On 28 September Vladimir Putin signed decree No. 686, “On approving the list of information in the fuel and energy sector to which access is restricted, and the procedure for its use”. We read the decree and its annexed list in full in the official publication — three pages plus a two-page annex. It restricts four groups of data at once, from the details of a company's export shipments to the production volumes of individual refineries, and it took effect on the day of signing.
The four entries on the list
The first entry covers information about a legal entity's exports, item by item: the names and quantities of goods shipped out; their prices, including the average producer price of industrial goods meant for export; the sellers, buyers and everyone else involved — carriers, freight forwarders, insurers; the procedure for settlements under supply contracts; the vessels, container numbers and transport documents; the directions and routes of shipments, the sea terminals and their operators, the geographic coordinates of storage sites; the dates and times of operations; and the contents of customs documents.
The other three entries are shorter, and two show the level of aggregation the decree reaches:
“2. Aggregated information of customs statistics on the export of goods by a legal entity. 3. Information on the volumes of processing and production of goods by a legal entity — a Russian oil refinery.”
The list closes off not just individual transactions — who shipped what to whom, on which vessel — but also the company-level summary: its aggregated customs statistics. The fourth entry covers exchange trading: the planned sales volumes and the concluded deals, in the main trading sessions of each trading day, for high-octane petrol (RON 92 and above) and diesel produced from crude that a market-dominant company extracted or sold.
A ban on publication, with one exception
Point 3 of the decree sets the rules of use. It bars distribution of the listed information, “including with the use of mass media or information and telecommunications networks, including the Internet”. The one exception is information a legal entity discloses about its own activity. Everyone else gets the data only under an agreement with its owner, and state bodies exchange it under the procedures of Russian legislation. Information held in state information systems will be processed under a standard regulation that the government must approve.
The government has two tasks: within ten days it must define the list of commodity codes to which the decree applies; it must also approve that standard regulation. The decree names no sanction for violations — point 2 makes confidentiality compliance mandatory and refers to “necessary measures provided for by the legislation of the Russian Federation”, without naming them.
The same day, the gas payment workaround was extended by six months
Decree No. 686 was not the only decree Putin signed that day. Putin also signed decree No. 701 on 28 September. It replaces one date in point 7⁶ of decree No. 172 of 31 March 2022, the “gas for roubles” order: “Until 1 October 2026” becomes “Until 1 April 2027”. Under that point — we cite its text as published in the current ConsultantPlus version of decree No. 172 — a foreign buyer's payment for gas counts as duly made if the roubles arrive in an ordinary rouble account of the Russian supplier at any Russian credit organisation, outside the special “K” account mechanism introduced by the 2022 decree. The previous extension, decree No. 427 of 15 June, which we also read in the original, moved the same deadline by exactly one quarter, from 1 July to 1 October. This one moves it by six months — according to the amendment list in the ConsultantPlus version, the first extension of that length. The decree gives no reason for the longer extension. Both decrees were signed on the same day; no document connects them.
Why this is about the ability to pay for the war
Our oil and gas budget revenue indicator uses the finance ministry's monthly reporting, and decree No. 686 does not touch it: the ministry's numbers are the state's own accounting of the money it received. What the decree closes off is the external evidence against which those numbers could be checked — how much physically left the country, at what price, through which terminals, and how much the refineries actually processed. Our guide explains what the ministry's figure includes and what it cannot say; the decree further narrows what outsiders can check. When outsiders' view of the oil money narrows to the state's own accounting and whatever a company chooses to disclose about itself, a gap between the report and reality stops being visible — and a budget problem usually starts with exactly that gap.
What this changes in our model
Today — nothing. No number our indicators read has moved. Oil and gas budget revenues stand at 12 of 100: the twelve-month real total is at 56.1% of the 2021 level, with the registered trouble line at half of it. The decree does not change that number; it changes what can be used to verify it. The strength index stands at 47.1 of 100, in the stress zone; the current state of all eight indicators is on the monitor.
What we do not know
Which goods the decree covers. The list of commodity codes is the government's to define within ten days. Until it appears, the reach of the closure — oil and oil products alone, or coal and gas as well — is not defined.
What happens to published statistics. The decree addresses the owners of information and state bodies. Whether the composition of what Rosstat, the finance ministry or the customs service publish will change, its text does not say.
The boundary of the exception. A company may still disclose information “about its own activity”. Whether that covers an issuer's mandatory disclosures, the text does not establish.
Whether the two signatures are connected. Decree No. 686 closes settlement data on export contracts; decree No. 701, the same day, extends the workaround through which gas payments arrive. The coincidence of dates is a fact; a documented link is not.