"Friendly" shareholders of Cypriot Rusagro ADR's can apply for direct ownership in the Russian Rusagro entity until the end of 2026

For various Russian companies the shareholder rights of the western holding company were suspended under the ESO-law (ESO is an acronym for Economically Significant Organization; the relevant law is Federal Law No. 470-FZ of 04.08.2023 "On the Specifics of Regulation of Corporate Relations in Business Entities That Are Economically Significant Organizations").

Normally shareholders in the western holding then have a 3 to 4 month period to apply to receive shares in the Russian entity. For Rusagro this period ended on the 28th of December 2024.

In July 2025 new amendments to Federal Law No. 470-FZ were adopted. The newly introduced parts 20-22 of article 7 now allows for Russians and investors from jurisdictions friendly to Russia to apply for shares in the Economically Significant Organization until the end of the suspension of corporate rights of the western holding company. This is mandatory for Russians.

Rusagro requested the Moscow court to extend this period until the 31st of December 2026 (see the request of the 18th of November 2025; https://kad.arbitr.ru/Card/ba4ee5c8-64e4-47b3-8734-183da7d7dae0), which was granted on 11th of December 2025. Hence Russians and shareholders from countries friendly to Russia can now apply until the 31st of December 2026 for shares in the Russian entity of Rusagro, even if they missed the initial deadline.

Shareholders from jurisdictions unfriendly to Russia have the opportunity to transfer the right to receive shares in Rusagro Russia to a Russian person / entity that can then claim this right until the end of December 2026.

More information and the necessary forms can be found on the website of Rusagro: https://www.rusagrogroup.ru/en/investors/news-events/press-releases/single-view/article/1421/

It will be interesting to see if other companies will ask for an extension of this period. Many Evraz PLC shareholders missed the deadline for the share distribution in Evraz NTMK (Evraz Russia).