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SNILS in assembly meetings: new requirements and risks

From 1 March 2025, GIS ZhKH publication of HOA meeting resolutions interacts with new SNILS-related rules. How the law reads and what it means for managers and owners.

SNILS is the insurance number of an individual personal account assigned to each citizen by the Social Fund of Russia (SFR). It has 11 digits and is assigned once. It does not change even if documents are lost or the name changes. SNILS is used for pension contributions and for registering on Gosuslugi and agency websites to file applications and receive e-services.

Previously SNILS appeared on a green plastic card — the insurance certificate. Today SNILS has no physical carrier; it is enough to know the number shown in the ADI-REG notice.

The ADI-REG notice is an electronic document confirming registration with the SFR. It states SNILS, full name, sex, date and place of birth. A paper copy can be obtained at an SFR office or MFC.

Federal Law No. 463-FZ of 13.12.2024 amended the Housing Code to require the administrator of a general meeting of owners in an apartment building, when holding absentee voting using a system, to enter SNILS in that system.

Thus, from 1 March 2025, amendments to the Housing Code (Art. 47.1) take effect requiring SNILS to be indicated when publishing resolutions in GIS ZhKH.

That does not mean SNILS must appear on the ballot itself.

Minstroy Order No. 79/pr of 07.02.2024 (on GIS ZhKH) states that to publish a scan of a resolution in GIS ZhKH, SNILS must be entered in GIS ZhKH — not on the scan.

Therefore one can no longer upload all resolution scans as a single attachment to the minutes, because there is no technical way to tie SNILS to each owner in that workflow.

Consequently, uploads will need to be one resolution — one scan per owner (similar to online voting).

What could be the consequences of these requirements?

  • Where to get SNILS? Management companies and HOAs may not know how to obtain the data. Many owners will refuse to provide it.
  • Paralysis of self-government in apartment buildings. Excessive formalism and impossible requirements will make general meetings very hard to run.
  • Even fewer proactive owners. The already small active core may shrink further.
  • Personal data leakage risks. How will information be protected? How will resolutions bearing SNILS be disposed of? Clear answers are still missing.
  • The goal is noble — curbing forged meeting minutes. But at what cost? Could meetings become impossible in practice?

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