Federal Tax Service Order No. ED-1-7/514@ of July 24, 2026 was registered with the Ministry of Justice on August 31, 2026 (No. 88065) and took effect on September 30, 2026 — one month after its official publication. The Tax Code amendments on reducing fines under Federal Law No. 425-FZ have been in force since September 1, 2026. The document set out a list of mitigating circumstances and established a clear relationship between their number and the size of the fine reduction.
The scale is as follows:
- one circumstance — the fine is halved;
- two — reduced four times;
- three — six times;
- four — eight times;
- with five or more mitigating circumstances, the penalty can be reduced by a maximum of ten times.
Before the order took effect, the application of mitigating circumstances was not formalised as a single scale, which left the outcome to the discretion of the inspector or the court.
Mitigating circumstances include: the insignificance of the violation or degree of guilt, voluntary cessation of the unlawful conduct, insignificant harm, its absence or elimination, compensation of damage to the budget, the difficult financial situation of a legal entity, and circumstances that positively characterise the taxpayer.
There is a lower limit to the reduction. After applying the scale, the final amount may not be less than 1,000 roubles for individuals, 3,000 roubles for entrepreneurs, non-profits and SMEs, and 10,000 roubles for other organisations. Each violation is considered separately: only circumstances directly related to it are taken into account.
For foreign trade participants, the new rules are especially relevant when a violation arose from objective difficulties: delayed payments from foreign counterparties, disruptions in supply chains, exchange rate fluctuations affecting the tax base. The difficult financial situation of a legal entity and the fact of voluntary elimination of the violation are two arguments that an importer or exporter can document and present to the tax authority.
In practice, this means that companies facing additional assessments get a predictable mechanism: collecting five or more documented grounds means a guaranteed claim to the maximum reduction. Before challenging a fine in court, it is worth checking how many mitigating circumstances can be recorded at the stage of reviewing the audit materials in the tax office itself.
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