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Who submits the SZV-M: the accountant or HR manager?

Who submits the SZV-M: the accountant or HR manager?

PUBLICATIONS \ 18.02.2021

Information about insured persons (Russian acronym SZV-M) is a report that is required to be formed by all employers who have employees on their staff. The procedure for filling in such a report, the list of errors that can be made when filling it in, and the scope of administrative liability for mistakes made are reflected in the relevant legislative acts as well as in official explanations of the supervisory authorities. 

However, the legislation does not specify another matter: who is responsible for submitting such a report to the Pension Fund of the Russian Federation (PFR). On the one hand, the document can be considered akin to accounting reports, because the accounting department more often interacts with PFR bodies on issues of accruing staff salaries. On the other hand, employees of the relevant department are responsible for maintaining personnel records and enter data in a report that accountants usually do not work with.

Acsour’s experts answer who should draw up the SZV-M and submit it to the PFR bodies.


The report consists of four sections:

  1. The company’s reference details of an insured company, specifying its registration number with the PFR, name, taxpayer ID number (Russian acronym – INN) and code of reason for tax registration (Russian acronym – KPP).
  2. The reporting period is the month for which the information about employees is submitted.
  3. The type of form (outgoing, supplemental, or cancelling), the choice of which depends on changes in the scope of information in the document.
  4. Information on insured parties – i.e. employees, specifying their full name, personal insurance policy number (Russian acronym – SNILS), and taxpayer ID number.

The most important section is the fourth, in which data about employees working in the company is entered. In other words, the process of filling in the SZV-M implies close interaction with employees, which is more typical for personnel, since the job duties and obligations of an accountant imply something else – maintaining records through the prism of reflecting business operations. Also, it is possible to highlight other reasons why it is better to have HR managers submit the report:

  • Accountants do not have the obligation to use information about the employee’s INN in their work

For example, a certificate of the amounts of an individual’s income (Russian acronym – 2-NDFL) can be submitted without reflecting the INN. And if such a need arises, then the specified information will have to be clarified either by the employees themselves, or by finding it out on the website of the Federal Tax Service of the Russian Federation in the section “Find out an INN”. To do this, it is necessary to enter the passport data of a working individual.

  • The accountant does not have an employee SNILS

The SNILS is the personal insurance policy number in the system of individual record-keeping of compulsory pension insurance, which the company needs to state in some HR and accounting reports (the SZV-M is not an exception). If the report does not contain the SNILS, the company may encounter a refusal to accept the document. And this is already a sign of incomplete information and the reason for a fine to be imposed.

A hired employee should provide the employer with his or her SNILS confirming the registration in the system. If the employee is not registered in the system, then information about him or her should be submitted to the territorial body of the PFR. Then, in the same department of the PFR, the employer receives a document confirming registration in the system and deliver it to the employee. 

And it is likely that it is the specialist of the HR department who will be the first to have information about the presence or absence of the SNILS and, consequently, about the possibility of including a new employee in the SZV-M.


On the other hand, thanks to records being maintained in automated systems, including the reflection of data about their employees, specialists of accounting and personnel departments will be able to see the personal data of their colleagues. In other words, both the accountant and the HR manager, with access to the system being within their rights, can find the information necessary for their work. Consequently, filling in the SZV-M and submitting it to the PFR will not cause difficulties for an accountant.

In addition, if the accountant’s responsibility statement stipulates an obligation to provide all data on personalized accounting, then an employee of the accounting department should submit the SZV-M report, since this is part of his or her job function (article 57 of the Labour Code of the Russian Federation).

And, of course, the issue of submitting the SZV-M will not arise if the organization has an accountant on its staff who, as a single person, performs the functions of a financial and HR employee.


In any case, no one cancels the imposition of administrative liability for the incorrect preparation of the report. And regardless of who submits such report, the company may face a fine for making mistakes. The amount of the fine depends on the scope of the error. Such error can be:

  1. Incorrectly reflecting information about employees (for example, the absence of information in the report, the presence of records about irrelevant employees, or an incorrectly stated INN or SNILS of an employee).
  2. Late submission of the report.  The deadline for submitting the report is not later than the 15th day of the month following the reporting month.

The amount of punitive sanctions for these types of violations is the same – 500 rubles for each individual in respect of whom errors were made in the report.

  1. Failure to submit the SZV-M in electronic form if the company has such an obligation. If the company employs more than 25 employees, then such report should be submitted only in electronic form, while if there are fewer than 25 people, it is possible to submit the report on paper. The amount of financial sanctions is fixed and amounts to 1,000 rubles, regardless of the number of employees.

Officers who commit such mistakes will be subject to administrative liability under article 15.33.2 of the Administrative Code of the Russian Federation and will be fined 300-500 rubles.


The decision on the appointment of a responsible person for filling in and submitting the SZV-M to the PFR remains with the head of the organization. In addition, the burden of filling in the report can be divided between two departments. This helps specialists to focus on their task and be all the more attentive when reflecting information in the report.

Also, an alternative solution would be to outsource these functions. Specialists of the outsourcing company:

  • focus on the development of your business and take into account the specifics of your activities, thereby freeing up your time and resources for other tasks;
  • will, by dividing the burden between departments, be able to concentrate on filling in your company’s report and start the process of interacting with the PFR if necessary;
  • guarantee the security and confidentiality of information. The majority of the processes in outsourcing include confidential information, and personal data about employees is no exception. Thanks to the safe storage and transfer of data, you do not have to worry about any leak of such data.

Acsour’s specialists take into account all possible risks and organize the process of drawing up documents in such a way as to avoid undesirable consequences in the future.

Ekaterina Lutenko

Internal Auditor