Clarification on marking codes
When selling motor oils, accountants may wonder whether marking codes need to be transferred to the electronic invoice. According to the clarification dated 9 October, motor oil marking codes currently do not need to be specified in the electronic invoice. This information must be included in the accompanying consignment note for goods — SNT.
This distinction is important when preparing electronic documents: the electronic invoice and the SNT serve different purposes, so the absence of a marking code in the electronic invoice does not in itself mean that the document has been completed incorrectly. At the same time, the accountant must ensure that information about the marked goods is correctly specified in the SNT if its preparation is mandatory for the particular transaction.
Who the clarification applies to
The clarification is relevant to suppliers and recipients of motor oils, as well as accountants, accounting system operators, and employees responsible for preparing documents in the Electronic Invoicing Information System. In practice, it helps distinguish the requirements for electronic invoices from those for accompanying documents.
When working with marked goods, it is necessary to check not only the item master record in the accounting system but also the type of electronic document being created. If the software prompts the user to enter marking information, it is important to determine whether it relates to the electronic invoice or the SNT. The automatic appearance of a field or warning in the accounting system does not confirm that the relevant detail is mandatory specifically in the electronic invoice.
Information should also not be removed from the SNT merely because it is not required in the electronic invoice. The rules for preparing an SNT provide for separate details relating to goods subject to marking. In particular, the general section of the SNT may specify the number and date of an acceptance certificate or a notification of the import of marked goods; these fields are designated as optional.
What the accountant should do
Before submitting the documents, it is advisable to divide the review into several stages:
- determine whether an SNT must be prepared for the transaction;
- check the product and marking information in the SNT;
- prepare the electronic invoice without transferring motor oil marking codes to fields for which no such requirement has been established;
- compare the information about the transaction parties, goods, and quantities in the related documents;
- retain the registration numbers and confirmations that the documents have been processed by the information system.
If an electronic invoice cannot be submitted from 1C, the error should not automatically be attributed to the absence of marking codes. The cause may relate to authentication, the electronic digital signature certificate, user registration, or the completion of other details.
After replacing the electronic digital signature, it is advisable to verify authentication in the Electronic Invoicing Information System using the organisation's BIN and ensure that the user has been invited as an employee. The user should then be re-registered in 1C and the new certificate linked. In 1C, the relevant setting is available at: Administration → General Settings → Electronic Invoices → Electronic Invoice Settings → Electronic Invoicing Information System Users → select user → Select Certificate for Signing In to the Electronic Invoicing Information System.
What will change when traceability is introduced
According to the published clarification, the current approach is expected to remain in place after traceability is introduced from 1 February 2027. This means that motor oil marking codes are still expected to be included in the SNT rather than in the electronic invoice.
Before the new procedures take effect, accountants should monitor official clarifications and accounting system updates. If the developer changes document forms or data exchange algorithms, it is necessary to check whether the updates affect the procedure for completing SNTs and electronic invoices. The inclusion of details must be based on current requirements, rather than solely on the technical availability of a field in the software.
Frequently asked questions
Does the motor oil marking code currently need to be specified in the electronic invoice? — No. According to the clarification dated 9 October, there is currently no obligation to specify such codes in the electronic invoice.
Which document should contain the marking codes? — Information about motor oil marking codes must be specified in the SNT.
Is the absence of a marking code in the electronic invoice an error? — The absence of such a code does not in itself violate the procedure described. However, the correct preparation of the SNT and the other details of the electronic invoice must be checked separately.
Will this procedure remain in place after traceability is introduced? — The clarification provides for this approach to remain in place after traceability is introduced from 1 February 2027.
What should be checked if a document cannot be submitted from 1C after replacing the electronic digital signature? — Authentication in the Electronic Invoicing Information System, the employee's authorisations, user registration in 1C, and the linking of the new certificate should be checked.