SPOT in the contract: lawyers advise including a QR code as a condition for loading.

Translation. Region: Russian Federation –

Source: KMZ Cargo – KMZ CARGO –

An important disclaimer is at the bottom of this article.

The new SPOT system makes carriers hostage to customer data. Experts advise urgently changing contracts and regulations.

Starting April 1, 2026, a new mandatory procedure for pre-declaration of goods imported into Russia from EAEU countries by road will be introduced. The Confirmation of Expected Delivery System (SPOT) will begin pilot testing and will be fully operational on July 1, with financial guarantees and a ban on importing goods without a QR code, NOVELCO told Logirus.

The system's mechanism is rigorous and consistent. The applicant—the importer or their authorized representative—must generate and submit to the Federal Tax Service a document on the upcoming delivery (DOPP) no less than two days before the planned border crossing. This document contains full details of the transaction, the goods with their TN VED codes, the transport, and the calculation of the security deposit. If the system verifies that the DOPP is completed correctly, and, starting from July 1, 2026, also confirms the reserve funds, it will generate a QR code within 15 minutes. Failure to do so from this date will result in the vehicle being physically stopped at the border.

The most sensitive element for businesses will be the security deposit. Starting in the second half of 2026, to obtain a QR code, it will be necessary to reserve an amount equivalent to the estimated import VAT and excise taxes. This is not a tax, but a temporary blocking of funds in a special account, subject to subsequent offset or refund. The key financial risk lies in the freezing of working capital for the period from the submission of the additional payment order until the completion of customs clearance, according to NOVELCO. Exchange rate risk is added to foreign currency contracts, as settlement is based on the Central Bank exchange rate on the document submission date, not the date of actual import. Several categories of companies are exempt from the security deposit, including major taxpayers, companies subject to tax monitoring, and authorized economic operators, creating a significant competitive advantage for them.

NOVELCO is confident that the new system fundamentally changes the approach to operational planning, eliminating spontaneous delivery scenarios. The main risks for importers are concentrated in three areas: operational, which requires a shift to advance schedule coordination; financial, associated with liquidity pressures; and regulatory, where any discrepancy between the data in the delivery note and the shipping documents leads to the denial of cargo. The situation for carriers is also changing: they effectively become dependent on the correct actions of the customer. NOVELCO lawyers recommend that transportation contracts now stipulate the importer's obligation to provide a valid QR code as a mandatory condition for the commencement of a shipment, in order to avoid delays and financial losses.

Before launching the system, companies must take a number of specific steps. Importers should check their status for exemptions, ensure technical connectivity to the Federal Tax Service or data exchange through an electronic document management (EDM) operator, and revise contracts with suppliers to specify deadlines for transmitting accurate data to the DPP, NOVELCO advises. Assessing the impact of reserve funds on working capital is equally important. Carriers should train drivers to use QR codes and develop internal procedures for handling border denials. NOVELCO specialists recommend beginning test interactions with the system immediately after the launch of the applicant service on the FTS website, which is expected to occur no later than March 30, 2026.

In the first stage, the SPOT will only affect road transport. The inclusion of rail, air, and sea transport is planned no earlier than 2027 and will be regulated by a separate government decision.

As a reminder, the Russian government plans to allocate 16.5 billion rubles from the federal budget for the implementation of a system for confirming the expected delivery of goods in 2026-2028. LR

Read more:http://logirus.ru/nevs/custom_and_after all/spot_in_agreement_lawyers_advise_to_register_KR-code_as_a_condition_of_departure_for_loading.html

Publication date: 02/02/2026

Please note; this information is raw content obtained directly from the information source. It is an accurate account of what the source claims, and does not necessarily reflect the position of MIL-OSI or its clients.