According to customs statistics, the states of the Eurasian Economic Union account for a significant share of agricultural imports into Russia: Belarusian dairy products, cheeses and meat, Kazakh grain, flour and compound feed, Armenian fruit and wine, and Kyrgyz vegetables and berries are actively supplied to the country. Until now, the movement of these goods across the Russian border followed a relatively simple scheme: an indirect tax declaration was submitted by the importer after import — within 20 days of the following month — and taxes were paid within the same period. From 1 June 2026, the logic has been reversed: first an application and a security payment to the budget, and only after that does the truck travel to the border. Without a confirmed application and a QR code, the vehicle will now simply not be allowed across the border.
The new solution is called the “System for Confirmation of Expected Delivery of Goods” (SPOT) and is governed by two federal laws dated 17 April of this year (on the system itself and on the procedure for accounting for the security payment on the single tax account). At first glance, this is a purely technical reform: a digital platform of the Federal Tax Service (FTS), an electronic document on the upcoming delivery, and a QR code at the border checkpoint. For an importer of agricultural products, however, the effect is more tangible. With the innovation, supply planning, money movement and the allocation of liability between the parties to a transaction are changing.
Why Does the State Need Another Digital Circuit?
Within the Eurasian Economic Union there are no customs borders in the classical sense — goods move freely between the member states, and indirect taxes (VAT and excise duties) are levied according to the destination-country principle. This means that the importer — a Russian company — pays these taxes not at the border but as part of its current tax obligations, under a declaration submitted after import. Control over the integrity of these payments was previously exercised post factum, and the state has long recorded significant budget losses here: grey import chains, shell companies, understated prices and unpaid VAT.
SPOT is an attempt to reverse the scheme. Tax payment is moved from the moment “after import” to the moment “before import”, and the very fact of payment becomes a condition for the physical admission of goods into the country. For this purpose, a unified digital platform for customs and tax control is being created, where the FTS acts as the system operator, the Federal Customs Service (FCS) as the controlling body, and data on each vehicle crossing the border enters a common circuit accessible to both agencies.
By design, this should solve several tasks at once: increasing VAT collection, ensuring transparency of the entire chain from the foreign supplier to the final buyer, and making it possible to cut off unconfirmed deliveries at entry rather than sorting them out at the end of the quarter. In addition, customs authorities receive another source of statistical information on the volume and prices of imported goods.
How This Works in Practice
Two calendar days before the planned import of goods, the importer must submit an electronic document to the FTS — it is called the “document on the upcoming delivery” (DUD). This can be done in two ways: through the applicant’s personal service on the tax website (access via an enhanced qualified electronic signature — ECES) or through an electronic document operator from its accounting system. In parallel, the importer makes a security payment — an amount calculated as the estimated VAT on the upcoming delivery, and for excisable goods also excise duty. The payment is credited to the company’s single tax account. If the goods are exempt from the security payment, a DUD is still required, and it can be submitted later — but no later than four hours before the goods are imported into Russia.
The question arises of how to deal with consolidated cargo: the law says that a DUD is issued for goods sent on the basis of one transport (carriage) document. This means that if a truck carries goods under several transport waybills, a DUD is issued for each of them.
The FTS checks the application, and if everything is in order, the document is assigned the status “Secured”, a QR code is generated — in the law it is called a “visualized link”. The data is automatically sent to the FCS. When the truck approaches the Russian border, a mobile customs team scans the QR code, verifies the data from the DUD against the shipping documents and, if they match, allows the vehicle through. After the importer submits an ordinary indirect tax declaration (at the end of the month), the security payment is offset against actual tax obligations. If an excess has formed on the account, it is recorded on the single tax account, but it can be disposed of only after a desk audit of the indirect tax declaration.
When No Security Payment Is Required
The law provides for several categories of persons exempt from the obligation to make a security payment. First of all, these are the largest taxpayers and companies under tax monitoring — that is, businesses with already established and transparent relations with the FTS. Authorized economic operators also do not pay the security payment if the goods are addressed directly to them. Security is also not paid when importing goods exempt from indirect taxes under one of the paragraphs of the EAEU Treaty or under the Tax Code. This includes, for example, import for personal needs, sale to individuals through electronic trading platforms, or transfer within one legal entity. The exemption also extends to residents of special economic zones when importing goods into the territory of border free and special economic zones (FEZ and SEZ). In addition, no security is required for transit between EAEU countries through Russia and for the import of leasing items if, under the contract, ownership of them passes to the lessee.
For agricultural imports, this means the following: large federal chains, top-tier agroholdings and processors included in the register of largest taxpayers pass through the system “idle” — that is, submission of a DUD is mandatory, but the security payment is not. Medium and small importers of food products and agricultural products, such as a regional cheese distributor, a supplier of raw materials to an individual feed mill, or a wholesale supplier of fruit and vegetables, go through the full procedure with actual freezing of funds on each delivery.
Pilot and Official Launch
Between the announcement of the reform and its mandatory application, a pilot regime was in effect — from 6 April to 27 May 2026. During the pilot, participation was voluntary, no security payment was required, and the FTS collected feedback through the website and the Max messenger. From 1 June, the system operates in normal mode: submission of a DUD, payment of the security payment and assignment of a QR code are mandatory for each delivery.
As for the security payment, a government resolution established a deferral for its application — it became mandatory from 1 July, but when importing goods through the Russian-Belarusian section of the state border, where the supplier is a Belarusian organization or individual entrepreneur, the deferral applies until 31 October.
For those who missed the pilot, June and July became the period of the first practical encounter with the system. Based on the experience of similar digital rollouts (for example, mandatory marking or a traceability system), most errors are identified in the first six to eight weeks of operation, and the cost of an error here is measured not in fines but in trucks stopped at the border.
What Happens If Something Goes Wrong
The main legal consequence of the new system is that the absence of a confirmed DUD with a QR code becomes grounds for refusing to admit a vehicle with goods into Russia. This is not a fine, not a sanction in the usual sense, but a direct ban on entry. A carrier that finds itself at the border without the correct DUD status or QR code is issued an order to leave back within three hours — a separate norm is fixed in the SPOT rules. The same consequences arise when the actual quantity of goods in the truck exceeds that declared in the document. The situation is aggravated by the fact that QR code control at the border is selective, and mobile customs teams operate not only in border areas but also on major highways inside the country — complying within three hours with an exit order received somewhere in the Urals will be very difficult.
For the importer, the consequences are material. A truck turned back at the border means not only lost time and the cost of return transport, but also breached obligations under the contract with the supplier, penalties under logistics contracts, and the risk of spoilage of perishable goods. For dairy products, chilled meat, fresh fruit and vegetables, a one-day delay already becomes commercially significant. In the future, administrative liability will be added to direct losses: for failure to submit a DUD, for failure to make the security payment, and for submitting inaccurate information. It is quite likely that new offences will appear in the Code of Administrative Offences (CAO) as practice accumulates.
The carrier bears separate risks. Refusal to present a QR code at the request of a mobile customs team may be classified under two existing articles of the CAO — disobedience to a lawful order of an official of a controlling body and failure to provide information, respectively. The fines under them are small, but special norms with more serious liability may be introduced into the CAO. At the same time, the carrier, as a rule, does not have access to the applicant’s personal account and depends on whether the importer has transmitted the correct QR code to it. This changes the allocation of liability in logistics chains, and this is worth discussing separately.
What Will Change in the Work of an Agro-Importer
The first and most noticeable change is that the planning horizon shrinks. The rule “two calendar days before import” means that the application must be submitted not “when the truck is already moving” but strictly in advance. For short routes from Belarus or Kazakhstan, where the leg may take a day or less, this requires rebuilding logistics processes: the DUD is formed at the moment the supplier is ready to ship, not at the moment the vehicle approaches the border. Any change in the composition, weight or route of delivery after the document has been submitted requires correction — and here the electronic document operator through which updates pass becomes key.
The second change is that the security payment becomes a separate working capital item. For each delivery, money equivalent to the upcoming VAT and excise duties is frozen on the company’s single tax account. For an importer that previously paid VAT post factum for the whole month under one declaration, this becomes a prepayment regime for each truck. For large wholesale suppliers with dozens and hundreds of deliveries per week, the cash gap risk must be calculated in advance — and built into the financial model. This will be especially painful for seasonal importers who bring in vegetables and fruit in summer or fertilizers before sowing: the peak need for working capital coincides with the peak volume of DUDs.
The third change is that internal procedures for working with suppliers and carriers will have to be rewritten. Who is responsible for timely submission of the DUD? Who calculates the amount of the security payment? How is the QR code transmitted to the carrier — by email, via messenger, through the electronic document flow system? What should be done if the document status changes after the vehicle has already departed? These questions did not exist before — now they must be set out in supply and carriage contracts, otherwise, at the first failure, the parties will end up in a dispute over who is to blame for the truck turned back at the border.
Thus, SPOT is not another technical add-on but a change in the rules of the game for everyone who brings goods from the EAEU to Russia by road. For the largest taxpayers and AEOs, the changes amount to new document flow; for everyone else, this is a shift in the financial model toward prepayment of taxes and a rebuilding of logistics processes within the horizon of “two calendar days before the border”. The next two to three months will be a period when each importer either develops a streamlined process for working with the DUD and the security payment or begins to accumulate trucks turned back at the border, contractual sanctions and, possibly, CAO fines. Unfortunately, the market does not provide for a third scenario.