From 1 September 2026, the technical conditions for accepting reports submitted to the Social Fund of Russia (Социальный фонд России; SFR), Russia’s state social insurance fund, will change. The qualified electronic signature certificate (квалифицированный сертификат электронной подписи) used to sign reports must contain the “Key Agreement” («Согласование ключей») attribute — keyAgreement. A valid certificate without this parameter may prove insufficient: the absence of the attribute is grounds for refusing to accept a report.
What is changing in the HR and reporting process
The SFR will verify the presence of keyAgreement in the qualified electronic signature certificate. This attribute defines the scope of use of the electronic signature key.
The requirement applies to organizations and individual entrepreneurs that submit reports to the SFR using a qualified electronic signature. It also applies to heads of branches and representative offices of foreign organizations in Russia.
For a company, this is not a change to the composition of reporting, but an additional technical verification of the tool used to sign it. Therefore, the risk arises at the submission stage: a report may not be accepted if the certificate used does not contain the required attribute.
How to establish internal controls within the company
First, it is necessary to determine exactly which certificate is used to sign reports. This is especially important when reports are prepared by the accounting department, while the qualified electronic signature is issued to the director or an authorized person.
The check should not be limited to confirming that the signature is valid: it is necessary to ensure that keyAgreement is specified in the certificate. If the parameter is absent, the procedure for replacement or reissuance should be clarified with the certification authority (удостоверяющий центр) or the EDI operator (оператор ЭДО) through which the submission is made. A certification authority issues electronic signature certificates; an EDI operator provides electronic document interchange services.
In practice, it is useful to designate a person responsible for the check and communicate the result to employees who submit reports. This will enable the company to replace the certificate in advance and verify its use in the working software.
When to conduct the check and what risk to consider
The requirement applies from 1 September 2026. Certificates should be checked and, if necessary, replaced before the first report submitted to the SFR after this date.
If keyAgreement is absent, the SFR will refuse to accept the report. This may result in the late submission of mandatory information and risks associated with missing reporting deadlines.
The source information does not specify the exact procedure for checking the attribute and reissuing the certificate. It must be clarified with the certification authority or the EDI operator.
What to check
- Determine which qualified electronic signature is used to sign reports submitted to the SFR.
- Check whether the certificate contains the “Key Agreement” («Согласование ключей») attribute (keyAgreement).
- Appoint an employee who will confirm the result of the check and oversee subsequent actions.
- Clarify with the certification authority or EDI operator whether the current certificate needs to be reissued.
- If replacement is necessary, obtain a new certificate before the first submission of reports to the SFR after 1 September 2026.
- Check that the new qualified electronic signature works in the reporting software or with the EDI operator.
- Inform the accounting department and other employees who submit reports about the new requirements.