Fiscal accumulator 13 and 36 months. Which one can I use?


The fiscal drive is standardized equipment, the requirements for the characteristics of which are established by law. There are two main types of FN: 1.0 and 1.1, differing in operating periods and supported formats. As of 2020, version FDF 1.0 is considered obsolete. From this moment on, FFD 1.05 becomes the working format. In turn, this version is understood as an intermediate one, and the goal of the improvement is to transfer all cash registers to FFD 1.1.

FN 1.0 supports FFD 1.0 and 1.05 and is available in versions for or 36 months. Type 1.1 supports all existing versions of the FFD and includes models designed for 13/15 or 36 months of operation.

When choosing which fiscal drive is suitable for a particular business using the simplified tax system, you need to focus on the approved Register, which lists certified samples, and on the relationship between the actual period of work and the taxation system used.

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What FN is needed under the simplified tax system in 2019

Federal Law No. 54-FZ in Article 4.1 (clause 6) stipulates for individual entrepreneurs and LLCs on the simplified tax system the need for fiscal accumulators designed for 36 months.

The technical requirements for the cash register itself are not directly related to the taxation system used. However, a business entity needs to have an idea of ​​what type of financial tax is needed under the simplified tax system specifically for its business model.

For 13/15 months:

  • 1.1 isp. 3 (Automatic);
  • 1.1 isp. Av15-2 (Automation);
  • 1.1 isp. 5-15-2 (Event);
  • 1.1 isp. EV15-2 (Evotor);
  • 1.1 isp. Iz15-2 (Meter);
  • 1.1 isp. 6-15-2 (Dreamkas);
  • 1.1 isp. PR15-2 (Pragmatist).

The listed samples are used without additional restrictions in seasonal trade and in the activities of paying agents/subagents. In offline mode and when selling excisable goods, their service life is 410 days.

For 36 months:

  • 1 isp.2 (RIK);
  • 1.1. version 4 (Event).

These fiscal accumulators are used for LLCs on the simplified tax system in the provision of services without restrictions. When selling excisable products or seasonal activities, their validity period is reduced to 410 days. In offline mode, the module is capable of functioning for 560 days. The sample produced by Rick LLC can be used by payment agents on the simplified tax system for 410 days, and the model from Events can be used without restrictions.

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If you use the wrong FN

If the law obliges the subject to apply the FN for 36 months, then theoretically, a cash register with a 13-month accumulator should be subject to liability under Part 4 of Article 14.5 of the Code of Administrative Offenses . However, in practice there are no fines for this yet. The Federal Tax Service explains the details in a letter dated May 23, 2020 No. ED-4-20/ [email protected]

FNs permitted for sale are included in the Federal Tax Service Register . At the time of writing this letter, there was not a single 36-month drive model in the Registry. Thus, the special regime officers, no matter how much they wanted, could not purchase them. Therefore, the Federal Tax Service promised not to impose fines.

And so that there would finally be no grounds for fines, the officials themselves pointed out a legislative loophole. Law 54-FZ states that special regime officers can use a PF for 13 months if their work is seasonal . However, this concept is not disclosed in the legislation of the Russian Federation. The taxpayer can independently determine that the activity is seasonal in nature by stipulating this in a local act.

When to change the fiscal drive for individual entrepreneurs to the simplified tax system

The regularity of device replacement is determined by their cryptographic and design characteristics. Hacking protection eliminates maintainability and the ability to edit information. To prevent sudden blocking, cash register terminals have an early warning function about the need for immediate reinstallation.

Equipment is subject to scheduled replacement in the following cases.

Upon expiration of the key

This period is determined by the nominal operating time, at the end of which it is necessary to replace the media and re-register the cash register, otherwise the device will be blocked and will need to be transferred to the Federal Tax Service to read the data. The processed copy is sent for storage to the accounting department. For a period of five years, it can be requested for verification.

When the internal memory is full

Nominally, any FN 36 is enough for three years of operation of an LLC under the simplified tax system, but in fact its volume accommodates about 200,000-250,000 operations. With intensive use, the memory may fill up much faster and the media will require replacement.

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When switching to another taxation

In most cases, LLCs under the simplified tax system use carriers of the “FN 36” standard. The exceptions are counterparties:

  • engaged in seasonal activities;
  • selling excisable goods;
  • combining OSNO with any of the special tax regimes;
  • working in areas remote from communication networks, the list of which is approved separately in each subject of the Russian Federation;
  • being payment agents/subagents.

In such cases, both for LLCs and individual entrepreneurs, the simplified tax system provides fiscal accumulators for /15 months.

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Fiscal memory

As it was before

Before maintaining online cash registers, KKT recorded all data on EKLZ - electronic tape. For each sale, only the amount was recorded. Once a year, the tape should have been submitted to the Federal Tax Service for inspection.

The EKLZ contained little information - its memory capacity was 4 MB . When it overfilled or expired, you had to contact the service center for a replacement. Large stores had to change the tape quite often.

How did it happen

FN is placed inside the cash register . Its functions are broader - it not only records sales information, but encrypts and transmits it to the server of the fiscal data operator. The latter’s responsibilities include sending fiscal information to the Federal Tax Service.

Sales data is usually transmitted immediately when a receipt is generated or a little later if the connection is not working at that moment. Thus, the tax authority monitors all sales via the Internet, so there is no need to take the fiscal drive for inspection to the Federal Tax Service.

Fiscal storage

The fiscal drive also has a certain validity period and memory resource. When disassembling one of the first drives that appeared on the market, a 256 MB . It turns out that the fiscal drive can hold 64 times more information than its ECLZ.

This does not mean that exactly 64 times more checks will “fit” into the fiscal document, because now there are many new details on the fiscal document. However, it is estimated that the drive can hold approximately 230 thousand receipts and even more. It turns out that it should definitely be enough for a year if you print less than 700 checks a day.

A cash register with FN saves the entrepreneur’s time and reduces maintenance costs. After all, you can replace the drive yourself.

Validity period of the fiscal accumulator for the simplified tax system

This parameter is determined by law based on the specific types of business activities. The use of models not permitted by regulations is considered a violation and is punishable by a fine (Article 14.5 Part 4 of the Code of Administrative Offenses of the Russian Federation). It is also necessary to take into account the restrictions that the manufacturer prescribes in the data sheet. The validity period of the fiscal accumulator for the simplified tax system and other special tax regimes is reduced if:

  • using CCP in offline mode (operating time is 560 days);
  • trade in excisable products (the device is valid for 410 days);
  • cessation of data transfer to the OFD (the nominal operating period of any model is halved).

These rules apply to both legal entities and individual entrepreneurs.

How to choose a fiscal drive for a cash register

Why do you need a fiscal drive?

The fiscal drive is a chip inside the cash register.
It records information about each sale and transmits it to the fiscal data operator (FDO). The operator processes and transmits the data to the tax office - this is how the tax office finds out how much money passed through the cash register. At the old cash desks, EKLZ, a secure electronic control tape, was responsible for information. She wrote down the amount of each sale, and once a year it was taken out of the cash register and taken to the tax office for inspection. Inside the new cash registers there is a FN. It records more information: not only amounts, but also a list of goods. The cash desk transmits this data via the Internet. The tax office receives all the information online, so there is no need to take the FN anywhere.

Both the EKLZ and the FN have a limited service life, but only the employees of the maintenance center could replace the EKLZ, and the FN can be changed independently.

EKLZ's memory was only 4MB - that's like four photos on a phone or half a song in MP3 format. In high-traffic stores, the electronic tape quickly became full and sometimes had to be replaced ahead of schedule. The memory of the fiscal drive is 64 times larger. The FN passport does not say how many checks it can hold, but craftsmen disassembled one of the first FNs and found a 256 MB memory module inside.

Although the memory has increased significantly, the size of the check has also increased. When you buy a FN, expect that it will be enough for about 230-250 thousand fiscal documents: if you print less than 700 checks a day, the FN should be enough for a year.

In old EKLZ models there was 4 MB of memory, in FN - 256 MB, 64 times more. Photo EKLZ - texnokass.ru, photo FN - rikllc.ru

Which FN to choose

Fiscal drives differ in validity period and model.

Validity period of the FN

The validity period of drives can be 13, 13/15 or 36 months. The choice of FN depends on the taxation system and the characteristics of the work. The number of months on the box is the maximum service life of the drive. The actual period depends on the specifics of your work.

If you trade on the general tax system

Entrepreneurs who trade on the general taxation system (GTS) must use a drive with a validity period of 13 or 13/15 months. The drive will last them all the stated months.

In general, the law says that entrepreneurs on OSN can use a drive for a period of “at least 13 months,” that is, any: for 13, 13/15 or 36 months. But the FN passport for 36 months does not mention OSN for trade: the manufacturer does not explain how long such a drive will work and whether it will work at all. Therefore, it is better not to buy such drives.

If you trade in special modes or provide services

Entrepreneurs on simplified taxation, imputation, patent, Unified Agricultural Tax and those who provide services should only use the FN for a period of 36 months: it will also work as written - 36 months. The exception is trade in excisable goods and the temporary (seasonal) nature of the work, more about them below.

If you sell excise goods, work seasonally or independently

Anyone who works in a special regime and sells excisable goods can use the FN for 13, 13/15 or 36 months, but all of them will last 410 days (a little more than 13 months).

Entrepreneurs on a special regime with a seasonal nature of work can use the FN for 13, 13/15 or 36 months. The drives will last the maximum stated period.

Entrepreneurs who work autonomously, that is, their cash register does not transmit data to the OFD, can use the FN for 13, 13/15 or 36 months. A 13/15 month FN will last 13 months, a 36 month FN will last 560 days (a little more than 18 months).

Entrepreneurs who trade excisable goods, but do not transfer data to the OFD, can use the FN for 13, 13/15 or 36 months. All models will last 410 days.

FN model

The FN model is the numbers in the name of the drive: FN-1 and FN-1.1. Different FN models support different formats of fiscal documents. Fiscal document format (FFD) is a special type of document that is generated by the cash desk and accepted by the Federal Tax Service. Currently there are three formats: 1.0, 1.05 and 1.1, but over time the tax office plans to completely switch to FFD version 1.1.

The fiscal drive model FN-1 works only with formats 1.0 and 1.05, and FN-1.1 - with all existing ones. The format in which the cash register transmits documents depends on the model of the fiscal drive and the firmware version of the cash register.

All this is important for those entrepreneurs whose cash registers have old firmware that transmits fiscal documents in 1.0 format, and a drive model FN-1: before January 1, 2020, they will have to update the cash register firmware and change the data format to 1.05. According to the order, when changing the format, you need to replace the FN with a new one, but the government wants to amend the order - entrepreneurs will not have to buy a new FN when switching from format 1 to format 1.05.

If the cash register already works with FFD version 1.05, you don’t have to do anything.

When you look for a fiscal drive on the Internet, you will also come across MGM-FN-1. This is a reusable test fiscal drive. It is needed by cash register and software developers to test and configure equipment on the OFD test site. The test FN does not form a fiscal sign: checks have no legal force. This kind of FN will not suit you.

Why buy FN for 15 months if you can for 36

The law allows many businesses to use a financial fund for a period of “at least 13 months.” It seems logical to buy a drive for 36 months, save money and forget about cash register maintenance for three years. In fact, it is unlikely that you will be able to save money.

Firstly, as stated above, the period indicated on the box does not always coincide with the actual life of the drive. For example, if the cash register does not transmit data to the OFD, the fiscal drive for 36 months will only work for 18.

Secondly, the memory of drives for 13/15 months and 36 months is the same. It is large, but not endless: if you are processing more than 200 checks a day, one fiscal drive may not be enough for three years. It’s easier and more reliable to buy FN for 13 or 13/15 months.

What happens if you use the wrong FN

If you are on a special regime or provide services, you are required to use the FN for 36 months. However, if you bought a FN for 13 months, you can use it until the expiration date. In general, warnings and fines are expected for this, but in May 2017, the tax office published a letter in which it pointed out a loophole in the law: organizations with a seasonal nature of work are not required to use a 36-month drive. The law does not explain what “seasonal nature” is and leaves the interpretation of the term to the discretion of the entrepreneur. This means that in order to avoid a fine for incorrect storage, special regime officers only need to approve the seasonal nature of the work within the organization.

Where to buy FN

Fiscal drives are sold by cash register manufacturers, service centers, OFD and FN manufacturers. The price depends on the model, validity period, number of drives - often it is not even written on the website.

Do not forget that the law allows the production of fiscal drives only by certified manufacturers, and the drives themselves are included in the tax register. Please check the registry before purchasing.

If you buy a new cash register, most likely a fiscal drive will be included.

Memo

How long is the fiscal accumulator valid for the simplified tax system when selling alcohol?

The service life of the carrier is influenced by two factors - the norms of 54-FZ (Article 4.1) and technical features, which the manufacturer informs about in the data sheet of a specific model. The legislation stipulates the need to implement EGAIS and connect a unique transport module as a condition for the sale of any alcohol. Accordingly, to sell goods you will need either a cash register that initially supports EGAIS, or a cash register connection via a computer with UTM installed. The service life of any media is limited to a period of 410 days. Similarly, in 2020, the operating time of fiscal storage units for the simplified tax system for the sale of certain types of alcohol as part of catering services will be reduced.

Let's sum it up

So, recommendations for choosing and using a fiscal drive are as follows:

  1. If you purchase FN separately, use the table above to decide which period is right for you. Otherwise, the drive is a universal device - you can take any one.
  2. If you transfer data in FFD 1.0 format, do not forget to switch to format 1.05 . Although we recommend not to rush for now - it is quite possible that the amendments will be accepted, and there will be no need to change the FN during the transition.
  3. If you plan to switch to data transfer directly to FFD 1.1 , buy FN-1.1. Any drive is suitable for FFD 1.05 You should no longer focus on format 1.0 - it will soon be canceled.
  4. If the drive comes with the cash register, be sure to ask what its expiration date is.
  5. If, while on a special regime, you apply the FN for 13 months, we recommend that you adopt an internal document about the seasonal nature of the work. This way you can definitely avoid a fine for using a drive with the wrong expiration date. And when it expires, purchase FN for 36 months.
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