The transition period is not a postponement. The difference is fundamental. Starting from September 1, 2026, freight forwarders and carriers are required to issue orders and instructions to the forwarder electronically via GIS EPD. If this does not happen, a violation is recorded. Just a sanction for a violation until March 2027 is only a verbal warning.
From March next year, the same violation will result in a fine. The size of the fines is still being discussed at the regulatory level.
It is important to understand this distinction correctly. It doesn't mean that you can do nothing for another eight months. Carriers that have not configured integration with GIS EPD by September 1 will receive accumulating comments — and move on to March with a history of violations, which increases the risks at the first check after the start of the penalty period.
At the same time, there is an unresolved technical issue from Avtogruzex: there is no mechanism for correcting documents in transit in the system. The absence of this tool means that even those who are technically connected to GIS EPD, in non—standard situations — route change, cargo redistribution - find themselves in a situation where the correct action in the system is simply not provided.
For shippers, forwarders and carriers who have not yet started implementation: you need to start now. The transition period gives you the right to make mistakes, not the right to delay.
