There are three months left until September 2026, and most companies have not yet started the transition. This is exactly what the situation looks like according to analysts of the Tochka Bank Transport EDO service.
Federal Law No. 140 established September 1, 2026 as the final date for all participants in cargo transportation: senders, carriers, forwarders, and recipients. Paper invoices will have no legal effect after this date.
What exactly turns into a number
Four types of documents fall under the mandatory transition. The bill of lading is the main document confirming the contract of carriage and the fact of cargo delivery. The order and the request for transportation are the primary documents when making the flight. Forwarding documents — instructions to the forwarder, forwarding receipt, warehouse receipt.
Railway and air transportation are also switching to electronic format: the railway bill of lading and the air freight bill of lading are included in the list of mandatory EPA.
Exceptions are provided for a number of specific types of cargo — the state will determine their list separately. But their share in the total volume of traffic will be insignificant.
Why it affects 95% of the business
Logistics companies are aware of the transition — they work with invoices on a daily basis. But the law applies to all participants in the chain. The manufacturer sending the goods to the buyer is obliged to sign the ETRN as the shipper. The retailer accepting the delivery acts as the recipient. This applies to almost any company with a physical turnover.
That is why the figure of 95% of businesses looks realistic: about 3,000 OKVED codes are somehow related to the movement of goods.
What needs to be done before September 1st
The minimum set of actions for each company is to obtain a qualified electronic signature (CAP) from a supervisor or employee by proxy (MCHD). Connect to an EDI operator that supports the ETRN format — their list is accredited by the Federal Tax Service. Update the internal regulations for working with transport documentation. Specify the procedure for exchanging electronic documents in contracts with counterparties.
For companies already working with 1C: connecting to the transport EDI via the built-in module takes from one to several business days.
The transition that has started now gives three months for real-time testing. The transition, which began in August, means the risk of stopping cargo transportation.
