Shipping to Russia: How to Check That Your Buyer's Customs Broker Is on the Register Under the New Ministry of Finance Rules

What changes in the inclusion and removal procedure

Order of the Ministry of Finance of Russia No. 101n of 27 July 2026 was registered with the Ministry of Justice on 8 September 2026 under No. 88180. It sets out the procedure for three actions:

• including legal entities in the register of customs representatives;
• removing them from the register on the ground in subparagraph 3 of paragraph 1 of Article 403 of the EAEU Customs Code;
• amending the register.

Subparagraph 3 of paragraph 1 of Article 403 covers removal at the request of the customs representative itself. In plain terms, the order describes a voluntary exit: the company has decided to stop working as a broker and has applied to be removed. The order covers only this ground of Article 403 and does not describe the others. For completeness, under paragraph 1 of Article 403 a broker is also removed from the register in the following cases:

• failure to fulfil the obligations under subparagraphs 1 and 2 of paragraph 1 of Article 405 of the Code;
• failure to fulfil, or improper fulfilment of, the obligation under paragraph 4 of Article 405 of the Code within the period stated in the customs authority's notice;
• liquidation of the legal entity;
• reorganisation of the legal entity, except in cases established by the legislation of EAEU member states.

The legislation of EAEU member states may also set other grounds. The new order does not regulate these cases. The takeaway for a shipper: a broker can leave the register not only because of violations but also by its own decision. Even a broker with a good reputation is worth checking, and a single status check at the start of the relationship is not enough.

The annexes to the order contain recommended templates of approval sheets for the decisions taken. So the order also covers the internal work of the customs authority: how decisions to include a broker in the register, to remove it or to change its details are prepared and approved.

The main change is who sets the rules. Until now, the procedure was set out in the FCS administrative regulation on the public service of maintaining the register of customs representatives, approved by FCS order No. 1373 of 30 August 2019. Now the Ministry of Finance sets the procedure, and the FCS regulation is to be repealed by a separate FCS order.

The order does not give an exact date of entry into force. It takes effect 30 days after official publication, but not before the FCS order repealing regulation No. 1373 comes into force. Until then, the previous procedure applies. For your shipments, nothing changes overnight. But a broker's status now matters just as much as the paperwork, so find out in advance who will clear your goods in Russia.

Who clears your goods in Russia and what the broker is responsible for

People often talk about a “customs broker licence” or a “customs representative licence”. Legally, there is no separate licence. A company gets customs representative status when it is added to the register. Without this status, it cannot carry out customs operations on a client's behalf.

In short, a broker acts on behalf of and on the instructions of the declarant. In your case, that is your buyer in Russia. The broker prepares and files the goods declaration, submits documents, calculates customs payments, answers customs requests and stays with the cargo during checks and inspections. So the commercial documents you send with the goods end up with the broker, and the broker answers customs' questions about them.

Under the EAEU Code, the representative shares liability with the declarant for paying customs duties. That is why a broker must meet requirements to get on the register, including security for this obligation and civil liability insurance.

We explain the broker's role and when you cannot do without one in “Customs broker: who it is and when you need its services”. The process from filing the declaration to release is covered in our article on the customs clearance procedure.

In Russia, only a broker listed in the FCS register of customs representatives can clear your cargo on your buyer's behalf

What a broker must meet to get on the register

The Ministry of Finance order describes the procedure. The conditions for getting on the register are set by Article 402 of the EAEU Customs Code and by national legislation. Each condition protects either the client or the state budget. Knowing what stands behind broker status helps you judge who is handling your cargo.

• Civil liability insurance. The broker must have an insurance contract covering its civil liability in case it damages the property of the persons it represents or breaches its contracts with them. The insured amount is set by the legislation of EAEU member states. In practice, the broker's liability to its client, your buyer, is insured, and so are the goods and contracts behind your deal.
• Security for its obligations. The broker provides security for its obligations as a customs representative in an amount set by the Eurasian Economic Commission. For brokers that work only with exports of goods not subject to export duties, national legislation sets the amount. The representative shares liability with the declarant for customs payments, and the security guarantees them for the budget. This means the broker has confirmed it is ready to answer for the operations it performs on the client's behalf.
• No debts to customs. On the day it applies for inclusion in the register, the company must have no overdue customs payments, special, anti-dumping or countervailing duties, penalties or interest. This is a sign of the broker's payment discipline. But the condition is checked on the day of application, so being on the register does not replace regular status checks.
• Other national requirements. EAEU member states can set additional requirements. For example, the law may require the broker to employ at least two people who hold a certificate of meeting the qualification requirements. For you, this means specialists with confirmed qualifications prepare the declaration based on your documents.

A company that does not meet these conditions will not get on the register. So it cannot represent your buyer at customs as a customs representative.

How to check your buyer's broker

The check takes a few minutes. It is worth repeating before every new contract and before every large delivery. Your buyer is the one who contracts the broker, but you can ask for the details and check them yourself.

1. Ask your buyer for the broker's details. You need the full name of the legal entity, its INN (Russian taxpayer number) and its number in the register of customs representatives.
2. Find the company in the FCS register. The register is published on the service's official website. Check the name, INN and number, and make sure the company has not been removed. A broker's website, a directory or reviews do not replace this check. The only reliable source is the register.
3. Ask about the buyer's contract. The contract for customs representative services must be with the legal entity that is on the register. The register number in it must match the one you found.
4. Find out who will appear in the declaration. Box 54 of the goods declaration shows the representative and its contract with the declarant. It should name the same company your buyer works with. Also make sure the buyer and consignee details in your commercial invoice, packing list and supply contract are the same as those the buyer gives to the broker.
5. Be careful if you hear “we'll clear it through a partner”. If one company files the declaration while the contract and payment go through another, it is hard to tell who is responsible when something goes wrong. Requests for your documents may also reach you through several hands.

iCustoms Logistics LLC has been on the FCS register of customs representatives under No. 1636 and has worked as a customs representative since 21 July 2023. You can verify the entry in the FCS register. We handle customs clearance at any customs post, from equipment and machinery to electronics and home appliances, and can also take care of delivery. We state our register number in the contract, so it can be checked before work starts. If your buyer in Russia is looking for a broker, you can refer them to us.

Warning signs: a broker or an intermediary

Some intermediaries present themselves as brokers. They take the order and the payment, but a different company files the declaration. You can tell the two apart from documents your buyer already has or should request before work starts. As a shipper, you will not see all of them, but you can ask your buyer about each point.

One of these signs is enough to ask the broker a follow-up question. If there are several, it is safer to choose another provider. Agree on this with your buyer before the goods are dispatched.

Hypothetical example: the cheapest “broker”

This is a made-up situation for illustration. It does not describe a real client or a real company.

A manufacturer ships a batch of equipment to a buyer in Russia. The buyer asks several “brokers” for quotes and picks the cheapest. The manager replies quickly, promises clearance without delays and sends the contract and invoice from their own company. There is no register number in the contract, but the buyer does not notice.

The cargo arrives, the declaration is filed, and customs asks for additional documents. Only now does it turn out that box 54 names a completely different company. It is a customs representative the buyer has never dealt with directly. This representative received documents and instructions from the intermediary and redirects every question there. The intermediary answers late and keeps referring to its “partner”. While the parties work out who prepares the reply to customs and who is responsible for the declared information, the cargo sits in a temporary storage warehouse and storage costs grow. For the manufacturer, the delivery is not completed on time. If some of the requested documents have to come from the supplier, the request travels through the whole chain: buyer, intermediary, representative.

What went wrong:

• no one checked whether the company in the contract was on the FCS register;
• the contract and payment went through one company, while another filed the declaration;
• price was the deciding factor, and no one asked “who will file the declaration” before the shipment.

How the check from this article would have prevented the problem. A search of the register would have shown that the company offering the contract was not on it. Asking “which company will appear in box 54” would have revealed the real representative before signing. The buyer could then have contracted directly with a registered broker or found another provider. Either way, when customs made its request, it would have been clear who was responsible and who would prepare the answer. Savings on broker fees are easily lost while the cargo sits waiting. For the shipper, one question to the buyer before dispatch would have exposed the risk: who will clear the goods, and what is their register number?

What to do as a shipper

1. Before your next shipment, ask your buyer which broker will clear the goods: legal name, INN and register number. Check the company in the FCS register and keep a dated screenshot or extract.
2. Ask the buyer to confirm that their contract is with the same legal entity that files the declaration and that the contract states the register number.
3. Check that the buyer and consignee details in your commercial invoice, packing list and supply contract match. Send the documents in advance, so the broker can prepare the declaration and answer customs requests without waiting for you.
4. If the broker reports a reorganisation or a change of name or address, ask the buyer to confirm that the changes are in the register. This matters most for shipments already in transit.
5. Agree with the buyer who will file the declaration if the main representative cannot continue: a second broker or the buyer's own specialist with an electronic signature. Also agree in your supply contract who pays for storage if the goods are held at the border.
6. Watch for the FCS order repealing regulation No. 1373. The new procedure cannot start before that order takes effect, and until then the previous procedure applies.

FAQ

Does my buyer need a customs licence to clear the goods itself?
No. The declarant has the right to file the declaration itself. Only a company that provides customs representative services to others has to be on the register. A buyer that clears goods on its own is not a red flag.

Do I, as a foreign supplier, need to be on this register?
No. Only a company that provides customs representative services to others has to be on the register. The order sets out procedures for the register and creates no new obligations for importers or suppliers.

What happens to my shipment if the broker is removed from the register?
The company loses the right to act as a customs representative. Clearance that is still in progress will have to be handed over to another broker, or the buyer will have to declare the goods itself. Meanwhile, the cargo waits in temporary storage. So agree on a backup plan with your buyer in advance.

Does anything change in my current contracts or documents?
The order sets out the procedure and introduces no new obligations or documents. But it is a good reason to check your buyer's broker against the register and make sure its details are up to date.

How often should the broker's status be checked?
At least before every new contract and before every large shipment. It is also worth checking whenever the broker reports a reorganisation or a change of name or address, and whenever an unfamiliar company appears in the shipment documents. Keep a dated screenshot or extract, so you can later show what the register said on that date.

What should I ask if the broker has changed its details?
Ask the buyer to confirm that the changes are already in the register, and check the new details on the FCS website: name, INN and register number. Find out which company will appear in box 54 for shipments already in progress. The new Ministry of Finance order describes how the register is amended. What matters for you is the result: the details in the register, in the buyer's contract and in the declaration must match.

Does this apply to shipments to other CIS countries?
The order is a Russian document and applies to the register kept by the FCS of Russia. The basic conditions for customs representatives come from the EAEU Customs Code, and member states' legislation may add its own requirements. For deliveries to other EAEU countries, check the broker's status under the rules of the country where the goods are declared.

Expert opinion

Yaroslav Loginov — logistics and customs clearance expert with 40 years of experience.

“The most common mistake importers make is not choosing the wrong broker. It is checking the broker only once, at the first contract, and then working on autopilot for years. Over that time, the company's name, address or structure may change, while the contract stays the same. A register check takes minutes, and I recommend doing it at least before every large shipment.

The second typical mistake is a setup where the contract is with one company and another company files the declaration. As long as everything runs smoothly, nobody notices. But when the declaration has to be corrected or there is a post-release audit, someone has to work out who is responsible for the information in each box and for any additional payments. Build in time to bring the contract and the actual working setup into line before the shipment, not during it.”

Summary

Russia's Ministry of Finance has approved a new procedure for three things: adding legal entities to the register of customs representatives, removing them under Art. 403(1)(3) of the EAEU Customs Code, and amending the register. It will replace the 2019 FCS regulation and will take effect no earlier than that regulation is repealed. Clearance rules and the documents required from you as a shipper stay the same. It is still a good moment to find out which broker will clear your goods in Russia, check it against the register and agree a backup plan with your buyer. Send us a request, and we will look at your specific cargo.