GosLog, the forwarder register and mandatory electronic transport documents from 1 September 2026
In 2026 freight forwarding in Russia became regulated: only forwarders entered in the state register on the GosLog platform may operate, and from 1 September transport documents within Russia must be electronic. Here is what changed, which dates have passed and what it means for a shipment to your Russian customer.
In brief
- ✓The forwarder register on the GosLog platform has operated since 1 March 2026: registration is mandatory for all companies and sole traders providing freight forwarding services (Federal Law No. 140-FZ of 07.06.2025, Government Decree No. 173 of 20.02.2026).
- ✓Companies already operating on 1 March 2026 had 60 calendar days to file a notification — the deadline expired on 30 April 2026.
- ✓Operating without registration falls under Article 11.14.3 of the Russian Code of Administrative Offences: fines of 100–300 thousand roubles for legal entities, 500 thousand – 1 million roubles for a repeat offence. Cases are heard by Rostransnadzor.
- ✓From 1 September 2026 electronic transport documents become mandatory: the consignment note (ETrN) and transport order for road, the air waybill, the rail waybill, as well as the forwarding instruction, forwarder’s receipt and warehouse receipt.
- ✓The exchange runs through the state EPD information system (GIS EPD) via operators accredited by the Ministry of Transport — there were 12 as of March 2026.
- ✓The requirement applies to carriage within Russia. On the cross-border leg CMR (road), AWB and e-AWB (air) and CIM/SMGS waybills (rail) continue to apply.
- ✓Next stage: a carrier register from 1 March 2027 for vehicles over 3.5 tonnes.
Checked against current regulations on 20 August 2026
Rates, deadlines and lists change — we confirm what applies to your shipment on the date of dispatch.
What changed: from a free market to a register
Until 2026 freight forwarding in Russia was not licensed and needed no special authorisation: any registered business could act as a forwarder. Federal Law No. 140-FZ of 07.06.2025 rewrote the core law No. 87-FZ “On freight forwarding” and introduced a state register of forwarders.
The register is kept on the GosLog platform. The system is operated by the Ministry of Transport, while the register and supervision are assigned to Rostransnadzor. The registration procedure is set by Government Decree No. 173 of 20.02.2026.
Registration is mandatory for all companies and sole traders providing freight forwarding services, whether or not they take possession of the cargo or only arrange the transport. Classic forwarders and logistics intermediaries working on an agency basis are both covered.
To be registered, a company must meet several conditions: no more than two administrative offences in forwarding over the last year, no outstanding criminal record for economic crimes on the part of its head, and accurate information in the filing.
Dates that have already passed
The register started on 1 March 2026. Companies operating on that date had 60 calendar days to file a notification — that period expired on 30 April 2026. New market entrants file before they start providing services.
From 1 March 2026, operating without being entered in the register is punishable under Article 11.14.3 of the Code of Administrative Offences: 100 to 300 thousand roubles for legal entities, 500 thousand to 1 million roubles for a repeat offence, with separate amounts for officials. In addition to the fine, a ban on providing forwarding services is applied.
The next milestone is 1 September 2026, when mandatory electronic document exchange begins. And another — 1 March 2027 — when a similar register of carriers starts for vehicles with a maximum permitted weight over 3.5 tonnes.
Mandatory electronic transport documents from 1 September 2026
From 1 September 2026 transport documents are issued electronically. For road transport these are the consignment note (ETrN) and the transport order; for air, the air waybill; for rail, the rail waybill.
A separate group covers forwarding on any mode: the forwarding instruction, the forwarder’s receipt and the warehouse receipt. For the cargo owner this means that exchanging scans by email is no longer a sufficient way of documenting the relationship with a forwarder.
The exchange does not run directly but through the state information system for electronic transport documents (GIS EPD). Between the parties and the system sit operators accredited by the Ministry of Transport: there were twelve as of March 2026, and the ministry publishes the current list. Each party signs its part of the document with a qualified electronic signature, after which the signed document appears in the shared system.
Practical conclusion: connecting to an e-document operator and setting up the exchange is not a one-day task. If a company still exchanges paper or scans with its logistics contractor, it should start now, not in the first week of September.
What happens to international transport and CMR
This is the question importers and exporters ask most, and the answer is clear: Law No. 140-FZ applies the electronic document requirement to carriage within the Russian Federation. The cross-border leg is governed by international agreements, and they continue to apply.
On the international road leg the CMR consignment note under the Convention on the Contract for the International Carriage of Goods by Road remains; for air, the AWB and e-AWB; for rail, CIM/SMGS waybills. If the cargo travels on a single international waybill from the foreign shipper to the consignee in Russia, no ETrN is needed for that leg. For you as the exporter, nothing changes on your side: you still hand over the goods against a CMR.
The nuance that costs money comes next. If a foreign carrier takes the cargo to the border or to a temporary storage warehouse, and the goods then travel within Russia on Russian transport under a separate contract, that is domestic carriage, and from 1 September it must be documented with an ETrN via GIS EPD. The same applies to delivery from the terminal to the consignee’s warehouse after release.
For the typical schemes we operate — groupage from Europe, road freight from China, sea containers unloaded at the port — this means the document chain splits: the international part on CMR, the Russian leg and warehouse handling in electronic form.
How to check a forwarder and why it matters to the cargo owner
The forwarder is responsible for its own registration, but the consequences of working with an unregistered contractor also fall on the customer. The first risk is operational: the forwarder may be banned from providing services, and the delivery stops mid-route. The second is tax: expenses under a contract with a counterparty that was not entitled to provide those services become an easy target when the VAT deduction and the justification of costs are audited.
The check takes a few steps. Ask the contractor for its register entry and verify it on the GosLog platform. Find out which accredited EPD operator it is connected to and whether it is ready to issue forwarding instructions and forwarder’s receipts electronically from 1 September. Make sure the details in the contract match the register data.
It is also worth agreeing how the Russian leg will be documented after 1 September: who issues the ETrN, through which operator, and what to do if the system fails. Silence in response to these questions in August 2026 is itself an informative signal about the counterparty’s readiness. If several contractors are involved, check them all at once and record the result: replacing a forwarder mid-delivery costs more than checking in advance.
What this changes when working with us
We work under a freight forwarding contract and exchange documents electronically, so the switch to electronic transport documents does not change the approval process for our clients: the booking, the quote and the closing documents are already electronic.
In the quote and the contract we separate the international leg from carriage within Russia — exactly the distinction required for correct documentation after 1 September: the international part is covered by the CMR, the Russian part by the electronic consignment note.
Our register entry, contract details and the e-document operator we use are provided on request before the contract is signed. This is a normal part of counterparty due diligence and worth requesting from any logistics partner, not just from us.
Key dates and penalties: GosLog and electronic transport documents
| Item | Status |
|---|---|
| GosLog forwarder register | mandatory from 01.03.2026 (Federal Law 140-FZ, Decree No. 173 of 20.02.2026) |
| Deadline for existing companies | 60 calendar days — expired 30.04.2026 |
| Fine for a legal entity operating without registration | 100,000–300,000 ₽ (Art. 11.14.3 Code of Administrative Offences) |
| Repeat offence | 500,000–1,000,000 ₽ |
| Mandatory electronic transport documents | from 01.09.2026 |
| Documents in electronic form | ETrN, transport order, air waybill, rail waybill, forwarding instruction, forwarder’s and warehouse receipts |
| International leg | CMR, AWB / e-AWB, CIM/SMGS — unchanged |
| Exchange operator | GIS EPD operator accredited by the Ministry of Transport |
| Carrier register | from 01.03.2027, vehicles over 3.5 t |
| Supervisory authority | Rostransnadzor |
Frequently asked questions
From what date is the GosLog forwarder register mandatory?
From 1 March 2026. Companies already operating on that date had 60 calendar days to file a notification — the deadline expired on 30 April 2026. New entrants file before they start providing services. The legal basis is Federal Law No. 140-FZ of 07.06.2025 and Government Decree No. 173 of 20.02.2026.
What is the fine for operating without registration?
Under Article 11.14.3 of the Code of Administrative Offences, 100 to 300 thousand roubles for legal entities and 500 thousand to 1 million roubles for a repeat offence, plus a ban on providing forwarding services. Cases are heard by Rostransnadzor.
Which documents must be electronic from 1 September 2026?
For road, the consignment note (ETrN) and the transport order; for air, the air waybill; for rail, the rail waybill. On all modes, the forwarding instruction, forwarder’s receipt and warehouse receipt go electronic. The exchange runs through GIS EPD.
Is an ETrN needed for international transport?
Not on the cross-border leg. Law 140-FZ applies to carriage within Russia, while the international part is covered by a CMR, AWB / e-AWB or CIM/SMGS. But if the cargo travels within Russia on a separate trip by a Russian carrier — for example from the terminal to the consignee’s warehouse after release — that is domestic carriage and requires an ETrN from 1 September 2026.
How can I check whether a forwarder is registered?
Ask the contractor for its register entry and verify it on the GosLog platform, and make sure the contract details match the register. Also ask which accredited EPD operator it uses and whether it can issue forwarding instructions and receipts electronically after 1 September 2026.
What does a cargo owner risk with an unregistered forwarder?
Two things. Operationally, the contractor may be banned from providing services and the delivery stops mid-route. For tax, expenses under a contract with a counterparty not entitled to provide such services become vulnerable when the VAT deduction and costs are audited. A check takes minutes; replacing a forwarder mid-delivery takes weeks.
What if GIS EPD is unavailable at the time of dispatch?
The procedure for technical failures and the list of exceptions are set by Ministry of Transport regulations, and as of August 2026 practice is still developing. The practical advice is to agree the procedure for system outages in the contract in advance rather than working it out while the truck waits.
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