From 2026, the tax authorities and banks will interact directly with each other through a unified system of interdepartmental electronic interaction. TC tax consultant Zauri Ormotsadze told EZh-Jurist about what this means for taxpayers.

In the last few years, cooperation between tax authorities and banks is gradually shifting to an automated system of interaction, which, among other things, is accompanied by the use of new joint technologies. As noted by Daniil Egorov, Head of the Federal Tax Service of Russia, during a panel discussion at an extended meeting of the board of the Federal Tax Service of Russia, it is precisely such solutions that allow businesses to immediately start earning, rather than thinking about how to customize interaction with the state.

As of January 1, 2026, the Central Bank of the Russian Federation's Instruction No. 6952-U of 25.11.2024 (the Instruction) comes into force, which establishes a new procedure for the exchange of documents/information between banking institutions and the Federal Tax Service of Russia. The previously effective Regulation of the Bank of Russia No. 440-P dated November 6, 2014 shall be deemed null and void.

This Instruction establishes:

• the procedure for the Federal Tax Service of Russia to send to banks (1) decisions to suspend operations on a taxpayer's accounts with a bank, (2) to cancel suspensions of operations on a taxpayer's accounts, and for banks to send to the Federal Tax Service of Russia (3) messages from banks on the non-execution (partial execution) of tax authorities' instructions in electronic form, (4) messages containing information on a taxpayer-organization's cash (precious metals) balances in bank accounts;
• the procedure for determining the date and time of receipt by a bank of a tax authority's decision to suspend operations on the taxpayer-organization's accounts with a bank and transfers of its electronic funds in electronic form.

As follows from the explanatory note to the Decree, the purpose of these innovations is to optimize interaction between banks and tax authorities, namely to transfer banks and tax authorities to direct interaction without using the infrastructure of the Bank of Russia.

Currently, the document exchange process consists of several stages involving the Bank of Russia's Information Technology Center (CIT of the Bank of Russia) and informatization departments of the Bank of Russia's territorial institutions (TU of the Bank of Russia).

The CIT of the Bank of Russia checks the documents received from the Federal Tax Service of Russia and further transfers them to the TU of the Bank of Russia, which sends the documents of the tax authorities to the relevant branches of the bank. The change in the approach to interaction will help speed up the process of information exchange and minimize legal risks associated with the transfer of documents.

It is planned that tax authorities and banks will interact through a unified system of interdepartmental electronic interaction (SMEV), and the documents transmitted by tax authorities and banks will be signed with an enhanced qualified electronic signature (UKEP).

One important aspect of the Guidelines is the establishment of clear rules for determining the date and time when banks receive instructions from tax authorities. This is necessary in order to avoid contentious situations involving delays in the execution of tax authorities' requests. The Decree provides that the date and time of receipt of a document shall be recorded automatically at the moment of its receipt in the CMES. However, it should be noted that upon receipt of documents in the CMES, banks and the Federal Tax Service of Russia must, within the day following the receipt of the documents, verify the documents for compliance with the established formats, after which a notification is sent either on acceptance of the documents or on non-acceptance of the documents, indicating the date and time of completion of the verification. 

It is presumed that this approach will ensure transparency and unambiguity in determining when the execution of a tax authority's order begins.

Thus, the amendments will reduce time spent on processing documents, minimize errors and ensure prompt execution of decisions of tax authorities, which will help taxpayers to take timely action to protect their rights and interests.