The Federal Tax Service clarified its position on paper transportation documents: inspections will begin at the end of 2026

Ilya Prisyazhnyuk, Deputy Head of the Electronic Document Management Department of the Federal Tax Service of Russia, spoke at the EPD 2026 conference in Moscow on October 7 and clarified the department's position on paper transportation documents. The key thesis is that just the fact of making a document on paper will not become an independent basis for tax sanctions. The approach is comprehensive.

"The Federal Tax Service will still apply an integrated approach: just based on the fact that the document was issued on paper, the inspector is unlikely to make a decision to apply any negative tax sanctions," Prysyazhnyuk said, adding that the company is obliged to confirm the reason why the document was not issued electronically.

The main criteria for tax purposes are still the reality of transportation and payment of all taxes due. However, the absence of any attempts to switch to EDI, according to the representative of the Federal Tax Service, in itself will attract the attention of inspectors. The question of whether a paper document will be the basis for excluding transportation costs from the income tax base did not receive a definitive answer at the conference.

The practical consequences for carriers and cargo owners will be outlined by the turn of 2026-2027. "Everything will be shown by the beginning of next year — the end of this year, when the first "camerals" will be released and it will become clear how the tax system reacts to such behavior," said Prysyazhnyuk.

The Federal Tax Service has not yet published official written explanations on the use of paper transportation documents. This creates legal uncertainty for all participants in cargo transportation, including importers and exporters who work with Russian carriers.

A separate confusion is caused by the widespread misconception about deadlines. Part of the market expects to postpone the transition to EDI until March 1, 2027. Until this date, there is only a deferral for the application of fines for road freight transportation on a paper bill of lading — instead of a fine, an oral warning is issued. There is no transition period for the most mandatory EDI: Artem Yurenkov, Director of the Digital Development Department of the Ministry of Transport of the Russian Federation, explicitly confirmed this at the same conference.

From September 1, 2026, the electronic format is required for the railway waybill, air waybill, waybill and application, as well as all types of forwarding documents. Companies that continue to work with paper without justification should prepare a documented explanation of this practice before starting desk inspections.

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