Germany’s Federal Office for Economic Affairs and Export Control (BAFA) has officially extended General License No. 42 until 31 March 2027, offering much-needed legal certainty for cross-border legal, tax, accounting, and software-related services to Russian entities.
In addition, from 1 August 2025, individuals, companies and organizations from the “partner countries” listed in Annex VIII to Regulation (EU) No. 833/2014 — including the US, UK, Japan, South Korea, Australia, Canada, New Zealand, Norway, Switzerland, Liechtenstein, and Iceland — can also rely on BAFA’s General License No. 42. This applies only to the software categories in Annex XXXIX (e.g., ERP, CRM, BI, CAD, CAM, BIM, ATM etc.) and only when the software is supplied from within Germany.
What Is Covered?
The license applies to a wide range of non-sensitive business services, including:
Legal and tax advisory,
Accounting and auditing,
Provision of business-related software, including for the banking and financial sector (per updated Annex XXXIX of EU Regulation 833/2014).
The registration and reporting obligations for German-based firms still apply. Non-German firms should ensure they act strictly within the license scope and serve only eligible Russian recipients.
Practical Implications
This extension provides continuity for European businesses with Russian operations, especially those struggling to stay compliant after the previous exemptions expired. While there is no EU-wide license, Germany's pragmatic approach may serve as a model.
Solstico Legal and Managing Partner Alex Stolarsky, remain authorized to provide legal and tax services in Russia and Germany under the extended BAFA license. We will continue to monitor any regulatory changes affecting service provision.
Let us know if you need help assessing your compliance status or continuing cross-border services safely