GOOGLE LLC AND OTHERS v. RUSSIA - 37027/22 (Article 10 - Freedom of expression - {general} : Third Section) [2025] ECHR 170 (08 July 2025)

Executive summary

The European Court of Human Rights held that Russia violated Article 10, and also found Article 6 § 1 problems, in proceedings where Russian authorities imposed large fines on Google companies for refusing take-down requests and for suspending a Russian television channel’s YouTube account. The Court found the fines and enforcement measures were disproportionate, lacked adequate judicial scrutiny, and exerted pressure to censor content, including political speech and reporting on Russia’s invasion of Ukraine.

Key points

• Applicants were four Google companies, including Google LLC, Google Russia, Google International LLC, and Google Ireland Limited.
• Article 10: substantial fines for failing to remove YouTube content were not 'necessary in a democratic society' and had a chilling effect.
• The impugned takedown demands covered political opposition, criticism of the Russian government, war reporting, and LGBTQ-support content.
• The Court stressed the domestic courts did not assess truthfulness, risk, reach, or harm of the content before penalizing Google.
• A second Article 10 finding concerned penalties for not restoring a TV channel’s YouTube account; the suspension was linked to sanctions on the channel owner for support of Crimea annexation, and the enforcement was found manifestly disproportionate and conducted in bad faith.
• Article 6 § 1: the courts failed to justify aggregating revenue across multiple entities, failed to address objections on separate legal personality, and gave inadequate reasons on jurisdiction and enforcement.

Why it matters

The judgment frames platform takedown enforcement as a sanctions-adjacent coercive tool when linked to content about war, sanctions, annexation, and politically sensitive expression. For sovereign-risk and compliance analysis, it signals that large penalty regimes and enforcement tactics can be scrutinized as disproportionate state pressure on cross-border tech operators.

Implications

For compliance and litigation strategy, the decision supports challenges to broad, revenue-based fines, especially where domestic authorities aggregate affiliate revenues without clear legal basis or individualized reasoning. It also strengthens arguments that platform moderation disputes tied to sanctioned persons, war reporting, or political expression require careful proportionality analysis and robust judicial review before penalties can be enforced.