Court Clarified How to Calculate the Deadline for Correcting EFS-1 Reports

In its ruling dated 09.12.2025 in case No. A45-2069/2025, the West Siberian District Arbitration Court reviewed a dispute on how to calculate the deadline for correcting EFS-1 reporting errors identified by the SFR.

The SFR found errors in the EFS-1 report and gave the company 5 days to correct them. The company submitted a corrected report on the 6th day after receiving the notice and was fined.

The fund argued that the 5-day period should be counted from the date of receipt of the notice, while the company argued it should be counted from the following day.

What did the court decide?

• The period for correcting errors is 5 business days from receipt of the SFR notice (Part 5, 25, Article 17 of Federal Law No. 27-FZ dated 01.04.1996).
• Since the law on individual accounting does not directly establish deadline calculation rules, Articles 6.1 and 6.2 of the Tax Code of the Russian Federation apply: the period starts on the day following the date or event that determines its beginning.
• The court concluded that the 5-day period must be counted from the day after receipt of the SFR notice. Therefore, the company did not miss the deadline.

Practical takeaway

When you receive an SFR notice about EFS-1 errors, count 5 business days starting from the day after the document is received. This is the court’s official position for disputes with the fund.