Negative protocol SZV-M - error code 50

When submitting reports in the SZV-M form, specific deadlines are established, violation of which entails administrative liability in the form of a fine. Sometimes a situation arises that a report is not submitted due to a technical software failure. In this case, a fine can be avoided, but you need to take into account the nature of the technical problems that caused the failure to submit the SZV-M report to the Pension Fund.

We present to your attention such technical problems that may lead to litigation with the Pension Fund.

Who is responsible for delivery?

Before clarifying the main issue - when there is no protocol from the Pension Fund for SZV-M - you need to understand the terminology.

What is "SZV-M"? This is a special form according to which a company or individual entrepreneur keeps a report to the Pension Fund of the Russian Federation. Stands for incoming information about the insured. That is, which the company submits to the fund. And the letter “M” indicates that this reporting is monthly (PFR Resolution No. 83p dated 02/01/2016).

Also see “New SZV-M report form from 2021”.

The head of the company appoints the person responsible for maintaining such documentation at his own discretion. But, as a rule, this is done by someone from the HR department (or an accountant): they have access to all personal affairs and contracts with employees.

Every month, SZV-M provides a list of all employees who worked for the organization during the reporting period (month). Even if a person worked for the company for only one day, information about this still needs to be reflected.

Also see “Instructions for filling out the SZV-M form in 2021.”

What are errors in SZV-M with result code 50

Code 50 is typical for the following error categories:

The file does not conform to the XSD schema or correctly filled out .xml format.
Errors were made in the data of the reporting person - registration number in the Pension Fund and Taxpayer Identification Number.
The policyholder's electronic signature turned out to be incorrect or invalid.
The form submission period is before April 2021.
The reporting period indicates a period that has not yet arrived - it is impossible to submit a report for March 2020 in February 2021.
Errors in form type, for example, two forms are submitted for the same period with the type “original” or the first time a form is submitted not with the type “output”.

In the first five cases, the report must be resubmitted with the “outcome” form type, eliminating the violations. The policyholder is given 5 working days to do this from the date of receipt of notification from the fund about the refusal to accept the reports. If you correct everything and redirect the report within the specified period, you will be able to avoid a fine.

If, upon re-testing, a negative protocol is generated, the policyholder will face a fine, determined, as a rule, by multiplying 500 rubles. by the number of insured persons.

We will examine the sixth case in more detail in the next section.

What are the consequences of not having a protocol?

This is the first thing that most accountants and personnel officers are interested in. After all, the law has strict limits that determine when SZV-M needs to be sent. Namely, no later than the 15th of every month.

In case of delay, sanctions will immediately follow: 500 rubles for each person whose data the Pension Fund did not receive on time. This is spelled out in Article 17 of the Law “Penalties for late submission of SZV-M: 2017.”

Naturally, any employer begins to get nervous if they do not receive a protocol from the Pension Fund on the acceptance of the report. After all, only by it can one judge whether the fund will give the go-ahead for the sent SZV-M or not. And if there is no protocol from the Pension Fund for SZV-M , then there is a high probability of sanctions.

A similar situation arose in the spring of 2021, when a large number of organizations and businessmen found themselves in the role of “guilty parties.” All of them did not receive a positive protocol for SZV-M, although they sent the data on time. The reason became known very soon. It turned out that the fund had technical difficulties that no one could influence. As a result, it took time to fix this glitch. But in the end, no one paid the fine, since it was not the fault of the policyholders.

If your organization finds itself in a similar situation - when time passes and there is no SZV-M protocol , they begin to accuse you of being late, write a claim against the fund’s act. Of course, that the report was sent on time. And fight all charges.

With what errors will the report be fully or partially accepted?

If the inspectors send the policyholder a positive report, this does not mean that there are complete absence of errors in the submitted SZV-M. Errors with codes 30 and 20 are not critical; with them the report is considered submitted, but for those persons for whom errors were identified, the information may have to be supplemented.

Code 30 is usually assigned for errors in full name. or SNILS of employees. All this data must match what is stated in the insurance certificate. Although the controllers will accept such a report, information with identified errors will need to be submitted with a supplementary form.

Errors in the TIN of employees or the complete absence of this parameter are indicated by code 20. A supplementary form in the absence of a TIN will not be required; the inspectors will accept the report. But an incorrect indication can result in a fine, so it is better to correct such information.

What steps to take

If enough time has passed and there is still no protocol for taking SZV-M, then:

First of all, contact your special operator, who acts as an intermediary in transferring reports to the Pension Fund.

It is quite possible that he is aware of the situation and will be able to shed light on the reason for the delay. For example, he will say that there is simply a large influx of documents in your branch of the Pension Fund and specialists do not have time to send return protocols to everyone. This, by the way, is one of the most common reasons.

The second option is to call the fund branch directly. It's even faster. And if the delay is again caused by a large influx of documents, then the staff will try to respond to the person who applied first.

If there is no protocol from the Pension Fund for SZV-M , this does not mean that you did not submit a report. And even more so, this does not constitute a violation. If everything is done correctly and on time, no one can blame you for being late in sending the report.

The most unpleasant reason why a protocol does not arrive for a long time is when the report is drawn up incorrectly. In this case, the fund creates a negative protocol, and this takes much more time. Moreover, once you receive it, there will be virtually no time left to correct errors.

For more information, see “SZV-M: negative protocol.”

Therefore, in any case, we advise you to always play it safe and call the Pension Fund branch. And if they say that the fund’s employees are preparing a negative protocol, you can act proactively: find the errors yourself and send a corrected version of the SZV-M. In this case, there is a chance to avoid fines.

Report submission mechanism

In accordance with the Law on Personalized Accounting in the Pension Fund of the Russian Federation No. 27-FZ dated April 1, 1996, the SZV-M report is submitted by the reporting organization (IP) to the territorial office of the Pension Fund of the Russian Federation at the place of its registration (Articles 8, 11).

On paper, the form is allowed to be submitted to the fund if it contains data on less than 25 employees. Otherwise, the SZV-M must be transferred electronically with a digital signature via TKS.

Before sending a report on the insured persons, the official must carefully enter all the data and avoid errors and typos. Otherwise, the organization will receive a negative response from the fund and will be forced to resubmit the form.

After sending the data, the fund must send a response receipt confirming acceptance of the report. It confirms that the information has been analyzed and is reliable, and that the file format is current and meets established requirements.

The procedure for exchanging information with the Pension Fund is regulated by the fund’s order No. 190r dated 10/11/07. There are cases when the protocol from the Pension Fund has not arrived. Every employer should know what to do in this situation.

After automatic processing of SZV-M data, the fund sends a protocol to the company.

It can be of three types:

Negative about refusal to accept data	It indicates the presence of gross errors. In this case, the information is considered not provided. They need to be corrected and sent to SZV-M again with the “output” type. This option is possible not only if there are inaccuracies in the data on employees, but also if the file format does not match the current version, or if the electronic signature is not true.
Positive about partial acceptance of the report	In this case, data on insured citizens with errors will not be accepted. The employer must correct the shortcomings and send the form only to rejected citizens.
Positive about document acceptance	The form has been accepted and contains no errors.

It is important to read the contents of the positive notice so as not to miss a partial deviation of the information in the SZV-M. Since 2021, SZV-M has been submitted electronically in a new format, which was established by the Board of the Pension Fund of the Russian Federation (Resolution No. 1077p dated 12/07/16).

Questions and answers

How long should I wait for the protocol from the Pension Fund from the date of sending the SZV-M?

Answer: Usually, 2-3 days pass from the moment the SZV-M report is sent to the receipt of the protocol from the Pension Fund.

2. Will a fine be collected if there is no protocol for technical reasons? We don't even know whether the report was accepted or not.

Answer: In case of technical problems at the Pension Fund of Russia, no fine will be collected from policyholders for failure to submit the SZV-M report. It is better to contact the Pension Fund to clarify the deadline for submitting the protocol.

Definition of concepts

SZV-M is a reporting form with which employers report to the pension fund about their insured employees.

The document was developed by the PRF and put into effect in 2021. The primary goal of introducing this paper is to control the number of employed people of retirement age. The state does not index their pensions. Pensioners will be able to receive them in full only after dismissal.

The abbreviation “SZV” means that the form contains incoming information about the insured persons. The letter “M” in the name of the form indicates that the report is monthly. It was approved by Resolution of the Foundation Board No. 83p dated 02/01/16. All legal entities and individual entrepreneurs using the labor of individuals must provide information from April 2019.

SZV-M indicates:

short name of the company (full name of the individual entrepreneur), INN, KPP, Pension Fund number;
reporting month (01, 02, etc.) and year;
type of form (filling options are given in the form);
information about employees: full name, SNILS, INN;
date, signature, seal.

The head of the legal entity appoints an employee responsible for drawing up the form. This is usually an accountant or human resources officer who has access to staff employment agreements and personnel files.

The form provides a list of persons who worked for the employer in the reporting month. It does not matter how long a person has worked. The main criterion for including workers in the list is the conclusion of an agreement with them: labor or civil law.

The form includes part-time workers, foreign employees, including those without citizenship, who are insured by the Pension Fund. Highly qualified foreign specialists are not included in SZV-M, since they do not need to register in the pension insurance system of the Russian Federation.

If a citizen working under an employment agreement did not receive payments within a month, he still needs to be included in the SZV-M, and if he had no income and worked under the GPA, he does not need to be included in the form.

Form SZV-M

Procedure if there is no protocol from the Pension Fund for SZV-M

Save the receipt for sending the report	If it is not generated when submitting data electronically, you should contact the operator responsible for the process. If any disputes arise with the fund, the receipt will be irrefutable evidence of the timely dispatch of the SZV-M. The employer is not responsible for technical problems.
Check report control ratios before sending	You can find out more about them on the Pension Fund website and other online resources.
Contact your data provider	Often the reason for the protocol delay is a large influx of papers that a specialized company does not have time to deal with in time. This situation is common in the last days of the deadline for providing information.
Contact the fund if there is no protocol	Perhaps the Pension Fund will provide clarification on this issue. For example, when submitting information in May 2021, many companies received a notification that their application was rejected, even though the report was completed correctly. The Foundation recommended retransmitting the data with the “additional” type. As a result, the Pension Fund of Russia accepted the reports without penalties.

If you don’t have time to visit the fund to receive clarification from the Pension Fund or you can’t get through to them by phone, you can send an appeal in writing. It needs to state the situation that has arisen in free form. The sent letter will also serve as a supporting document when resolving possible disagreements with the fund.