is included in either the public or classified portion of the list. If the technology is missing, submit an application to update the list through the Ministry of Industry and Trade prior to applying for a SPIC.
Assess the investment threshold and choose the contract form. Accessing sole-supplier status requires an investment volume of 3 billion rubles or more (750 million rubles for entities in the defense-industrial complex registry). If the project is smaller, consider a regional SPIC without federal benefits under 44-FZ, or phase the accumulation of investments across several stages.
Assemble the document package for GISP. The legal block (contract copy, articles of association, Taxpayer Identification Number (INN)), technical block (technical specifications or regulations, project passport), production block (extract from the Unified State Register of Real Estate (EGRN) for the production site, staffing details), and reporting block (schedule plan, target production indicators) should be prepared in parallel. The average review period depends on the completeness of the package and product category.
Calculate localization points under Decree No. 719 three years ahead. For electronics and power equipment, the 2028 and 2030 thresholds are significantly higher than current ones. Ensure that Russian circuit boards, controllers, and design documentation provide a point buffer above future thresholds, not just current ones.
Set up annual reporting in GISP. Establish an internal deadline for report submission 30 days prior to 1 April, and assign a responsible manager to monitor changes to Annexes No. 1 and No. 2 of Decree No. 1875, as these lists are expanded several times a year.
Local product status does not replace capital investments in manufacturing with regulatory formality. It translates investments already made into a concrete competitive edge in procurement. That advantage itself requires continuous maintenance: localization points are verified annually, technology lists change, and a breach of SPIC terms leads to contract termination and loss of access to the procurement market for which the investments were made in the first place.
Regulatory Framework:
1. Government Directive No. 3143-r of 28 November 2020 (as amended), «On Approval of the List of Modern Technologies»
2. Federal Law No. 488-FZ of 31 December 2014, «On Industrial Policy in the Russian Federation» (Chapter 2.1, Articles 18.1-18.6)
3. Federal Law No. 44-FZ of 5 April 2013, «On the Contract System in the Sphere of Procurement of Goods, Works, and Services for State and Municipal Needs» (Article 111.3, Clause 47 of Part 1 of Article 93)
4. Federal Law No. 223-FZ of 18 July 2011, «On Procurement of Goods, Works, and Services by Certain Types of Legal Entities» (Article 3.1-4)
5. Government Decree No. 1875 of 23 December 2024, «On Measures for Granting National Treatment in Procurements of Goods, Works, and Services»
6. Government Decree No. 719 of 17 July 2015, «On Confirmation of the Production of Industrial Products on the Territory of the Russian Federation»
7. Government Decree No. 45 of 27 January 2026, «On Amendments to Decree of the Government of the Russian Federation No. 719 dated 17 July 2015»
8. Government Decree No. 1604 of 21 December 2017, «On Provision of Information by Entities Operating in the Field of Industry… for Inclusion in the State Information System of Industry»