06.10.26
Publication
Mandatory transition to electronic documents for road transport
On 1 September 2026, certain provisions of Federal Law* No. 140-FZ dated 7 June 2025 “On Amendments to the Federal Law ‘On Transport and Forwarding Activities’ and Certain Legislative Acts of the Russian Federation” (“Federal Law No. 140-FZ”) entered into force. These provisions require transport documents used in road haulage to be issued in electronic form.
1. What has changed in transport regulations?
Previously, transport documents could be issued electronically on a voluntary basis. The governmental IT system for exchanging electronic transport documents has been in operation since 1 September 2022, and for four years companies could choose between paper and electronic formats.
From 1 September 2026, transport documents must be issued in electronic form.
This transition to electronic documents forms part of a broader reform of transport regulations that has developed consistently over the past several years.
In addition to this transition, the reform clarified and expanded the obligations of forwarding agents. They are now required:
2. How should electronic transport documents be issued?
1. What has changed in transport regulations?
Previously, transport documents could be issued electronically on a voluntary basis. The governmental IT system for exchanging electronic transport documents has been in operation since 1 September 2022, and for four years companies could choose between paper and electronic formats.
From 1 September 2026, transport documents must be issued in electronic form.
This transition to electronic documents forms part of a broader reform of transport regulations that has developed consistently over the past several years.
In addition to this transition, the reform clarified and expanded the obligations of forwarding agents. They are now required:
- to be included in a special register*;
- to identify goods whose circulation is prohibited or restricted, and ensure compliance with the requirements applicable to the carriage of such goods;
- to obtain the necessary information about the goods before commencing performance of the contract;
- to notify the competent authorities if goods whose circulation is prohibited or restricted are identified and the client does not hold the relevant special permit;
- to store information about carriage operations in data centres located in Russia.
2. How should electronic transport documents be issued?
(Annex to Order* No. 262 of the Russian Ministry of Transport dated 1 June 2026)
(Annex to Order* No. 115 of the Russian Ministry of Transport dated 3 April 2026)
3. How does the IT system for exchanging electronic transport documents operate?
Electronic transport documents are managed through the state information system for electronic transport documents (the “E-TD GIS”).
The parties involved in transportation do not interact directly with the E-TD GIS. To exchange electronic documents, they must select an operator included by the Russian Ministry of Transport in a special register* and enter into an electronic document management agreement with that operator.
The parties involved in transportation use the operators’ infrastructure to prepare and sign documents and exchange them with counterparties. The operator then transmits information about the documents and the relevant stages of transportation to the E-TD GIS.
An electronic transport document is not an electronic copy of a paper document. Instead, it comprises one or more exchange files in XML format. Depending on the type of document, the exchange files may contain information about the parties involved in transportation, the goods, the vehicle, the route and other relevant matters.
4. What should be considered and what steps should be taken?
If road transport forms part of your logistics operations, we recommend taking the following steps:
(1) analyse the current processes and identify transport and forwarding documents that must now be issued in electronic form;
(2) choose an operator included in the special register maintained by the Russian Ministry of Transport and connect to that operator’s infrastructure;
(3) inform counterparties about the transition to electronic transport documents and, where necessary, amend the relevant contracts and internal procedures;
(4) provide employees with the necessary electronic signature tools and machine-readable powers of attorney;
(5) provide employees with access to the operator’s infrastructure and train them to work with electronic transport documents.
*In Russian
(Annex to Order* No. 115 of the Russian Ministry of Transport dated 3 April 2026)
3. How does the IT system for exchanging electronic transport documents operate?
Electronic transport documents are managed through the state information system for electronic transport documents (the “E-TD GIS”).
The parties involved in transportation do not interact directly with the E-TD GIS. To exchange electronic documents, they must select an operator included by the Russian Ministry of Transport in a special register* and enter into an electronic document management agreement with that operator.
The parties involved in transportation use the operators’ infrastructure to prepare and sign documents and exchange them with counterparties. The operator then transmits information about the documents and the relevant stages of transportation to the E-TD GIS.
An electronic transport document is not an electronic copy of a paper document. Instead, it comprises one or more exchange files in XML format. Depending on the type of document, the exchange files may contain information about the parties involved in transportation, the goods, the vehicle, the route and other relevant matters.
4. What should be considered and what steps should be taken?
If road transport forms part of your logistics operations, we recommend taking the following steps:
(1) analyse the current processes and identify transport and forwarding documents that must now be issued in electronic form;
(2) choose an operator included in the special register maintained by the Russian Ministry of Transport and connect to that operator’s infrastructure;
(3) inform counterparties about the transition to electronic transport documents and, where necessary, amend the relevant contracts and internal procedures;
(4) provide employees with the necessary electronic signature tools and machine-readable powers of attorney;
(5) provide employees with access to the operator’s infrastructure and train them to work with electronic transport documents.
*In Russian
Authors:
- Vsevolod Tyupa, Partner, vsevolod.tyupa@sl.legal
- Ivan Zaraiskiy, Senior Associate, ivan.zaraiskiy@sl.legal
- Violetta Gavrilova, Paralegal, violetta.gavrilova@sl.legal
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