
Inserting Contracts into ChatGPT Risks Major Fines Under Russia's 152-FZ Personal Data Law
A detailed analysis examines the legal consequences of uploading contracts containing personal data into foreign AI services such as ChatGPT under Russian Federal Law 152-FZ. The article clarifies that even standard supply agreements include names, positions, passport details, INN numbers, phones and emails that qualify as personal data. It breaks down applicable administrative penalties from Article 13.11 of the Code of Administrative Offenses, including 150-300 thousand rubles for processing without a proper legal basis and separate fines for failing to notify Roskomnadzor. Cross-border transfer rules under Article 12 require a dedicated notification to the regulator before sending data to services hosted in the United States or European Union. The piece also reviews recent court practice, including a Moscow district court ruling that treated uploading commercial information to DeepSeek as disclosure of trade secrets. No criminal liability under Article 272.1 of the Criminal Code applies to ordinary business use, yet the absence of a data processing agreement with OpenAI or similar providers creates ongoing compliance exposure.
HabrSep 16, 2026Translated from Russian


