Russian Pension Fund Order No. 769-P dated October 27, 2020 (in Russian) requiring, among other things, all employers to specify relevant five-digit position codes from the National Classification of Positions will enter into force on July 1 August 1 (July 2, 2021 Pension Fund). SZV-TD reports will not be accepted if the appropriate code is not specified. The order provides as follows:
“2.5.5. The code matching the position held (profession), type of work performed at the workplace when fulfilling work functions (work, duties) consisting of 5 digits is to be specified in column Code of Function Performed as follows “XXXX.X”, where:

  • The first four digits represent the name of the group of occupations in the National Classification of Positions; and
  • The fifth digit is a control digit.”

The code used to have seven digits and be filled out only by employers who themselves had decided to apply professional standards. Russian Ministry of Labor Letter N 14-0/10/В-1704 dated March 05, 2020 states as follows:

“Regarding the procedure for filling out column 5 Code of Function Performed (if any) in SZV-TD forms, employers who have decided to apply professional standards for positions held by insured persons (employees) are to complete it from January 1, 2021 onwards”.

The code has to be selected based on actual functions of the employee regardless of the title of the position in HR documents.


Article 15.33.2 of the Russian Code of Administrative Offenses provides for the following for failure to comply with the procedure and deadlines for submitting reports to the Russian Pension Fund and for errors in reports:

  • Company officers – an administrative fine from RUB 300 to RUB 500 for each error (except for individuals engaged in entrepreneurial activities without establishing a legal entity).

This violation also falls under Article 5.27(1) of the Russian Code of Administrative Offenses which provides for:

  • A fine from RUB 1,000 to RUB 5,000 for company officers; and
  • A fine from RUB 30,000 to RUB 50,000 for legal entities.

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Our specialists can audit your HR documents and introduce all the necessary changes to submit SZV-TD reports in accordance with the new requirements.