The USN and the director are below the minimum wage: The Federal Tax Service confirmed zero contributions and the cancellation of the RSV
Starting in 2026, a monthly minimum base for insurance premiums equal to the federal minimum wage has been introduced for heads of commercial organizations.: if the director's monthly fees are less than the minimum wage or there are none, the base is still considered "as the minimum wage". At the same time, the existence of an employment contract and the fact of money transfers do not matter — the rule is tied to the very fact of exercising the powers of the sole executive body.
For many dormant companies and small businesses, this came as an unpleasant surprise: technically, you can not operate, but insurance premiums for the director still arise. In practice, this is especially sensitive for small imports and foreign economic activity structures that hold a legal entity "under contract" or seasonal supplies: during the months of pause, the accounting department risks incurring a contribution obligation simply because of the director's status.
But the AWS mode has a key exception in terms of the total amount. The letter from the Federal Tax Service emphasized that commercial organizations have no obligation to submit RSV to the Federal Tax Service, and the insurance premium rate itself is set at 0.0% during the period of application of the Federal Tax Service. Therefore, even if the base for the director is "tightened" to the minimum wage automatically, the amount to be accrued and paid remains zero.
The key wording of the Federal Tax Service, which removes the dispute:
"Accordingly, regardless of the size of the base for calculating insurance premiums for taxpayers applying the insurance policy, the amount of calculated insurance premiums is determined at the rate of "0"."
What does this mean for business in practice?:
- if you are on the ACC and the director is charged 0 or below the minimum wage, you do not need to pay "up to the minimum wage" in contributions — the result is still zero.;
- RSV is not required to be taken precisely because of the ACN regime (this is separately stated in the letter);
- It is important not to confuse the modes: on "regular" systems (without the right to a reduced tariff), minimum contributions can become a regular payment, and ignoring it increases the risk of claims and additional charges during desk inspections.
