For the last 5 years, construction sites of foreign companies in the regions had been opening without accreditation on the basis of the Order of the Ministry of Finance of the Russian Federation of 30.09.2010 N 117n «On approval of data on the state of products or agreements». In some regions, of course, tax officials groaned about lack of accreditation, but they agreed to register at last! So, turns out it is possible to open an establishment without accreditation, is not it?
An interesting point about this is that the same order provides for the submission of «documents confirming the accreditation of the Branch of a foreign organization on the territory of the Russian Federation», i.e. without accreditation to open an establishment of a foreign company is impossible. But inspections in the regions appear to have little practice of opening those establishments of foreign companies, and the requirement for accreditation documents to open an establishment can be interpreted as requiring a certificate of accreditation of an already opened branch / representative office. In other words, if there is an already accredited branch and it is necessary to open an establishment, you may try using a certificate of accreditation of the branch for this purpose.