Ministry of Transport Order No. 389 dated August 31, 2026 supplements the list previously approved by Order No. 115 dated April 3, 2026. Both documents are the result of amendments introduced by Federal Law No. 140—FZ of June 7, 2025 to the Law on freight forwarding Activities of June 30, 2003 No. 87-FZ.
Starting from September 1, 2026, forwarding documents are generated electronically and sent to the state information system of electronic transportation documents. At the same time, the law gave the Ministry of Transport the right to determine exceptions — cases when paper remains acceptable. April Order No. 115 fixed the initial list of such cases. The new order adds another position to it.
Now the paper form is directly allowed for the provision of freight forwarding services related to the transportation of military and dual-use products in foreign trade, in accordance with the legislation on military—technical cooperation and export control. The change will take effect on October 11, 2026.
For exporters operating in this segment, the amendment eliminates legal uncertainty: prior to its adoption, carriers and forwarders were formally required to switch to EDI, even under sensitive military-technical contracts, where digital data transmission to government systems could conflict with the export control regime. Paper processing retains the usual documentary chain and does not require integration with GIS of electronic shipping documents for such shipments.
Freight forwarders handling mixed cargo flows, some of which are subject to export control and some not, will need to differentiate document flow by cargo category. Shipments that are not related to military or dual-use products are still processed electronically and transferred to the system in a standard manner.
Related materials:
- The mandatory EDI in transportation starts today: checklist - from which general rule is an exception made
- Electronic invoices in logistics: fines will begin only in March 2027, when paper documents will be fined.
- A machine—readable power of attorney will be simplified: one form instead of a set - how to issue credentials for electronic documents to the forwarder
