Mystery purchase, updated regulations

Law , useful information , mystery purchase , inspection

Since December, 1st, 2018, the new Rules have taken effect for arranging and conducting the mystery purchase under certain types of State control (supervision) approved by the RF Government Degree № 1398, of November, 21st, 2018.


The key update to the Rules of the mystery purchase is the fact that from now on it can be held off-site, via the Internet, thus, similar inspection is now applied to online shops also.

The Rules state that the mystery purchase is only conducted under the condition no other way of control is possible. The Rule Book is valid for both offline and online shops. In case an offline shop is subject to inspection, the inspector is obliged to report on his or her actions to the shop’s representative right after having taken them, return the purchased item (with only several cases in exclusion) and draw up a record within 3 hours after the purchase took place.

In case an online shop is to be inspected, and the mystery purchase was made remotely, the record is drawn up right after the purchase is made, while the fact of the mystery purchase is announced via sending the copies of the decree and the record to the legal entity or the sole proprietor whose establishment has been subject to control, no later than the day following that of the mystery purchase.

The record of the mystery purchase must be accompanied by some documents to prove the fact of acquisition of goods (work or services), including the receipts and other forms of strict accountability equivalent to cash vouchers.

In case your shop has been object to such revision, it is necessary for you to study all the papers you are given, as well as the following crucial points:
– sufficient basis for such the inspection to be conducted;
– whether the inspector is authorized and has got the corresponding position;
– make sure the witnesses are not at least interested in the purchase’ outcome (whether they are relatives or employees of the state control organization, its subordinate, or rival agents).

Unless these requirements are complied with, or you’ve got remarks on any of the points listed above, you can argue the record and avoid troubles related to the inspection.

The text contains extracts from the Decree published on the Official Internet Legal Advice portal, and the evidence from the following websites:,,,