The changes were approved by the Order of the Ministry of Labour dated 14.06.2018 No 385n.
According to the new version, without a fine, it is possible to correct only mistakes in the information already accepted by the Pension fund.
Thus, if information on one or more people wasn’t initially included into SZV-M, this information cannot be considered accepted.
The fine for the additional form SZV-M, submitted to the RF Pension fund later than the 15th day of the month following the reporting one, will be lawful.
Here we remind you that in accordance with Federal Law No 27-FZ "On Individual (Personalized) Accounting records...", the fine is 500 rub. per each insured person, including those not included in the report.
Due to the fact that the changes affected clause 39 of the Instructions, to which the judges referred when deciding on the cancellation of fines, it will be more difficult to challenge the fine for the additional form SZV-M for the insured persons not included in the initial report, submitted to the RF Pension fund upon completion of the period established by the legislation.
Based on the above, we, as before, highly recommend that you:
- establish corporate processes and provide us with information on upcoming civil-law contracts at the stage of their internal approval;
- timely provide us with already agreed and current civil-law contracts;
- timely inform us that, according to the already concluded civil-law contract, payments will not be made in the current month;
- prevent the conclusion of civil-law contracts and accrual of payments under them retrospectively.
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