FAS Commission Meeting on RNP: How to Prepare and Protect Your Business

Why is the FAS meeting the key point of the entire РНП story?

The Commission meeting on inclusion in the Register of Unfair Suppliers (RUS) is not a formality and not a “technical stage”.

Right here:

the final position of the regulator is being formed;
supplier behavior is evaluated;
a decision is made that is extremely difficult to reverse in court.

90% of the success or failure of the RNP is decided before and during the commission meeting.

1. What is the FAS Commission and what is its role?

The Commission is a collegial body of a territorial subdivision

Federal Antimonopoly Service, Commissioner:

evaluate the supplier's actions;
analyze customer materials;
make a decision on inclusion or exclusion from the register.

The Commission does not resolve the dispute between the parties, but acts in the logic of the public interest.

2. When and how is the commission meeting scheduled?

After receiving materials from the customer FAS:

initiates a case;
sets the date and time of the meeting;
sends a notification to the supplier.

Table 1. What is important to check immediately after receiving a notification

Parameter	Why is it critical
Date and time	Pass = loss of protection
Foundation of the RNP	Different strategy
Content of materials	Understanding the customer's position
Deadline for submitting explanations

Error: assume that the main event is the speech at the meeting.

In practice, the key is a written position before the meeting.

3. What the FAS Commission really evaluates

Table 2. Supplier Evaluation Criteria

Criteria	Meaning
Fact of violation	Formal base
Vendor behavior	Key element
Good faith	Defining feature
Documentation	Critical
Execution attempts	In favor of the supplier

Important:
Even if there is a violation, the commission may refuse to include if the behavior is considered to be in good faith.

4. Preparing a written position: the basis of defense

Table 3. What the supplier's position should contain

Block	Content
Actual part	Timeline of events
Vendor actions	Execution attempts
Causes of the violation	Objective circumstances
Documents	Confirmation of words
Legal assessment	Link to the approach of the Federal Antimonopoly Service and courts

❌ Error:
emotional emails, customer accusations, and general phrases.

5. Documents that strengthen your position at the commission

Table 4. Documentation of Good Faith

Document	Meaning
Correspondence with the customer	Key factor
Risk notifications	In favor of the supplier
Screenshots and logs	Confirmation of facts
Acts and emails	Commit actions
Settlement attempts	Plus to the position

Principle:
The Commission believes in documents, not explanations.

6. The supplier's behavior at the commission meeting

Table 5. How to behave and how not to behave

Behaviour	Evaluation
Calm, structured speech	✅
Reliance on documents	✅
Clear logic	✅
Emotions and pressure	❌
Conflict with the customer	❌
Missing position	❌

A meeting is not an argument, but a presentation of a position to the regulator.

7. Typical logic of the FAS Commission meeting

Scheme 1. How the decision is made

Report of materials

↓

Customer's position

↓

Supplier's position

↓

Commission questions

↓

Behavior assessment

↓

Solution (RNP / opt-out)

8. Why "going to court" is a weak strategy

Table 6. Common Misconceptions

Delusion	Reality
"The court will fix everything"	The court evaluates the FAS
FAS formalna	FAS analyzes behavior
"The main thing is to win the trial"	It is better not to get into the RNP
"This is a civil dispute"	This is a regulatory procedure

The strongest protection is the refusal to be included at the FAS stage.

9. Key business takeaway

Meeting of the FAS Commission:

the crucial moment;
managed process;
the point where strategy is more important than emotion.

👉 Companies that prepare in advance and professionally often avoid РНП even if they have violations.

How can YANG CONSULT

YANG CONSULT accompanies business:

when preparing a position for the FAS commission;
at RNP meetings;
in cooperation with the customer and the regulator;
at the subsequent appeal of decisions.

We build protection before making a decision, not after inclusion in the register.

Contacts: E-mail: info@yangconsult.com, Telegram: @info_YC

Business, government, GR, and judicial practice news — in our Telegram channel: https://t.me/yangconsult

2026-01-27 12:20