Agora’s analysts have drawn attention to the poor drafting of the document: “A strategy for legal regulation at this level must necessarily comprise as detailed an implementation plan as possible, including benchmarks, deadlines and the allocation of roles and responsibilities to participants.”

The lawyers recall that Russia, as a member of the Shanghai Cooperation Organisation, is party to the 2009 Agreement on Cooperation in the Field of Ensuring International Information Security, which defines a major threat as the dissemination of information which, "distorts the notion of the political system, the structure of society, external and internal politics, important political and social processes in government, and the spiritual, moral and cultural values of its people." They note that while the German court regards access to the internet as a basic need, V Kontakte blocks opposition groups in Belarus, and Tajikistan completely blocks access to Facebook.