"BUKA" has prepared comments on the law regulating the Russian gaming industry

Recently, "Buka" presented a list of amendments and recommendations to the bill "On the Activities Related to the Development and Distribution of Video Games on the Territory of the Russian Federation," which was submitted for consideration to the State Duma on December 12 by a group of deputies and senators led by Anton Gorelkin. App2Top's editorial team discussed with Alexander Tebuev, CEO of "Buka," why the company prepared comments and whether they will be considered by the legislators.

Disclaimer: On January 28, the Association of Video Game Operating and Development Professionals (APRIORI) held a discussion on the bill. It involved more than 30 representatives from the video game industry. During the meeting, it was noted that until February 5, comments on the bill could be submitted for legislators to consider. As Tebuev mentioned, "Buka" was among those who expressed a desire to draft them. 

Alexander Semyonov, App2Top: Am I right in understanding that the proposed comments are the result of the industry's participants meeting with APRIORI?

Alexander Tebuev, "Buka": Not exactly. The bill was discussed at the meeting. The organizers stated that there is currently an opportunity to provide our comments to the legislators, but it needs to be done promptly before their next meeting, which was scheduled for February 5.

Comments were encouraged from all attendees, emphasizing the importance of making them, if only to show that the industry cares, that it is alive, flourishing, and wants to actively participate in discussions.

"Buka" committed to definitely providing comments and amendments by the specified deadline, which we did.

In other words, the comments were drafted in connection with the meeting but are not its result or a reflection of other participants' opinions. The opportunity to submit comments was (and remains) available to all meeting participants.

We, in turn, are grateful to APRIORI and personally to Alexander Mikheev for the opportunity to discuss the bill and directly submit comments to the lawmakers.

What do you see as the main goal of the feedback on the proposed document by officials?

Alexander: Our main goal is to ensure that the adopted law benefits the domestic video game industry and does not harm it. To do this, we tried to identify and highlight the bill's weaknesses and unaddressed factors that could negatively impact the industry. We hope this will influence the legislators to revise the bill while considering the industry's opinions and interests.

Additionally, we wanted to draw the attention of industry participants themselves to the issue, encourage more developers and distributors, and possibly users (the players themselves) to study the bill and voice their opinions.

"Buka" submitted approximately 30 comments to the bill. Can you highlight the key points?

Alexander: The comments are crafted as specific proposals for amendments to certain sections, with notes on why we believe the amendments are correct. If we summarize everything, we are asking:

• Not to vilify or demonize video games, not to equate them with alcohol and gambling. Video games are modern art, a sport, not a harmful habit;
• Not to prohibit or complicate the work of foreign services with Russian users, developers, distributors;
• To consider international experience when introducing new requirements.

If elaborated, we believe adopting the bill in its current form will lead to significant problems and could even harm the domestic video game industry.

The bill, as it currently stands, will not allow Russian users and developers to use foreign platforms, forcing them to use domestic ones, with mandatory authorization not on the game servers but on state services or the same Russian platforms, which will only deter most users.

Some formulations in the bill may give the impression that the legislator has a biased negative attitude towards video games, which, as we know from the President's Orders and general rhetoric, as well as actual government actions, is not the case. This means these aspects in the law also need to be changed to reflect the state's real, positive attitude towards video games. Currently, the first articles of the bill are taken from the law on gambling and speak not of support and assistance, but of restrictions and control.

All of this could lead to user attrition, revive (or rather amplify) the black market, which, although it exists, does not significantly impact the industry thanks to our efforts and the work of foreign services (notably Steam and GOG).

We propose to change this and prevent such an outcome.

A major mistake would be to assume that a user deprived by the bill of their library in Steam (that is, the collection of games acquired over many years) and the ability to legally purchase games of interest would seamlessly transition to potentially less interesting projects on a domestic service.

Domestic developers, in turn, would lose a substantial portion of potential profits without access to sell their games on international platforms — leading to either bankruptcy or relocation. This would be highly undesirable, as our developers are currently gaining considerable recognition in the global community; they and their games are valued, receive awards, and earn well.

Moreover, while larger companies might try to recoup development costs through funds and grants, smaller studios would find it extremely challenging. There are too many legal and accounting complexities, and sometimes meeting sales/download requirements can be very difficult. Guaranteeing the popularity of a particular game is difficult, almost impossible for a new game from young developers, especially in an unknown setting. Investing only in well-known titles, as has become popular recently in the West, means burying talents, which contradicts the stated governmental policy.

Considering communication with other market participants, can it be said that your comments reflect the general position of the Russian gaming industry on the bill?

Alexander: I wouldn't want to speak for everyone, so I suggest discussing only the facts.

Our comments represent "Buka's" position. As I've said above, industry participants have the opportunity to propose their amendments to the bill themselves.
In response to the publication of our comments, we received quite a lot of supportive feedback and some criticism. We took that into account and submitted our comments to be forwarded to the lawmakers within the agreed deadlines from the meeting.

Some of our colleagues have also begun not only discussing but creating amendments themselves, for which we are very grateful. We hope that publishing our comments will motivate even more industry participants to voice their ideas and opinions. As we mentioned earlier, one of the goals of publishing the comments was to highlight the bill, attract the attention of video game industry participants, motivate them to take it seriously and actively express their position.

Should we expect all proposed changes to be adopted?

Alexander: No, that is not to be expected. Of course, we would be very pleased but also very surprised if that happened. However, the main goal is to point out the shortcomings and possible negative consequences of adopting the bill in its current form, and to show that the industry cares.

Therefore, we rely on our comments to highlight the problems in the bill, hoping it will be revised considering these and other comments and amendments from industry participants.

Moreover, besides the amendments themselves, the comments also contain questions about industry support measures. We wrote that the best support is the absence of obstacles, suggesting not to adopt the bill or to revise and postpone its implementation until a better time. Although we understand that this is unlikely, we wanted to highlight that the industry already faces challenges it is dealing with. Any changes should facilitate the lives of developers, users, distributors, and publishers, rather than complicate them.

For instance, the Federal Law No. 330-FZ of August 8, 2024, "On the Development of Creative (Artistic) Industries in the Russian Federation" is now coming into effect, aimed at supporting creative activities, including video game development. Additionally, there was recent news confirming the possibility of using the patent tax system for computer clubs in Moscow. All of these are excellent examples of state support and development for the video game industry.