The International Bar Association “Law Firm “Levant and Partners” reports on the Information Letter of the Bank of Russia dated March 30, 2016 No. IN-06-52/17 (published on 04/04/2016), which deals with the disclosure of annual reports by joint-stock companies for 2015.

The letter draws attention to the fact that on March 14, 2016, Bank of Russia Directive No. 3899-U dated December 16, 2015 “On amendments to Bank of Russia Regulation No. 454-P dated December 30, 2014 “On the disclosure of information by issuers of equity securities” came into force.

The annual accounting (financial) statements of joint-stock companies are disclosed, including by publishing its text on a page on the Internet information and telecommunications network provided by one of the information distributors on the securities market, no later than three days from the date of drawing up the auditor’s report, but no later than three days from the date of expiration of the deadline established by the legislation of the Russian Federation for the submission of a legal copy of the compiled annual accounting (financial) statements.

In accordance with Part 2 of Article 18 of the Federal Law dated December 6, 2011 No. 402-FZ “On Accounting,” a legal copy of the prepared annual accounting (financial) statements is submitted no later than three months after the end of the reporting period.

Thus, the annual accounting (financial) statements of a joint-stock company for 2015 are subject to publication by joint-stock companies on the Internet page along with the auditor’s report no later than 04/04/2016.

If it is justifiably impossible for a joint-stock company to comply with the requirement to disclose the annual accounting (financial) statements for 2015 together with the auditor’s report within the prescribed period (for example, due to the fact that the concluded contract for conducting a statutory audit provides for the submission of an audit report later than 04/04/2016), the joint-stock company should: