SZV-M due date for September 2021
SZV-M is submitted no later than the 15th day of each month (clause 2.2 of Article 11 of the Law of 01.04.1996 No. 27-FZ “On individual (personalized) accounting..."). If the deadline for submitting the report falls on a weekend or holiday, it is postponed to the first working day (Letter of the Pension Fund of the Russian Federation dated December 28, 2016 No. 08-19/19045).
The deadline for submitting SZV-M for September 2021 is no later than 10/15/2020.
Where to get the form and when to submit the finished SZV-M to the Pension Fund of Russia
The SZV-M form was approved by Resolution of the Pension Fund Board of February 1, 2016 No. 83p. It is one of the employers’ reports to the Pension Fund, containing personalized information about individuals (full name, SNILS and Taxpayer Identification Number) - employees with whom employment contracts have been drawn up, and persons who have entered into civil law agreements (GPC).
SZV-M must be submitted monthly - no later than the 15th day of the month following the reporting month (clause 2.2 of Article 11 of the Law “On individual (personalized) accounting in the compulsory pension insurance system” dated 04/01/1996 No. 27-FZ).
In some cases, you can spend a little more than the specified time filling out the SZV-M: if the 15th falls on a weekend or holiday, the reporting deadline is shifted to the first working day (PFR letter dated 04/07/2016 No. 09-19/4844).
Next, we will talk about the composition of the reporting form and show what the SZV-M sample looks like.
Who takes SZV-M for September 2021
The SZV-M report is submitted by:
- Employers for employees - with whom labor and civil law contracts have been concluded, as well as copyright and licensing agreements.
Individual entrepreneurs, lawyers, notaries do not rent SZV-M without employees.
- Organizations with several founders - if one of them is the CEO.
The report is submitted even when an employment contract has not been concluded with the director (Letter of the Ministry of Labor dated March 16, 2018 No. 17-4/10/B-1846).
- Companies with a single founder and director in one person.
The existence of an employment contract does not matter. Until March 2021, the Pension Fund allowed such companies not to submit SZV-M, citing the fact that there are no persons with whom labor and civil law contracts have been concluded, as well as payments accrued on their basis. And since there are no contracts and payments, then there is no need to submit a report (Letter of the Pension Fund of the Russian Federation dated July 27, 2016 No. LCH-08-19/10581).
But since March 2021, the Pension Fund has radically changed its position and obligated all companies, including those in which the only founder works as a director without an employment contract, to submit SZV-M. The reason is that labor relations without a properly executed contract arise when an employee is actually allowed to work (Letter of the Ministry of Labor dated March 16, 2018 No. 17-4/10/B-1846).
- SNT, DNT, HOA.
Submitted to the chairman if he is paid remuneration for the work performed. If the chairman works on a voluntary basis and does not receive anything for his work, the SZV-M does not need to be taken. But in this case, it is necessary to submit to the Pension Fund a charter that confirms the gratuitous activities of the chairman.
- Charity organisations.
They rent for volunteers, who are reimbursed for food costs in amounts exceeding the daily allowance if GPC agreements have been concluded with them.
- Separate units.
They rent out SZV-M only if they have a separate current account and pay their own salaries to employees. In this case, the SZV-M indicates the TIN of the parent organization and the checkpoint of the separate division.
Frequently asked questions about submitting and completing the SZV-M report
Is it necessary to take SVZ-M IP without employees?
Individual entrepreneurs or organizations that have at least one employee must report using the SZV-M form. Therefore, individual entrepreneurs without employees do not need to submit a SVZ-M report.
Do NGOs and public organizations without employees need to submit a report?
In accordance with the Letter of the Ministry of Labor of Russia dated March 16, 2018 No. 17-4/10/B-1846, brought to the attention of the Pension Fund Branches by the Pension Fund Letter dated March 29, 2018 No. LCh-08-24/5721, SZV-M must be submitted in relation to the chairman of the HOA , Civil Procedure Code, SNT, ONT, DNT (in the absence of a concluded employment or civil law contract).
Do newly created LLCs without employees, general director and bank account need to submit SZV-M?
In accordance with the Letter of the Ministry of Labor of Russia dated March 16, 2018 No. 17-4/10/B-1846, brought to the attention of the Pension Fund Branches by the Pension Fund Letter dated March 29, 2018 No. LCH-08-24/5721, SZV-M must be submitted in relation to the head of the organization , who is the sole founder, regardless of whether an employment contract has been concluded with him.
Do organizations need to submit a report during the liquidation process?
According to the explanations given by the Pension Fund of the Russian Federation, the fact that an organization is in the stage of bankruptcy does not relieve it of the obligation to submit a report in the SZV-M form. In this case, a zero form is filled out and signed by the bankruptcy trustee.
Procedure for filling out SZV-M for September 2021 - sample
The preparation of the report begins with entering information about the policyholder:
Registration number in the Pension Fund of Russia
It is assigned to each legal entity or individual entrepreneur upon registration with the Pension Fund and must be present on all reports sent to the fund. This is a 12-digit digital code, the correct filling of which can be checked, for example, on the Federal Tax Service website by requesting an extract from the Unified State Register of Legal Entities or the Unified State Register of Individual Entrepreneurs.
Short name of the policyholder
Organizations take it from their constituent documents. If there is no “official” short name, the full name should be indicated.
Entrepreneurs indicate the abbreviation IP and their full name. An individual employer who is not an individual entrepreneur (for example, a lawyer or a notary) does not indicate anything other than his full name in this line.
TIN and checkpoint
Taken from the certificate issued by the Federal Tax Service. For a legal entity, a 10-digit TIN and a 9-digit KPP (reason code for registration) are used. Individual entrepreneurs and individuals who are not individual entrepreneurs indicate only a 12-digit TIN.
Reporting period
The month (in two-digit format) and year (in four-digit format) are indicated. For September 2021, “09” and “2020” are entered in this line, respectively.
Form type
One of the letter codes is displayed, depending on the version of the submitted report:
- “out” - if the form is submitted for the first time;
- “additional” - if the report includes information that supplements previously sent information;
- “cancel” - if the purpose of the submitted form is to cancel previously provided incorrect data.
Information about the insured persons
The report includes all employees with whom contracts related to the payment of remuneration were in effect during the reporting period (in this case, September 2021).
The data is presented in the form of a table consisting of 4 columns:
- Serial number. The order in which the insured persons are included in the report does not matter. This can be alphabetical, chronological (as contracts are concluded), or even random order.
- Full name of the insured person. We give it in the nominative case. Please indicate your middle name if available.
- ILS insurance number. We deposit on the basis of the SNILS certificate.
- TIN of an individual. This detail, unlike the previous ones, is not strictly mandatory and if the employer does not have this information, it may not be included in the report.
Next, information about the person signing the report is indicated and his personal signature is placed. For a legal entity, this is the head or the person performing his duties (in the latter case, indicate the details of the document confirming the authority of the representative). The individual entrepreneur or other individual employer signs the report personally. In this case, in the line “Name of manager’s position” the status of the individual is indicated - entrepreneur, notary, lawyer, etc.
Sample SZV-M for September 2021
Features of the formation of SZV-M for September 2021
- In SZV-M for September 2021, include only those persons whose payments are subject to pension insurance. If a purchase and sale or lease of property agreement has been concluded with an individual, then there is no need to enter data about it in SZV-M.
- Information in the SZV-M form for September 2021 is submitted for each insured person with whom employment contracts and GPC agreements were concluded this month, continue to be valid, or have been terminated. The availability of payments for them does not matter. It does not matter how many days during September the agreement was valid. Even if we are talking about only one day, the employee must be included in the report. But if in the reporting period there were only payments, and the contract was not valid, there is no need to include such an employee in SZV-M.
- If employees are absent from work for any reason (long business trip, vacation, maternity leave), but their contracts are still valid in September, also include information about them in the report.
Useful information from ConsultantPlus - is it necessary to submit a zero report on the SZV-M form
Yes, you need to submit a SZV-M, regardless of whether you made payments to employees during the reporting month or not. We also recommend submitting Form SZV-M if the organization has only a manager with whom an employment contract has not been drawn up and who is its sole founder (read more...).
SZV-M what kind of reporting is this?
Many business entities still ask the question – what is SZV-M?
The sv-m form is a form drawn up by employers for their employees for the month, containing information with their personal data. By receiving this report, the pension fund determines who is a working pensioner.
He needs this in accordance with the law in order for this category of citizens to correctly suspend and, if necessary, resume indexation of pensions.
If an organization or entrepreneur includes a person in the report in the current month, then he is considered working.
Accordingly, if a contract with an employee is terminated, the company should not submit information about him next month.
This allows pension amounts to be indexed automatically as soon as pensioners stop working, making this procedure easier for them. Attention! The SZM form is drawn up not only for people of retirement age, but also for all employees of the company.
By submitting it, the employer has the opportunity to check the correctness of the information provided for these people and verify their registration data. The report must be compiled and submitted to the Pension Fund after the current month comes to an end.
What does reconciliation of SZV-M with SZV-TD give?
Before sending to the Pension Fund of Russia, check SZV-M with SZV-TD and make sure that you have included all hired employees in the report and removed dismissed ones. This will save you from a fine.
If earlier fund specialists could check information about the insured person only by checking with the DAM (that is, not earlier than the end of the quarter), then with the advent of the SZV-TD report, the Pension Fund receives information about fired and hired employees the very next day and can quickly identify information incorrectly reflected in the SZV-M, or missing data.
Zero SZV-M
The SZV-M form cannot be zero. After all, this is a report about the insured persons. And if they are, then SZV-M is served. If there are no insured persons, then there is no point in submitting a blank report. It doesn't contain any useful information.
There is also no need to provide individual information for one general director, who is the sole founder of the company, if an employment contract or GPA is not concluded with him and he does not receive any payments. This was indicated by the Pension Fund of Russia in a letter dated July 27, 2016 No. LCH-08-19/10581.
When can you avoid a fine for SZV-M?
Despite the fact that SZV-M has been submitted for several years, many disputes regarding fines due to errors in this form have to be resolved only in court. And often the courts support the policyholders. Here are a few court decisions that will help you avoid a fine or significantly reduce its size:
- The court reduced the fine by 10 times for being late in submitting the SZV-M, taking into account mitigating circumstances: the violation was committed for the first time, the period of delay was insignificant (4 days), there was no intent and no negative consequences for the budget (Resolution of the Central District Court of 06/02/2020 in the case No. A83-10587/2019).
- A grammatical error in SZV-M is not punishable by a fine (Resolution of the Administrative Court of the East Siberian District dated May 26, 2020 in case No. A78-11257/2019).
- There will be no fine if the fund misses the deadline for collecting sanctions, which must be calculated from the date established for submitting information about the accounting (Resolution of the Ural District Administrative District dated June 10, 2020 in case No. A34-14254/2019).
- An error in information about an employee, corrected within 5 days after receiving a notification from the Pension Fund of Russia, is not grounds for a fine (Resolution of the Administrative Court of the West Siberian District dated 03.03.2020 in case No. A75-9576/2019).
- Technical failure of the software (Determination of the RF Armed Forces dated 08.08.2019 No. 309-ES19-12439).
- A technical typo in SZV-M is not grounds for a fine (Determination of the RF Armed Forces dated September 28, 2018 No. 309-KG18-14482).
- It is impossible to fine a branch for being late with SZV-M (Resolution of the Supreme Court of the Russian Federation of December 10, 2018 No. 308-KG18-19977).
- An error in the SZV-M, corrected after the reporting deadline, but before its discovery by the Pension Fund of Russia, cannot be the basis for a fine (Determination of the RF Armed Forces dated November 29, 2018 No. 310-KG18-19510).
- The organization in the original SZV-M did not indicate information about 248 employees and only a year later supplemented the information that was missing. The Pension Fund of the Russian Federation fined her for this after an inspection, but the judges considered the prosecution to be unlawful, since the fund itself did not discover the error during the past period (Resolution of the Volga-Vyatka District Administrative District dated October 29, 2018 in case No. A82-1008/2018).
- The SZV-M was submitted late due to the accountant’s illness ─ the court reduced the fine by 11 times, recognizing the accountant’s disability as a mitigating circumstance (Determination of the RF Armed Forces dated July 4, 2018 No. 303-KG18-8663).
- The employer submitted the SZV-M a day late for a good reason (on the last day of submitting the report, the lights were turned off) ─ the judges sided with the employer, disagreeing with the imposition of a fine (Resolution of the Volga-Vyatka District Administrative Court dated July 17, 2017 No. A28-11249/2016) .
When a fine cannot be avoided
Let's talk about extraordinary cases when judges supported the Pension Fund of Russia and imposed a fine for SZV-M:
- The company received a protocol from the Pension Fund of the Russian Federation with the following set of information: about errors in SZV-M with their description, about the fund’s refusal to accept incorrect information and about the need to submit corrected statements. At the same time, the fund did not formalize or send the notification. The company submitted the adjustment later than 5 days from the date of receipt of the protocol. She was fined for this. The court equated the protocol to a notification and did not accept the arguments that the Pension Fund of the Russian Federation did not send a notification to the company (Resolution of the Court of Justice of the North-Western District dated April 23, 2020 in case No. A42-9736/2019).
- The company did not manage to submit SZV-M on time due to the fact that the programmer was on vacation, and the SZV-M program was not working on the last day of the deadline. In support, the company provided screenshots and a memo stating that it was impossible to provide information due to technical problems. However, the court did not consider the presented evidence to be objective and did not accept the company’s arguments (Resolution of the Administrative Court of the East Siberian District dated March 26, 2020 in case No. A19-13913/2019).
Let's sum it up
- The SZV-M for September 2021 must be submitted no later than October 15, 2020.
- The report is submitted on paper only if the number of employees does not exceed 24 people. For 25 or more employees, you will have to report electronically via TCS through EDI operators.
- From March 2021, SZV-M must be handed over to organizations with a single founder acting as a director, even if an employment contract has not been concluded with him.
- In order to properly defend yourself in court and not pay fines, you should take into account the current judicial practice on SZV-M.
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Do I need to submit a zero report?
Employees who are responsible for compiling salary reporting sometimes have a question about whether the new SZV-M form should be submitted in zero form. But the report on it lies in the very definition of this report.
It has been established that the report must include all persons with whom the organization or entrepreneur has formalized employment or civil contracts.
In this case, special attention should be paid to the word “registered”, since even if the company temporarily does not operate and, accordingly, does not pay wages to employees, their contracts are preserved, and they do not cease to be insured persons all this time.
But if the individual entrepreneur has no employees at all (he operates alone), and the company does not even have an agreement with the director, then they do not need to submit the form at all.
Attention! It follows from this that the zero form of sv-m does not exist. Either the organization or entrepreneur has concluded agreements, and these people are included in the report, or there are no agreements and the form is not drawn up at all.