Starting September 1, 2026, the Russian agro-industrial complex will enter the phase of mandatory use of electronic shipping documents (EPDs).
However, large-scale digitalization of logistics risks causing serious financial disruption for the industry.
The largest industry associations in the food sector have appealed to the Ministry of Transport and the Federal Tax Service (FTS) to protect businesses from fiscal and administrative risks during the transition period.
Fines are not the main problem
Earlier, the Ministry of Transport proposed a moratorium on harsh sanctions: until March 1, 2027, traffic police and Rostransnadzor inspectors will be limited to verbal warnings for drivers without EPDs if they present a paper equivalent.
However, businesses consider this measure insufficient. The main blow may come not from the traffic police, but from the tax authorities.
Since Federal Law No. 140 makes electronic format strictly mandatory, paper documents prepared «the old way» will effectively lose their legitimacy starting this fall.
Farmers are rightly concerned that regional tax inspectorates will refuse to recognize such invoices as proof of expenses. This will entail massive additional income tax assessments, denial of VAT deductions, and large fines that will far exceed any administrative fines for violating transportation regulations.
Agency Position: Compromise with Reservations
The reaction of the relevant ministries was mixed.
The Ministry of Transport took a hard line regarding infrastructure: the agency refused to expand the list of cases for the legal use of paper freight forwarding documents, declaring that this contradicts the goals of the reform.
Even multimodal transportation will not be an exception.
Regarding the relaxations, the ministry is preparing a memo in case of failures in the GIS EPD and is working on launching an online information system for reporting the system’s status.
The Federal Tax Service, for its part, attempted to reassure the market. The agency clarified that a paper document alone will not automatically trigger sanctions.
The main condition is that the taxpayer must prove the objective impossibility of generating an electronic document (for example, due to technical failures). Tax authorities will continue to evaluate the validity of transactions based on a combination of factors.
However, it’s too early to rejoice: the FTS letter is informational only, is not a regulatory act, and does not guarantee that local inspectors will not interpret the law literally.
Digital Unreadiness
The root of the problem lies in the critically low readiness of counterparties.
According to the Soyuzmoloko union, only 20-25% of dairy companies’ logistics partners are currently capable of working with the GIS EPD.
The situation is even more complex for small and medium-sized businesses—unlike large holdings, they lack the resources to quickly fine-tune their IT architecture.
Earlier, businesses requested that the reform for the agro-industrial complex be postponed until 2028, citing the software’s incompleteness and the lack of integration with accounting, but the authorities opted for accelerated implementation.
The coming months will reveal whether the transition to electronic payment documents will drive transparency or become an additional tax on the market’s digital immaturity. Agribusinesses urgently need to accelerate the audit of their carriers, and regulators need to formalize compromise rules of the game legally, not just verbally.
