The customer has the right not to place in the unified information system (UIS) data on purchases on the Law N 223-FL which are carried out after January 1, 2012 based on the framework agreement signed earlier.
Conclusion of the Ministry of Economic Development is based on regulations of the Civil Code of the Russian Federation that acts of the civil legislation have no retroactive force and are applied to the relations which have arisen after entering of acts in action (if other is not provided by the law). The law N 223-FL has come into force on January 1, 2012, except for separate provisions.
Document: The letter of the Ministry of Economic Development of the Russian Federation from 3/29/2016 N D28i-775