Is it possible to submit SZV-M if the employee does not have a TIN?

Main nuances

On April 1, 2021, Resolution of the Board of the Pension Fund of Russia No. 83p On approval of the form “Information about insured persons” came into force.
The abbreviation SZV stands for “incoming information about the insured.” The letter M indicates that the form must be submitted monthly. In an organization, a dispute often arises about who should prepare this report: accounting or representatives of the human resources department who accept the employee into the organization, and where copies of all his documents are stored. The answer to this is simple: the person responsible for a given segment of work is appointed directly by the manager. One thing is clear - the person in charge must have access to current contracts concluded with employees.

The first report had to be submitted for April 2021, starting from this period, reports must be submitted by each employer on a monthly basis. The document must include information about each employee, even if he worked under a contract for only 1 day.

SZV-M must be submitted even if the organization is temporarily not operating, for example, all employees are on unpaid leave, but they have valid employment agreements. This is due to the fact that the submission of this type of report is not related to any payments and accruals. The only thing that matters is the presence of an employment contract or a GPC contract.

When filling out the form, do not forget about those employees who are on maternity leave. If there are no employees in the organization, and therefore no valid contracts, you do not need to submit this form.

To prepare the report and check it, special programs have been created, which can be found on the website of the Pension Fund of the Russian Federation.

As for the form for submitting the report, it can be prepared and submitted on paper. This is only allowed for employers with no more than 25 employees. However, even in this case, it is better to accompany the report with the corresponding file on a flash drive. If there are more employees, the form is submitted exclusively in electronic format, and it must have an electronic signature.

To send a form with an electronic signature, you must be a subscriber to the electronic document management system with the Pension Fund. For this purpose, an agreement is concluded with this government agency. The next step is to obtain a CEP certificate and purchase reporting software. For example, a similar opportunity is provided by the Kontur.Extern system.

Is it possible to take SZV-M without a TIN?

The employees who are responsible for submitting the report have a question about whether it is possible to submit the SZV-M without a TIN. According to the amendments that were made to Federal Law No. 136 of 2021, if the organization does not have information about the employee’s TIN, this number need not be indicated in the report form.

The TIN is not a mandatory detail, so there will be no sanctions for failure to enter the number from the Pension Fund. But reflecting a fictitious or someone else's number is illegal. You can even get a fine for this. This inaccuracy will be identified by fund employees during a reconciliation with the tax service.

If a report with incorrect information regarding the TIN of one of the employees has already been submitted, it is better to correct the inaccuracy yourself. To do this, you need to submit a supplementary report form. If you submit an electronic version of the document, the program itself will replace incorrect data with corrected ones.

Today, a TIN is not required when filling out other reporting forms, for example, 2-NDFL. Until the end of 2021, tax authorities required employers to independently find out the identification numbers of their employees. If the number was not assigned, employees had to contact the tax office to obtain one.

If an employee does not know his tax number

If an employee does not know his TIN, but remembers exactly that the number was assigned to him, the organization’s accountant can find it out on his own. To do this, you need to visit the official website of the Federal Tax Service and use the service called Find out TIN.

In the appropriate field, you must enter the employee's full name, date of birth, and passport information. If the person was indeed previously assigned a number, it will appear on the monitor screen. If the employee made a mistake and in fact the code was not assigned to him, the tax authorities’ website system will notify about this fact.

There is no longer any need to force an employee to apply to the Tax Office for a TIN. Form SZV-M without TIN can be sent to the Pension Fund. If you fill out the form in this way, when sending it, you may receive a notification that the TIN field has not been filled in for a certain employee. However, this will not be an obstacle to the report reaching the recipient. If there are no other errors in the document, it must be accepted by the inspector.

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It follows from this that an employee who is a Russian citizen and has not received a TIN does not pose any problem for the person responsible for filling out the SZV-M form.

However, for the convenience of accounting and to avoid disputes with inspectors in the future, it is better to ask the employee to contact the Tax Inspectorate to obtain a TIN.

Sample of filling out the SZV-M form for February 2019

If the employee does not have SNILS

When an employer hires new employees, he requests a certain package of documents from them. The insurance number of an individual personal account (SNILS) must be present among the papers. A person may not have such a document. This is possible if this place of work, for example, is the first. In such a situation, the employer is responsible for preparing the document.

There may be another reason why a person does not have such a document: he simply could have lost it. Whatever the reason, it will take some time to restore or register SNILS, which can reach three weeks. Given this fact, it may happen that at the time when it is necessary to submit the SZV-M report, the employee will not yet have his insurance number on hand.

This field in the report form cannot be left blank; it must be filled out. If you provide incorrect details, an error will be identified when checking the provided data by Pension Fund employees. As a result, the employer will be held accountable in accordance with Article 17 of Federal Law No. 27. The amount of the fine that will have to be paid will be 500 rubles for each SNILS that was indicated incorrectly.

If the report is submitted using a telecommunications channel, the policyholder will be refused to accept the report, since the document will not pass the program’s verification. You must not miss the deadline for submitting the report, since this will also entail penalties: in this case, you will have to pay 500 rubles for each employee for whom information was not submitted in a timely manner.

In this case, the only acceptable option is not to include in the form the data of an employee who does not have SNILS. After the insurance certificate has been issued, you can send a supplementary report, which will include all employees who were not previously included in the reporting.

It is best to submit such a report with a cover letter indicating the reason why the employee was not included in the initial report form. As a basis for such actions, it should be noted that it was not physically possible to submit data on the SNILS of some employees in a timely manner, since at the time of submitting the report such a document had not yet been issued for them.

In such a situation, there is a possibility that no penalties will be applied to the employer. But if possible, it is better to avoid this and ask employees in advance for information about their SNILS.

What is the SZV-M report?

The SZV-M report contains only a list of employees’ full names, their SNILS and INN.
It is so simple that it raises the only question - why take it every month? The pension fund needs to know which employees are still working. The thing is that pensions are calculated differently for working and non-working pensioners. SZV-M will help the fund immediately find out about the dismissal of a pensioner and recalculate payments for him. Despite the fact that the report was started for the sake of pensioners, you will still have to submit a list of all working employees.

The information from the report is important to the pension fund. But there is another problem: they are duplicated. The Pension Fund of the Russian Federation receives similar information from the SZV-TD report, and much more quickly: the very next day after hiring or dismissal. And here again there is an explanation: SZV-TD is only about employees under an employment contract, SZV-M is also about individuals who work under a GPC agreement.

Changes from 2021

From the beginning of 2021, new rules for submitting the SZV-M form have come into force.

There are five of them:

• The term for filing SZV-M has been changed. If previously the report was submitted by the 10th day of each month following the reporting month (in some cases a fluctuation of one or two days was allowed), then starting in January of this year a new deadline has been established, which is set for the 15th. That is, now the employer is given 5 more days to prepare the report.
• The pension fund will impose a fine if a company with more than 25 employees submits a paper report instead of an electronic form. Last year, such sanctions were not applied to employers.
• Making a mistake in the TIN has become more dangerous than before. Starting from 2019, a tax identification number is a mandatory element when maintaining personalized records. It is not necessary to reflect it in the SZV-M, but in the new calculation of contributions it must be recorded without fail. If last year it was more difficult for pensioners to track the TIN of each employee, then since the new year the fund has additional opportunities for this, and, accordingly, the likelihood of receiving a fine is higher.
• If an error is detected in the SZV-M form, not only the company, but also its manager and the chief accountant will face penalties.
• The Pension Fund has approved the updated electronic format of the SZV-M form.

New electronic form

In 2021, the Pension Fund changed the format of information submitted using the SZV-M form twice. This happened in September and December. According to the changes made, the number of errors and inaccuracies was reduced, the admission of which led to the rejection of the report and its sending for revision. According to the order of the Pension Fund No. 432 of 2019, the number of errors decreased from 30 to 14.

Now pensioners are not punished for an extra dot, dash or space. If an incorrect registration number is entered, this will be regarded as a gross violation and the form will not be accepted.

The new form is more advanced, thanks to which accountants no longer experience difficulties filling out the SZV-M.

Starting in January 2021, the report is submitted in a new electronic format, which was approved in December 2021 by the Resolution of the Pension Fund, which gained force in early January of the new year. Failure to comply with the requirements for the report form will result in the organization receiving a negative report, which will indicate non-acceptance of the report.

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What if at the time of submitting the SZV-M there is no information about SNILS in relation to the new employee?

The organization has hired an employee for whom this is his first job. He does not have an insurance certificate for compulsory pension insurance. In this regard, the employer applied to the Pension Fund of Russia to obtain such a certificate. However, at the time of submitting the SZV-M form for the month in which the employment contract was concluded with the individual, the certificate is not yet ready, i.e. no data on SNILS. How to fill out information on such an employee in the SZV-M form?

No later than the 10th day of each month, the employer must submit to the Pension Fund of Russia information in the SZV-M form (approved by Resolution of the Board of the Pension Fund of the Russian Federation dated 01.02.2016 No. 83p) about the individuals working for him, with whom in the reporting month the agreements are, continue to be valid or employment contracts or civil contracts have been terminated (Clause 2.2 of Article 11 of Federal Law No. 27-FZ dated 01.04.1996, hereinafter referred to as Law No. 27-FZ).

This information includes: Full name, TIN (if the employer has information about the TIN), SNILS.

SNILS is indicated in the certificate of compulsory pension insurance. The employee must submit this document among other mandatory documents listed in Art. 65 of the Labor Code of the Russian Federation for employment.

The exception is the situation when an individual gets a job for the first time. In such a situation, the employer issues an insurance certificate for him (Part 4 of Article 65 of the Labor Code of the Russian Federation).

To do this, a questionnaire is submitted to the fund body for a new employee in the ADV-1 form (clause 9 of the Instructions, approved by order of the Ministry of Health and Social Development of Russia dated December 14, 2009 No. 987n, hereinafter referred to as the Instructions). Within three weeks from the date of receipt of the questionnaire, the Pension Fund of the Russian Federation must prepare and send an insurance certificate to the employer for delivery to the individual (clause 13 of the Instructions).

If such a certificate is not yet ready at the time of filing the SZV-M, the employer cannot reflect SNILS in the reporting in relation to the new employee.

According to Part 4 of Art. 17 of Law No. 27-FZ, failure to submit the SZV-M form within the prescribed period or reflecting incomplete and (or) unreliable information in it entails a fine of 500 rubles in relation to each individual.

However, in the above situation, the indication of incomplete information about the employee (without SNILS) is due to objective reasons. In this regard, it is advisable to attach a cover letter to the SZV-M for the reporting month justifying the reasons for the lack of data on SNILS.

In this case, as soon as the insurance certificate is ready, the employer needs to submit SZV-M reporting for the past month (the month of concluding an employment contract with the employee) with the code “additional” (it is indicated in field 3 “Form type (code)___”). In such a report, you will need to indicate data that was not reflected in the original form with the code “source”.

22915 May 5, 2016

Who must submit a new report to the Pension Fund of Russia

It is necessary to use the SZV-M form with the “Additional” attribute in the 3rd section. However, the accountant will not fill out data for all employees. The report must include the full name, SNILS and TIN of the new employee.

The cancellation form SZV-M must be submitted to the Pension Fund of the Russian Federation if the initially submitted form indicated an employee who was dismissed before the reporting month or if in the reporting month the organization (IP) made payments in favor of this dismissed person.

If in the initial SZV-M you indicated the contractor under the GPC agreement, with whom the GPC agreement was concluded in the reporting month, but he must begin performing work in accordance with the agreement only in the month following the reporting month, then a canceling SZV must also be submitted to him -M.

When submitting an SZV-M with the code “cancel”, it is necessary to note in it only those persons for whom it is necessary to delete the information presented in the original SZV-M, and employees for whom the correct data were submitted do not need to be indicated in the cancellation form, otherwise the Pension Fund of the Russian Federation will delete information in the database and on it.

The new report must be submitted by individual entrepreneurs and organizations for those employees who work under an employment or civil contract and receive income subject to insurance contributions to the Pension Fund.

Instructions for filling out a report to the Pension Fund of the Russian Federation using the SZV-M form

Section 1. We indicate the details of the policyholder:

• Registration number in the Pension Fund of Russia. Indicated in the notification from the Pension Fund of the Russian Federation received upon registration of the LLC (IP). You can also find it out at the local branch of the Pension Fund of Russia, or at the tax office (by dictating your TIN).
• Name (short). For example, "LLC".
• Field "TIN". Individual entrepreneurs and organizations indicate the TIN in accordance with the received certificate of registration with the tax authority.
• Checkpoint field. The IP field of the checkpoint is not filled in. Organizations indicate the checkpoint that was received from the Federal Tax Service at their location (separate units indicate the checkpoint at their location).

Section 2. Reporting period. The number of the reporting month for which the report is submitted is indicated, and a little further, the reporting calendar year (for example, Reporting period 04 calendar year 2019).

Section 3. Form type (code). Specify the form code:

• outgoing form (original form, submitted for the first time in the reporting month);
• additional (supplementary form, submitted to supplement previously submitted information);
• cancel (cancellation form, submitted to cancel previously incorrectly submitted information).

Section 4. Information about the insured persons (employees) who received payments in the reporting month is indicated:

• Last name, first name, patronymic (in the nominative case).
• Individual personal account insurance number (SNILS).
• TIN (if information about the employee’s TIN is available).

Note: Employees' full names can be indicated alphabetically or in any other sequence.

At the bottom of the report it is necessary to put the signature of the manager (IP) indicating the position, seal (if any) and the date of signing.

You no longer need to indicate the TIN in SZV-M

If the company does not have information about the TIN of employees, it may not be indicated in the SZV-M. Such amendments were introduced by Federal Law No. 136-FZ of May 1, 2016.

If you indicated an incorrect TIN, the fund will detect an error when reconciling with the Federal Tax Service. Therefore, if you have already filed a report, it is safer to correct the inaccuracy. The funds believe that for this it is enough to pass the supplementary SZV-M. The program will replace the previous information with new information.

Last week, the fund answered another controversial question on the new form: Is it necessary to take the SZV-M if the company only has a founding director? On its website on April 29, the Pension Fund of the Russian Federation gave official clarifications: The policyholder monthly no later than the 10th day of the month. following the reporting period, provides the following information about each employee (including persons who have entered into contracts of a civil law nature, for remuneration for which insurance premiums are calculated in accordance with the legislation of the Russian Federation):

1) Insurance number of an individual personal account; 2) Last name, first name, patronymic; 3) Taxpayer identification number.

Simply put, if the company has one founding director, SZV-M must be passed. Companies include in the report “physicists” who worked for a month under employment and civil law contracts. The director does not enter into an employment contract, but an employment relationship arises with him. The Ministry of Finance also agrees with this (letter dated March 15, 2016 No. 03-11-11/14234).

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SZV-M report form in 2019

The employee's full name must be indicated in SZV-M, as in SNILS. If an employee recently changed his last name or first name and has not yet managed to change SNILS, then SZV-M must be filled out using the old last name and first name, otherwise when checking the report you will receive an error message.

A person who is hired for the first time under an employment contract or who has entered into a GPC agreement, for which insurance premiums are calculated for remuneration in accordance with the legislation of the Russian Federation, receives an insurance certificate of compulsory pension insurance containing the insurance number of an individual personal account, through the policyholder, unless otherwise provided by federal law. dated 04/01/1996 N 27-FZ.

In case of loss of SNILS, the insured person is obliged to contact the policyholder within a month from the date of loss with an application for its restoration. The policyholder must submit this application to the relevant body of the Pension Fund of the Russian Federation along with a document confirming the insurance number of the individual personal account of the insured person.

The Pension Fund of the Russian Federation, upon application of the insured person for the loss of SNILS, within a month from the date of application, on the basis of an individual personal account opened for him, issues him a duplicate of the specified insurance certificate through the policyholder or in person. The Fund may require additional information from the insured person confirming his identity and information contained in his individual personal account (Article 7 of Federal Law No. 27-FZ of April 1, 1996).

If an employee has lost SNILS, then he must restore it himself using his passport in the Pension Fund. An employer cannot find out an employee’s SNILS number himself via the Internet, since SNILS number is confidential information.

The accountant can also ask the employee to enter SNILS through his personal account on the State Services website. To do this, the employee must select. The portal will send a notification, and it will indicate the employee’s SNILS. But this service is available only to those citizens who are registered on the State Services website.

Will an accountant be fined for not having SNILS and TIN in SZV-M?

2016 added new worries and worries to accountants. Form 6-NDFL has been introduced for the tax office. The Pension Fund of the Russian Federation did not stand aside either. In addition to quarterly reporting, monthly reporting has been introduced in the form of SZV-M. This form provides for entering data about each employee who has entered into an employment or civil contract with the enterprise. Full name, SNILS and Pension Fund are required details. And all accountants, naturally, are interested in the question, are there already penalties for unsubmitted reports or reports with errors in SNILS or TIN?

SZV-M: responsibility and penalties for errors

First of all, we need to mention the fine for not submitting a report at all. Failure to provide information about one employee will cost the company 500 rubles. The fine for a report with distorted data will be the same. The right to impose fines is granted directly to the Pension Fund branches receiving reports. Accordingly, we can assume that if an enterprise employs 100 people, 10 of them did not submit reports or submitted reports with errors, then the fine amount will be 5,000 rubles.

If the report is not submitted for 50 people, then you can reserve 25,000 rubles in your current account to pay the fine. It should also be taken into account that the report is monthly. Now, more specifically, whether errors in SNILS and/or TIN will be punished.

SZV-M without TIN or SNILS: will there be punishment?

The short answer to this question is yes, it will. The enterprise or organization will be punished in the amount of the same 500 rubles specified in the previous paragraph. The punishment will also apply for each incorrect report, that is, for each incorrectly entered SNILS or TIN. More details about the types of punishment can be found in paragraph 4 of Article 17 of Federal Law-27 as amended by Federal Law-385 dated December 29, 2015. Whether in such a situation the employee who submitted an incorrect report will be punished is up to the enterprise to decide.

What should accountants do in such a situation? Many employees are hired without having a complete package of documents, promising to deliver them later. And then comes the reporting period. Experts recommend the following way out:

— if an employee does not know his TIN and cannot provide a certificate or a copy of it, then the Rules allow the line with the TIN to be left blank. The basis for failure to enter data on the TIN is Federal Law-136 dated January 1, 2016. But if the data is entered into the line, then there should be no errors. An incorrect figure equals a fine of 500 rubles;

— if an employee does not know his SNILS, cannot provide a certificate, and has not received it yet, then the enterprise is obliged to obtain a certificate for him by submitting an appropriate application to the Pension Fund of Russia branch. Basis - Federal Law-27, Art. 9. clause 3). An enterprise is given no more than 2 weeks from the date of signing the employment contract to receive SNILS. The deadlines for receiving SNISL are specified in clause 9 of the Instruction of the Ministry of Health and Social Development of the Russian Federation dated December 14, 2009 No. 987n. If the reporting deadline has arrived and SNILS has not yet been received, then experts suggest submitting the report without including this employee in it. Later you will have to submit an additional report for a specific employee.

If the Pension Fund treats the absence of a TIN leniently, then without SNILS the report will be considered not submitted. You can prepare for a fine of 500 rubles for each sheet.

How to restore an employee’s SNILS

An enterprise is required to submit an application for the issuance of SNILS only if the employee has not previously received it at all. If the certificate is simply lost, the employee will have to restore it himself. State portals do not make it possible to quickly find out the SNILS number of a careless employee. Information can only be provided by the “confused” person himself. But to do this, you need to first register on the State Services website and look at the necessary information in the “Extended notice of the status of an individual personal account” tab.

Why is the TIN column needed?

Many of those filling out the SZV-M report make the same mistake. Almost everyone believes that if the TIN is not a mandatory requirement, then you don’t have to waste time on it. But it's still better to spend it. The TIN for the Pension Fund serves as the same identifier as SNILS. If in the latter case an error is made, the data will be posted using information from the TIN. But, if this column is empty, then a fine is inevitable: the Pension Fund will simply not count this sheet as passed.

A fine is possible even when the TIN is entered, but there is still hope that the inspector will be in a good mood and will not want to waste time issuing a notice of the fine. In this situation, there can be only one advice - spend an extra 5 minutes on each report in order to enter and once again double-check all the data for each employee. In addition, the Taxpayer Identification Number (TIN) for any person can be easily found on the Federal Tax Service website. This information is not classified as secret.

How to enter information about employees in a new report: randomly or alphabetically

The instructions for filling out the SZV-M do not contain any special requirements in this regard. An accountant can enter data in a way that is convenient for him.

New reporting form SZV-M: asked - we answer

April 29, 2016

1. Information on the employee is presented without a tax identification number due to its absence. Are financial sanctions applied in this case?

Monthly reporting is submitted in the form “Information about insured persons” (form SZV-M), which provides for filling out the taxpayer identification number (TIN) if the policyholder has data on the individual’s TIN. THAT. The absence of the TIN of the insured person in the information provided by the policyholder in the SZV-M form will not be a reason for refusal to accept monthly reports, and financial sanctions are not applied to such policyholder.

1. Can the deadline for submitting reports be extended if the policyholder does not have information about the employee’s SNILS number?

All indicators of the SZV-M form, with the exception of the “TIN” indicator, are required to be filled out. In addition, SNILS is a document required to be presented when applying for a job. In this regard, the SZV-M form information about the SNILS number is required to be filled out.

The absence of SNILS data from the policyholder is not a basis for extending the deadline for submitting reports. And violation of the deadline due to the lack of SNILS entails financial sanctions.

1. Is the SZV-M form submitted if the quarterly reporting is “zero”?

If someone submits a report, it means that he is an employee of this organization and he has all the authority to provide reports on its behalf. Accordingly, reporting must be submitted for at least one employee. The absence of accrual of insurance premiums cannot serve as a basis for failure to submit monthly reports to SZV-M.

1. Is it necessary to submit monthly reports for the founder in the absence of accrual of insurance premiums?

Working citizens are understood as persons (Article 7 No. 167-FZ), which include those working under an employment contract, including heads of organizations who are the only participants (founders) and members of organizations. THAT. they are subject to the compulsory pension insurance regime, and upon payment of insurance premiums they acquire pension rights.

Taking into account the above, persons in the category under consideration are classified as employed and must submit the SZV-M form to the Pension Fund on a monthly basis, even in the absence of accrual of insurance contributions.

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Insured persons for the purposes of SZV-M

The obligation to submit the form to the Pension Fund on a monthly basis has been established since 04/01/2016.

Information is provided for each insured individual, including part-time workers, foreigners, and not only pensioners, with the exception of:

The main criterion for including information about such persons in reporting is the fact of concluding agreements with them according to the following list, specified in the explanations to the form itself:

• employment contracts;
• GPC agreements, author's orders, publishing, licensing, etc. (i.e., agreements under which insurance premiums are calculated in accordance with the legislation of the Russian Federation).

IMPORTANT! The presence of payments subject to insurance premiums made to such individuals, as well as the validity period of contracts with them in the reporting period, do not matter for the purposes of including information in the SZV-M form. Consequently, information about employees on sick leave, on vacation - paid or at their own expense, as well as maternity leavers and other similar persons to whom payments were not made by the insurer in the reporting period must also be reflected in the form

Consequently, information about employees on sick leave, on vacation - paid or at their own expense, as well as maternity leavers and other similar persons to whom payments were not made by the insurer in the reporting period must also be reflected in the form.