New rules for SMEs: what has changed in the procurement of medicines and medical products

26 May 2025, Monday

On May 23, 2025, the Government of the Russian Federation adopted Resolution No. 708, which significantly changes the approach to the fulfillment by customers of the mandatory share of purchases from small businesses (SMEs) and socially oriented NGOs (SONOS). Now, a number of purchase categories are not included in the calculation of the total annual purchase volume (CBOF), from which the standard is calculated.

Which purchases are excluded from the calculation of the SGOZ:

- Purchases for space activities conducted by Roscosmos and organizations of the rocket and space industry.

- Narcotic and psychotropic drugs, as well as their precursors, subject to state control.

- Medicines, if the annual volume of purchases of such drugs from the customer is 20 million rubles or more.

- Medical products with a similar threshold of 20 million rubles per year.

These changes relate not only to Law No. 44-FZ, but also to accounting documents, including Resolutions No. 1352 and No. 238. Reporting forms have also been updated and duplicate data has been eliminated.

How will this affect the NSR:

Although the decree does not prohibit the purchase of medicines or medical products from the NSR, in reality, the motivation of customers is sharply reduced. As previously explained by the Ministry of Finance in a letter dated 04.10.2022 No. 24-06-07/95478, exclusion from the calculation does not mean a ban, however, during the period of similar regulations in 2022-2023, there was a sharp drop in the share of such purchases from SMEs.

In fact, government customers will now be able to comply with the procurement standard from the NSR at the expense of other categories, and large purchases of medicine, defense and pharmaceuticals will be carried out in the "neutral zone" without risking violating the quota.

What is important for a business to know:

- Formally, the participation of the NSR in the procurement of medicines and medical products remains possible.

- In practice, the share of such purchases from the "kids" may decrease, especially in large government agencies.

- Suppliers will have to reorient themselves either to other procurement segments, or to strengthen their competitive advantages.

Separately according to 223-FZ:

Similar exceptions have been introduced for purchases under 223-FZ. Purchases of narcotic drugs and their precursors are excluded from the calculation of the total value, even if they are concluded with the NSR.

Result:

Resolution No. 708 is an audit of procurement statistics: the government makes life easier for customers, but indirectly narrows the market for small businesses in the "medical" field. Customers get more freedom, and SMEs get fewer guarantees of participation in high—budget purchases.

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