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On April 27, the Decree of the Russian Federation Government N 590  dated April 26, 2020 "On peculiarities of the procedure and terms for submission of Information on labour activity of registered persons by policyholders to the territorial bodies of the Russian Pension Fund" was published and came into force.

Thus, experts of Baker Tilly attract your attention that today on the 28th of April, it is necessary to send the information about the employees hired or dismissed from the 1st to 27th of April to the Pension Fund of Russian Federation.

Document review

The Resolution stipulates that the policyholder is obliged to submit to the territorial bodies of the FIU the information on the registered persons working with him/her in the following cases:

•recruitment and dismissal of a registered person from April 1, 2020 until the day on which this resolution enters into force - no later than the working day following the day on which this resolution enters into force; •transfer to another permanent job and the submission by the registered person of an application to continue to maintain a work record book in accordance with Article 66 of the Labour Code or to provide information on work in accordance with Article 66 of the Labour Code by the policyholder (electronically) - not later than the 15th day of the month following the month in which the transfer to another permanent job took place or the submission of the respective application;

•hiring and dismissal of a registered person - not later than on the working day following the day when the relevant order (instruction), other decisions or documents confirming the execution of the employment relationship are issued.

The resolution applies to legal relations arising from April 1, 2020 and is valid until December 31, 2020. (inclusive).

Baker Tilly expert’s comments

Thus, today on the 28th of April, it is necessary to send the information about the employees hired or dismissed from the 1st to 27th of April to the Pension Fund of Russian Federation.

We would like to remind you that earlier we adopted temporary rules for providing data in the form of NHV-TD for registering citizens as unemployed and making social payments (for more details - in our earlier review "SZV-TD: temporary procedure for providing data").

Despite the legal gaps Baker Tilly recommended that her clients submit to the FIU the information on the form SZV-TD (in case of personnel events: recruitment, dismissal), within the time limits established by the Provisional Rules.

Please note that the deadlines for submission of information established by the Provisional Rules (Resolution of the Government of the Russian Federation N 460 dated April 8, 2020) in respect of hired and dismissed employees coincide with the deadlines established by the commented Resolution of the Russian Federation Government.

At present, the Pension Fund has not commented on whether the information provided in accordance with the Temporary Rules will be sufficient or whether it is also necessary to fulfill the same obligation under the Decree of the Russian Federation Government N 590 dated April 26, 2020.

It is important that the President of the Russian Federation has already signed the Federal Law "On Amendments to Articles 2 and 11 of the Federal Law "On Individual (Personified) Accounting in the Mandatory Pension Insurance System" with regard to the procedure for submitting data on personalized accounting, which is awaiting publication (information accurate as for April 28,2020 9:20 a.m. https://sozd.duma.gov.ru/bill/941251-7).