ERP Systems May Be Considered Critical Information Infrastructure Objects: What This Means for Business

In Russia, the Ministry of Digital Development is debating an initiative to classify ERP systems as critical information infrastructure (CII). If adopted, the import substitution requirements will affect not only public but also private companies using foreign ERP solutions, such as SAP, Oracle, etc.

What is planned to change

• ERP systems are proposed to be classified as CII, as they directly impact business sustainability: finance, logistics, production, tax, and payroll calculations.
• The use of foreign ERP solutions for critical business processes may be limited or prohibited from 1 January 2028.
• Companies will have to migrate to local ERP platforms (e.g., 1C) or hybrid architectures to minimize risks.
• These requirements may affect large and medium-sized businesses, even those not in the public sector.

How this will impact companies

For business, this means not just a software upgrade, but a revision of the IT architecture and accounting processes:

• Companies using SAP / Oracle as their primary ERP may face the need for a planned or accelerated migration.
• The role of local accounting and reporting systems, primarily 1C, will increase.
• Accounting continuity, data accuracy, and compliance with auditor requirements will need to be ensured.
• Demand for hybrid solutions will increase, where a foreign system is temporarily retained for IFRS or management reporting, while operational and regulatory accounting is transferred to domestic platforms.

Important: even without formal CII status, risks associated with providing support, updates, and access to the vendor are already becoming a key factor in decision-making.