The timeframe has been changed for filing the SZV-TD form

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Resolution No. 460 of the Russian Government dated 8 April 2020 “On approving the Temporary rules for the registration of individuals for the purposes of searching for suitable employment and as unemployed, and for paying social benefits to individuals properly registered as unemployed” has changed the timeframe for filing the SZV-TD form when an employee is dismissed or hired. Now this form must be filed not later than on the next business day after the corresponding order has been issued. This rule has come into effect on 9 April 2020.

This also gives rise to the question of whether the Government has the powers required to establish such a special procedure for submitting information which is inconsistent with the procedure established by article 11 of Federal Law no. 27-FZ dated 1 April 1996 “On individual (personified) record-keeping in the compulsory pension insurance system”.

In order to answer this question, we should turn to draft law No. 941251-7 “On amending articles 2 and 11 of the Federal Law “On individual (personified) record-keeping in the compulsory pension insurance system” which has passed its first reading in the State Duma (the lower chamber of Russia's parliament) on 14 April 2020. According to this draft law, the Russian Government will be granted powers to “establish specific aspects of the procedure and timeframes for policyholders to submit information on employment activities of registered persons to regional bodies of the Russian Pension Fund until 31 December 2020 (inclusive)”. In addition, such powers will be granted to the Government retrospectively, starting from 1 April 2020.

What to think about and what to do

Employers need to take the new requirements into account and ensure that the reports are filed on time, which may be difficult in the conditions of remote working. 

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