Clear criteria are also necessary to overcome

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Dmitry Burlakov believes that one of the main provisions of the import substitution concept is the definition of criteria for the presence or absence of domestic analogues of imported products. Anton Lensky agrees with him, also pointing out that clear wording is certainly important, as in any regulatory legal act. If there is no precise definition of what is considered a Russian analogue of a foreign IT product for conducting a critical information infrastructure audit, then there will be the possibility of various interpretations of the definition.

the risks pointed out by Andrey Volkov, head of the costa rica whatsapp data platform development department at Aladdin R.D.: “Here, a huge niche is emerging for all sorts of businessmen offering a ‘domestic’ product, but bearing virtually no costs for its creation and development. How much better will a ‘Russified’ Chinese third-tier router be than a Cisco or Juniper product? Is it fair to give preferences to a company that renames Linux or LibreOffice and is not even capable of providing high-quality support for its product? Where does the money that the state wanted to give to real domestic developers in the form of benefits and subsidies end up? I think that in this situation, both critical information infrastructure operators and domestic developers will only lose.”

But Nikita Shablykov believes that "there is a fairly clear definition of Russian software, it is fixed in the register of domestic software. I think it can be used as a guide."

Import Substitution for Critical Information Technologies Entities: How Russian Linguistic Technologies Reduce the Risk of Data Leaks
Critical information infrastructure (CII) entities may be required to switch to Russian software from January 1, 2021 — the corresponding bill was published at the end of May on the website of the Ministry of Communications. The document notes that this initiative will ensure the security and technological independence of information systems and networks, as well as automated control systems operating in healthcare and science, transport, communications, finance and energy, including nuclear energy, in the fuel and energy and defense industry complexes, in the mining, metallurgical and chemical industries.