Deferral of Import VAT in Russia: Customs Monitoring Is Open to Almost Everyone, but the Benefit Stays with AEOs

Two regulations and two groups of participants

We’ve already discussed how the monitoring experiment itself has changed in our article on Resolution No. 1188, and how Russian companies should prepare their records in our monitoring guide. Here, we’ll just add one point: the connection between monitoring and the Russian recipient’s funds.

Russian Government Resolution No. 1188 of September 18, 2026, extended the pilot program through March 31, 2029, and opened it to Russian legal entities that are declarants and are not classified as high-risk. Applications may be submitted until September 30, 2028. The document takes effect 30 days after its publication on September 18—that is, on October 19, 2026—and until then, the previous conditions remain in effect. According to industry media reports, more than 13,000 participants in foreign economic activity now meet the criteria.

Russian Presidential Decree No. 263 of April 20, 2026, is a separate VAT deferral pilot program that will run through June 30, 2027. It does not change the monitoring rules but adds a financial incentive to them, and the scope of its participants is already more clearly defined than that of the monitoring program.

Who is eligible for a VAT deferral and under what conditions

The deferral is granted for up to three months from the date of release of goods for domestic consumption; no interest is charged on it. To qualify, a Russian company must, as of the date of application, simultaneously meet the following conditions set forth in the decree:

• participate in the customs monitoring pilot program;
• be subject to the general tax regime;
• have no overdue liabilities for customs payments, special, anti-dumping, and countervailing duties, interest, and penalties, as well as any unpaid fines under a customs authority ruling that has entered into force;
• there are no pending criminal cases against the founders or executives that fall under the jurisdiction of the customs authorities and involve unrecovered damages;
• there are no bankruptcy cases;
• General security for the payment of VAT has been provided—either a cash deposit or a bank guarantee valid for at least three months after the payment due date.

Recipients of the goods must apply the general taxation regime, and such goods may be sold to individuals who are not sole proprietors or to organizations operating under the general regime. This means that a Russian buyer who takes advantage of the deferral may limit the scope of its customer base, and a foreign supplier should take this into account when discussing the volume and intended use of the goods. The application must be submitted electronically to the Federal Customs Service of Russia no later than June 15, 2027.

If, following a post-release inspection, it is determined that the conditions were violated, the date of release of the goods is considered the due date for VAT payment. The benefit of the deferral does not simply disappear but turns into a delinquency.

What the deferral means in monetary terms

For a Russian buyer, this is a working capital issue: VAT on imports from third countries is paid prior to release, meaning the funds are tied up long before the sale. Here’s a hypothetical example for illustration. A shipment worth 100 million rubles at a 22% VAT rate results in 22 million rubles in import tax. A three-month deferral, assuming a cost of borrowed funds of 15% per annum, saves approximately 825,000 rubles on such a shipment (22 million × 15% × 3/12).

This is a conservative estimate: the cost of collateral must be deducted from it. A bank guarantee or collateral for three months past the payment due date is not free, and for companies with limited access to banking products, the benefit will be significantly smaller. The calculation depends on the buyer’s interest rate, the shipment value, and the bank’s terms, so the figures above are merely illustrative.

The deferral applies to the tax levied by customs authorities. When importing from EAEU countries, VAT is paid through the tax system, so this mechanism does not apply to such shipments.

The timeframes do not align

The monitoring period has been extended until spring 2029, while the VAT deferral pilot program ends on June 30, 2027. If a Russian buyer participates in the monitoring program for financial benefit, they should keep in mind that the tax relief will last for a shorter period than the monitoring obligations. It is not yet known whether the decree will be extended. The Ministry of Finance and the Federal Customs Service of Russia must submit a report on the results of the pilot program by August 30, 2027—that is, after it has already ended. Therefore, foreign suppliers should not count on payment terms based on a VAT deferral remaining in effect after June 30, 2027.

For the average Russian importer who is not a authorized economic operator (AEO), the practical conclusion is this: joining the monitoring program provides a different audit regime, but not additional funds. They should decide whether to enroll based on the administrative burden and audit risk, rather than on VAT calculations.

What an importer should do

1. Check with your Russian buyer to see which group they belong to: do they have AEO status, or are they on the list of systemically important organizations? If not, you shouldn’t factor the VAT deferral into your calculations.
2. If they do have this status, keep in mind that the benefit depends on the buyer’s borrowing rate and the cost of the bank guarantee, and the pilot program is only in effect until June 30, 2027.
3. Expect the buyer to verify the other conditions of the decree: general taxation regime, no outstanding debts or criminal cases, a sales chain limited to individuals (not sole proprietors) and organizations under the general taxation regime. This may influence how they plan their purchases from you.
4. If the buyer plans to participate in the monitoring program, they will assess their accounting system: remote customs access to it is the main task involved; details are available in our guide. A foreign supplier should be prepared for the buyer to request delivery data and documents in a format convenient for accounting purposes.
5. If the buyer joins the monitoring system to reduce the number of post-release inspections, keep in mind: there are exceptions to customs’ waiver of inspections, so prompt responses to requests remain mandatory. Shipping documents must be complete and consistent so that the buyer can quickly respond to customs inquiries.

Frequently Asked Questions

Will a typical Russian buyer receive a VAT deferral if they are included in the monitoring program?
No. The decree requires that the company be included in the AEO registry and/or the list of systemically important organizations; participation in the monitoring program is only one of the conditions.

What is the duration of the deferral?
Up to three months from the date of release for domestic consumption; the pilot program itself runs through June 30, 2027, and the application must be submitted no later than June 15, 2027.

Does the deferral apply to imports from the EAEU?
It applies to VAT collected by customs authorities upon import. Taxes are paid differently for imports from EAEU countries, so the deferral does not apply to such shipments.

Does a Russian buyer need to submit an application for monitoring right away?
The deadline is September 30, 2028, but the new version of the regulation takes effect on October 19, 2026. Only those who need a VAT deferral until 2027 need to act quickly.