Do I need to reflect sales in egais. Egais: we keep records of alcoholic products in the provision of catering services

To date, the sale of alcoholic beverages by public catering through the Unified State Automated Information System is identical to the process of selling goods by a retail store.

The slight difference is that:

  • In retail, write-offs for the sale of a whole bottle occur through the cash register at the time of sale.

  • In public catering, drinks can be sold in parts, in which case the operation should be registered in the sales journal and a “Container Opening Act” should be drawn up indicating its excise stamp in the Unified State Automated Information System.

In the sale of alcohol in portions (beer on tap, bar, etc.), the question often arises - what is considered a fact of sale and what is considered its unit - a bottle, a keg or a glass?

In Appendix No. 2 to Order No. 164 of 06/19/2015 it is said that:

“The journal is filled out no later than the next day after the fact of retail sale of each unit of consumer packaging (packaging) of alcoholic and alcohol-containing products, or upon opening of the transport container (including reusable containers) used for the delivery and subsequent bottling of products to the consumer.”

That is, they opened a keg or a bottle - they reflected this in the magazine as a fact of its complete sale.

Remains of catering in EGAIS

Only complete containers are accepted for accounting for catering residues in EGAIS. In case of violation of integrity - this bottle must be written off to the Unified State Automated Information System by issuing a "Decommissioning Act" indicating the reason and an excise stamp that was not previously interesting for the Ralkgolregulation.

But in the declaration you had to indicate the total volume sold, taking into account those bottles that have already been written off in the Unified State Automated Information System.

At the moment, the methodology has changed and the licensing authorities allow the following formats for the introduction of the EGAIS and the declaration.

1. Write-off of products using the "Decommissioning Act" with the obligatory indication of the marking.

Starting from January 15, the presence of the brand will be controlled in the "Debit Acts" during the sale. If it is not there, RAR will send a refusal. That is, for public catering, the same rules for controlling duplicates will apply as for retail.

Note! New requirements are not made dependent on turnover. This means that absolutely everyone will have to acquire a scanner, even the smallest points of sale.

Do I need to scan the goods upon receipt?

Starting July 1, products will be entered into invoices by brand, and in electronic documents, each item will have its own code. However, there is no requirement to scan the invoice. Although PAP recommends that this be done to check the lot upon acceptance.

What products are covered by the requirement?

Only for hard alcohol. If a store sells beer and similar drinks (cider, mead, poiret), then nothing will change for it in terms of scanning.

2. Keeping records of balances using the sales journal in the Unified State Automated Information System, while the declaration indicates only written-off alcohol and the volume of opened bottles is not taken into account.

This facilitates the introduction of EGAIS residues in public catering, as well as the formation of a declaration in 11 and 12 forms.

In order not to make mistakes during accounting and not to violate the law with this, try the accounting system for EGAIS, which automates the work process.

Convenient product accounting program with support for logging of alcoholic products and auto-completion of primary documentation, declarations - TriAR-Retail

Catering sorting in EGAIS

In previous articles, we have already written why organizations in the EGAIS have a re-grading. However, consider a specific example in this article.

The same brand of vodka can be bottled at different factories, but each unit of production will have its own personal alcohol code.

Example:

Vodka "Putinka" is bottled at 8 factories and has 8 alcohols. Visually, this product is no different from Belochka vodka, which also has its own alcohol code and is imported, for example, by 5 factories.

So, the goods came to you and the factories were mixed up in the supplier's warehouse. Instead of one factory, they put another one, respectively, without checking the products by scanning, you accepted this product, where there is one alcode in the EGAIS, and physically it belongs to another product.

So that very sorting in the Unified State Automated Information System arose, which leads to a discrepancy in balances and minuses on the register, and sometimes to fines for the illegal sale of alcohol.

Solution:

  1. Before drawing up an act of putting on a balance sheet in the Unified State Automated Information System, an act of writing off products with the basis "Regrading" for a similar amount of products must first be registered. In addition, products that are written off and put on the balance sheet must be within the established product groups.

  2. In the act of putting on the balance sheet for 1 register, when filling out the basis "Regrading", you must specify the identifier of the act of writing off products in the ActWriteOffShop requisite. The act identifier is of the form AWOS-xxxxxxxxx.

  3. When placing on the balance sheet, it is allowed to use the product write-off act identifier only once. The use of one and the same act of debiting in several acts of putting on the balance sheet or other products is not allowed.

Services for writing off and leveling balances

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Please note that during the calendar month you can put on the balance sheet with the basis "Regrading" no more than 2000 bottles for one fsrar_id.

Regrading is allowed only within product groups.

The limit is common for all products (regardless of the product group) on this basis. Detailed information is provided in the EGAIS knowledge base.

Do catering establishments need to transfer information about the remnants of alcoholic beverages to EGAIS?

In the article “EGAIS in catering and alcohol residues”, which was posted in No. 8, 2016, we wrote that catering enterprises may not enter data on the remains of alcoholic products into the EGAIS system, since they are exempted from the obligation to transfer information to the EGAIS on the volume of retail sales of alcoholic products. (But only on the condition that they are not engaged in the retail sale of alcohol outside the framework of the provision of catering services.) This means that at the EGAIS level, the current balances of alcoholic products from persons involved in the retail sale of such products in the provision of catering services will not be controlled. Recently, however, officials of Rosalkogolregulirovanie began to receive information that public catering enterprises should transfer information about the remnants of alcoholic beverages to the Unified State Automated Information System.

Transition period.

Recall that enterprises engaged in the retail sale of alcoholic products are required to record and transfer to the unified state automated information system for recording the volume of production and turnover of ethyl alcohol, alcoholic and alcohol-containing products (EGAIS) information on the volume of turnover of alcoholic products. This requirement follows from par. 8 p. 2 art. 8 of the Federal Law No. 171-FZ, according to which the equipment for recording the volume of turnover of alcoholic products must be equipped with technical means for recording and transmitting information about the volume of turnover of these products to the Unified State Automated Information System. As a general rule, this requirement came into effect on 01/01/2016, but it is delayed - a transitional period (clause 2, article 2 of the Federal Law of 06/29/2015 No. 182-FZ):

  • until July 1, 2016 in relation to the retail sale of alcoholic products in urban areas;
  • until July 1, 2017 in relation to the retail sale of alcoholic products in rural areas. At the same time, on a voluntary basis, data can be transferred to EGAIS right now (this is not a violation).

To understand how the requirement to transfer data to the Unified State Automated Information System is interpreted, attention should be paid to the following concept, presented in Art. 2 of Federal Law No. 171-FZ.

On the requirements for public catering enterprises.

In addition to the transition period, at the level of Federal Law No. 171-FZ itself, exception cases have been introduced (clause 2.1, article 8), when the requirement established by par. 8 p. 2, you do not need to perform. In particular, it does not apply to volume accounting:

  • retail sale of beer and beer drinks, cider, poiret, mead, alcohol-containing products (clause 1);
  • retail sale of alcoholic products in the provision of catering services (clause 2);
  • retail sale of alcoholic products in settlements with a population of less than 3,000 people that do not have an Internet access point. The list of such settlements is determined by the law of the subject of the Russian Federation (clause 3);
  • transportation of alcoholic products, as well as alcohol-containing products with an ethyl alcohol content of not more than 25% of the volume of finished products (clause 10).

Therefore, in Art. 8 of Federal Law No. 171-FZ for catering enterprises there is an important exception, which, if paraphrased, sounds like this: it is not necessary to transfer data on the volume of retail sales of alcoholic beverages to EGAIS when providing catering services. Does this mean that public catering enterprises may not record or transfer information to the Unified State Automated Information System at all?

Assumption

What is meant by the retail sale of alcoholic products is not specified in Federal Law No. 171-FZ. At one time, the definition could be found, in particular, in the Law of Moscow dated December 20, 2006 No. 64 “On licensing and declaring the retail sale of alcoholic products”, but it became invalid on December 23, 2011.

From the presented definition it follows that the retail sale of alcoholic products is understood not only as the sale of products to the final consumer, but also the purchase and storage of alcoholic products. This is also confirmed by the fact that in order to legalize their “alcoholic” activities, catering enterprises must obtain a license for the retail sale of alcoholic products (they do not need to obtain a license for the purchase or storage of alcoholic products). According to paragraph 2 of Art. 18 of Federal Law No. 171-FZ, the types of activities subject to licensing include:

  • production, storage and supply of produced ethyl alcohol, including denatured alcohol;
  • production, storage and supply of produced alcoholic and alcohol-containing food products;
  • storage of ethyl alcohol, alcoholic and alcohol-containing food products;
  • purchase, storage and supply of alcoholic and alcohol-containing products;
  • production, storage and supply of alcohol-containing non-food products;
  • retail sale of alcoholic products;
  • transportation of ethyl alcohol (including denatured alcohol) and bulk alcohol-containing products with an ethyl alcohol content of more than 25% of the volume of finished products;
  • production, storage, supply and retail sale of wine products produced by agricultural producers.

In view of the foregoing, it could be assumed that catering establishments are not subject to the requirement to transfer data to the Unified State Automated Information System at all.

About the purchase.

However, already last year, Rosalkogolregulirovanie issued a letter (dated December 8, 2015 No. 23930/03) with such clarifications.

The retail sale of alcoholic products should be understood as the activity of transferring the specified products to the buyer for personal, family, home or other use not related to entrepreneurial activity.

The purchase of alcoholic products for the purpose of its retail sale is carried out on the basis of a supply agreement, according to which the supplier-seller, engaged in entrepreneurial activities, undertakes to transfer, within the stipulated time or terms, the goods produced or purchased by him to the buyer for use in entrepreneurial activities or for other purposes not related to personal, family, household and other similar use

Conclusion: organizations engaged in the retail sale of alcoholic products in the provision of catering services are required to submit to EGAIS information on the volume of turnover of alcoholic products in terms of its purchase

Thus, the officials considered that information on the volume of turnover of alcoholic products in the provision of catering services should be transferred to the Unified State Automated Information System only in the part of its purchase. A similar approach was demonstrated by the Ministry of Finance in Letter No. 03‑07‑06/52294 dated September 7, 2016. Answering a question about the sale of alcoholic beverages through mini-bars in hotel rooms, he pointed out:

From January 1, 2016, organizations engaged in the retail sale of alcoholic products in the provision of catering services, including through mini-bars, are required to transfer information to EGAIS only on purchases of alcoholic products and are exempt from transferring information to EGAIS on the retail sale of alcoholic products.

In response to the question about fixing the return of alcoholic products in the EGAIS system, the financiers emphasized this once again.

Considering that organizations providing public catering services record in the EGAIS only information on the purchase of alcoholic products, the recording in the EGAIS of the return of products by the end consumer, the further circulation of which is impossible, is not provided for by Federal Law No. 171-FZ.

However, now information (unofficial) has appeared that catering establishments must record in the Unified State Automated Information System, in addition to information on the purchase, also data on the storage of alcoholic beverages. Let's explain.

About the remains of alcohol in the EGAIS system.

The procedure for fixing and transferring data by business entities to the Unified State Automated Information System, including transitional moments, is not regulated at the legislative level. Rosalkogolregulirovanie is trying to partially fill this gap, for example, by posting news on the Internet on a specialized portal http://egais.ru. So, on July 19, 2016, a news item appeared entitled “Accounting for product balances in the Unified State Automated Information System for wholesalers and retailers” with the following content:

Rosalkogolregulirovanie draws attention to the fact that wholesale and retail trade enterprises must keep records of the turnover of alcoholic products in the EGAIS system, including in terms of storage of product residues.

In order to fulfill this obligation, the Service reminds that the balances of products in the EGAIS system must be brought into line with the actual ones by 01/01/2017.

Further, it is proposed to familiarize yourself with the methodology for keeping records of balances at the link http://fsrar.ru/files/retail_stock3.pdf. If you use it, then a text opens (without any details, that is, this is an unofficial document) with the heading "Maintaining product balances by retailers in the EGAIS system (as amended on 04/25/2016)", which begins like this:

Rosalkogolregulirovanie brings to the attention of retailers the methodology in terms of reflecting the current balances of products in the EGAIS system.

1. The balance of products received before 01/01/2016 and not sold before 10/01/2016 must be recorded in the EGAIS system after 10/01/2016 before retail sale by compiling:

A. The act of putting products on the balance sheet, indicating the basis "Products received before 01/01/2016". The remainders will be formed on the first register of remainders. In the act, it will be necessary to indicate the bar codes from the stamps and the details of the accompanying documents

B. The act of putting products on the balance sheet on the trading floor, indicating the basis "Products received before 01/01/2016". The remainders will be formed on the second register of remainders. In the act, it will be necessary to indicate only the alcoholic name (alcohol code). Bottle-by-bottle scanning and specifying the details of accompanying documents in this case are not required.

2. Automatic control of current balances in EGAIS will be enabled after 01/01/2017.

Thus, Rosalkogolregulirovanie informally instructs retailers to enter into EGAIS the remains of alcoholic products purchased before 01/01/2016, but not sold after 10/01/2016. (From the text of the methodology, it becomes clear that the requirements presented in it relate to labeled alcoholic products.)

note

From 10/01/2016, there is a restriction on the introduction of alcohol residues into the Unified State Automated Information System through the balance register No. 1 (no more than 100 units of production per month), while the balance register No. 2 “works” without restrictions.

At the same time, there is no special indication (or exception) in the methodology that public catering enterprises should also take care of the leftovers. At the same time, in the section "Write-off of products, the retail sale of which is not subject to registration in the Unified State Automated Information System", the following instructions are given:

Write-off of products, the retail sale of which is not subject to registration in the Unified State Automated Information System, is carried out by:

A. Fixing the act of writing off products. In this case, the products will be written off from the first register of balances. When writing off, it will be necessary to indicate the details of the accompanying documents. Blot scanning is not required in this case.

B. Fixing the act of writing off products on the trading floor. In this case, the products will be written off from the second register of balances. When writing off, it will be necessary to indicate only the alcohol name (alcohol code). It is not required to specify the details of the accompanying documents and information from the stamps.

3. The volume of products sold in organizations engaged in the retail sale of alcoholic products as part of the provision of public catering services may be written off indicating the basis "Retail sales of products not subject to registration in the Unified State Automated Information System" and the date of the act corresponding to the date of sale.

The methodology is rather damp, so the Federal Service for Alcohol Regulation is accumulating practice (including by holding conferences at which wholesalers and retailers of alcoholic products ask questions, talk about the problems that have arisen), in order to then release the corresponding one. One of the last such conferences on the topic "EGAIS: issues of operation in organizations of the retail and wholesale link of the alcohol market" was held on October 20 in Moscow. During its implementation, Anton Gushchansky, Head of the Department of Automated Information Systems, answering questions about the functioning of the EGAIS system in wholesale and retail, emphasized that the remnants of alcoholic products should be transferred to EGAIS by all enterprises without exception, including those engaged in the provision of catering services, explaining this in the following way. Public catering establishments are exempted from fixing retail sales of alcoholic products to the end consumer in the Unified State Automated Information System. However, according to Art. 2 of Federal Law No. 171-FZ, the concept of turnover includes the storage of products. Therefore, the methodology for keeping records of balances applies to all organizations selling retail products, including those selling alcohol in the provision of catering services.

Thus, based on the unofficial position of officials, catering enterprises must record information about stored products (residues) in the Unified State Automated Information System, the only thing is that so far the service makes such a requirement only for labeled products.

And one more important point. From the section of the methodology, which describes the procedure for writing off products whose retail sale is not subject to registration in the Unified State Automated Information System, it can be assumed that organizations involved in the retail sale of alcoholic products as part of the provision of catering services have the right to decide for themselves whether to write off the volume of alcohol sold to them, since in In this part, the word "may" is used. However, Anton Gushchansky does not give an alternative: these organizations must write off the sold alcoholic products either by checks or in one act per day. It is in connection with this choice that the word “may” is used in the methodology. Regarding the date of sale in the act of writing off products, the official also spoke: perhaps, after discussions of the methodology, not the date of sale, but some other option will be adopted.

If you follow the instructions (and unofficial ones) of Rosalkogolregulirovanie officials, the “benefit” provided for by Federal Law No. 171-FZ for persons involved in the retail sale of alcoholic beverages as part of the provision of catering services becomes quite conditional. After all, they demand not only to enter information about the purchased alcoholic products into the Unified State Automated Information System, but also to display the remains of alcohol (initially, by entering information about the remains of products that were purchased before 01/01/2016, but not sold after 10/01/2016). The latter means that catering establishments in EGAIS should, in fact, also record data on products sold, the only thing is that they can do this not by checks in the context of the alcohol name, but by drawing up an act of writing off products, which is recorded in the system. Whether the submitted demands of officials will be legalized, time will tell. However, they should probably not be ignored. After all, violation of the established procedure for accounting for ethyl alcohol, alcoholic and alcohol-containing products during their production or turnover is an administratively punishable act under Art. 14.19 of the Code of Administrative Offenses of the Russian Federation, which threatens officials with a fine of 10,000 to 15,000 rubles, legal entities - from 150,000 to 200,000 rubles.

Federal Law of November 22, 1995 No. 171-ФЗ “On State Regulation of the Production and Turnover of Ethyl Alcohol, Alcoholic and Alcohol-Containing Products and on Limiting the Consumption (Drinking) of Alcoholic Products”.

From January 1, 2018, restaurants will be required to scan every bottle of alcohol sold. This follows from the information message published on the FSRAR website on August 14, 2017 "Introduction of changes to the checks of product write-off acts with the basis "Sale""

« Rosalkogolregulirovanie informs that from 01/01/2018 an additional check will be introduced when recording acts of write-off of products from both registers of balances in the Unified State Automated Information System, which provides for the mandatory indication of data on bar codes with FSM / AM, which marked sold products».

Let's see what needs to be changed in accounting in order to implement the provisions of this letter.

As it was before 01/01/2018

Public catering was excluded from the list of enterprises obliged to register sales of alcoholic products in the Unified State Automated Information System, however, the FSRAR gradually tightened the alcohol accounting requirements for it. At the beginning, from 01/01/16, there was an obligation to confirm the purchases of alcoholic products in EGAIS. It was not difficult to do this and did not require any special changes in accounting. It was only necessary to find in the system the documents uploaded there by your supplier and confirm that the goods were actually received.

However, already on 10/3/16 she was, in which restaurants were also obliged to "bring from 01/01/17 in accordance with the real remnants of alcoholic products in the Unified State Automated Information System." To do this, it became necessary to write off the sale of alcoholic products "no later than the next day" with the documents "Debit Act" indicating the reason "Write-off of products whose sale is not subject to registration in EGAIS."

But such a document could also be generated manually, because it had to contain only the code of alcoholic beverages and the quantity sold. And the alcocode, as a rule, was the same for the entire batch and it could be obtained by requesting balances in the Unified State Automated Information System or from receipt documents. In other words, EGAIS did not care which bottle from a batch of the same identical bottles you write off.

How will it be from 01/01/2018

Starting from the New Year, the Write-off Act document in the Unified State Automated Information System will be supplemented with a field containing the value of the bar code of the excise stamp affixed to the bottle being written off. And you can get this value only by scanning and only the brand with which you are writing off the bottle. It turns out that for the daily write-off of sold alcohol, all of it will need to be scanned with a barcode scanner first.

And how is this option different from selling alcohol through the cash register of a store? What is the benefit for catering, which is exempt from the need to record alcohol sales at the checkout? And the fact that stores are required to scan each bottle in each check, and public catering can do this in one document per shift.

A controversial benefit, especially considering the essence of the process - in order to scan the bottles opened during the shift, they will have to be brought to the place where such scanning will be performed at the end of the shift. Can you imagine such a process in a real restaurant?

So it turns out that for normal operation, the restaurant will either have to scan all the bottles when they are transferred to the bar and immediately write them off from the Unified State Automated Information System or install the scanner at the bartender’s workplace and oblige him to scan the bottles when they are actually opened in the bar, and for this use the document " Opening the container". With the first option, there is a risk, because according to the rules, only opened alcohol can be written off from EGAIS. And if, during a check in a bar, they find alcohol that has not been opened, but written off in the system, then this will be considered an unaccounted for surplus and punishable by a very serious fine.

On the example of this story with the gradual transfer of public catering to the registration of sales of alcoholic products in the Unified State Automated Information System, it can be seen how, without the issuance of regulatory legal acts, the requirements of the federal law were actually leveled, which gives benefits for restaurants to work with the system. Why it was done this way is also clear - legal acts that contradict federal law could easily be challenged in the courts. And instructions and letters, as well as changes in the composition of the EGAIS documents, are difficult to challenge. But in order to fulfill them, the restaurants have no choice but to completely voluntarily switch to fixing retail sales in the Unified State Automated Information System.

Of the good news, there is only an addition to the FSRAR message, which says that “the mechanism for writing off non-marking products (beer, beer drinks, cider, poiret, mead) remains unchanged.” But no one knows how long this situation will last.

The carrier of all information about the composition, manufacturer, date of issue or import into the country, time and place of bottling, volume of containers and other unique characteristics of each bottle is a federal special excise stamp. The manufacturer or importer glues it on each bottle of alcohol, immediately transferring all this information to the Unified State Automated Information System. The stamp contains alphanumeric information, which is also encoded in a 2D PDF417 or micro PDF417 barcode.

Do restaurants need to connect to EGAIS?

The issue of connecting restaurants, cafes and bars to EGAIS is perhaps one of the most popular today. We answer unequivocally - YES, SHOULD !

First, to keep a log of alcohol retail sales. Despite the fact that, according to Federal Law N 182-ФЗ dated 06/29/2015, the provisions for connecting to the Unified State Automated Information System do not apply to "retail sales of alcoholic products in the provision of catering services", Order FS РАР No. 164 dated 06/19/2015 obliges all enterprises public catering to fill out a register of alcohol retail sales. You can fill it in:

  • in paper form, without connecting to EGAIS and without entering a barcode, however, in this case, the company will have to print such a magazine each time with all sales of alcoholic beverages for the entire quarter,
  • electronically using software. In this case, the lines of the journal will be filled in according to the barcode on the excise stamp of the bottle, so connection to the EGAIS is necessary in this case.


Secondly, to confirm the fact of purchase. On July 20, 2015, the FS RAP issued an “Information Message for Participants of the Alcohol Market”, which states that organizations engaged in the retail sale of alcoholic products in urban areas are required to register information in the Unified State Automated Information System regarding confirmation of the purchase of alcohol from 01/01/2016. This means that upon receipt of alcoholic products by the enterprise, it is obliged to reflect the fact of such receipt in the Unified State Automated Information System within 24 hours by connecting to it using the UTM and its crypto key. Those. the distributor of alcohol is obliged to upload this data there (from November 1, 2015), and the store or restaurant must find this data in the Unified State Automated Information System and confirm or refute the fact that the alcohol indicated by the distributor came to its enterprise.

We took care of you in advance and made improvements to the Traktir: Back-Office and Traktir: Head-Office software products. They fully implement the mechanism for exchanging data with EGAIS in terms of confirming the fact of purchasing alcohol, as well as loading incoming TTN and working with outgoing TTN, creating a EGAIS TTN based on movement between separate divisions and returning goods to the supplier.

The subtleties of connecting catering to EGAIS

- How to connect a network of cafes or restaurants to EGAIS?

The owners of network enterprises now face the question of how to connect the enterprise to EGAIS with minimal time and money costs. It is important to know that one of the features of connecting to EGAIS is the use of a crypto key and only from the facility where alcohol is sold. And this means that in every cafe, bar or restaurant, there must be a computer with an installed crypto key and an employee to ensure efficient work with the EGAIS, since you will have only a day to reflect the fact of purchasing alcohol.

Another important question concerns the sale of alcohol in portions (beer on tap, bar, etc.) - what is considered a fact of sale and what is considered its unit - a bottle, a keg or a glass? Appendix No. 2 to Order No. 164 dated 06/19/2015 states that “The journal is filled out no later than the next day after the retail sale of each unit of consumer packaging (packaging) of alcoholic and alcohol-containing products, or upon opening the transport container (including reusable packaging ) used for the delivery and subsequent bottling of products to the consumer. That is, they opened a keg or a bottle - they reflected this in the magazine as a fact of its complete sale.

On April 19, 2016, the FSRAR on its website published a methodology for maintaining balances for participants in the retail link of alcoholic products in EGAIS. According to this methodology, from 10/01/2016, all organizations had to ensure that the data on the balances of alcoholic products in the Unified State Automated Information System correspond to the real balances. This meant that in violation of Federal Law-182 of 06/29/15 all organizations (including public catering, individual entrepreneurs with beer and rural settlements) were required to report on alcohol sales through EGAIS. However, already on April 21, a new methodology was published ("as amended on 04/20/2016"), and then the "newest", ("as amended on 04/25/2016") methodology, in which such a requirement was already absent. What made FSRAR so quick to soften their requirements and how do they plan to control retailers?

The new document determined how and when the organizations of the retail segment should bring the current balances of alcoholic products in the EGAIS system into line with the actual balances. In addition, 01/01/17 has now become the date from which EGAIS will begin to control the balance of alcoholic products when they are written off in the system.
The first paragraph of the methodology says that from 01.10.2016 you can sell only those products that are on the balance sheet in the Unified State Automated Information System. It says:

1. The balance of products received before 01/01/2016 and not sold before 10/01/2016 must be recorded in the EGAIS system after 10/01/2016 before retail sale

In fact, this means permission not to start the balance of AP (alcoholic products) in retail and write it off when selling "in the red" until 01.10.2016. Everything that will not be sold out before this time will have to be "put on the balance sheet" before being sold through the cashier.

In addition, the new methodology allows "putting on the balance sheet" the balance of AP in a simplified form, immediately to the trading floor and without indicating the code of the excise stamp. Those. now there are two ways to put the AP on the balance:

A. The act of entering the products on the balance sheet, indicating the reason "Products received before 01/01/2016". The remainders will be formed on the first register of remainders. In the act, it will be necessary to indicate bar codes from stamps and details of accompanying documents;

or B. The act of putting products on the balance sheet on the trading floor, indicating the reason "Products received before 01/01/2016". The remainders will be formed on the second register of remainders. In the act, it will be necessary to indicate only the alcoholic name (alcohol code). Bottle-by-bottle scanning and specifying the details of accompanying documents in this case is not required.

Option B allows you to seriously simplify the work with the Unified State Automated Information System and does not require scanning of each stamp. At the same time, products can be put on the balance sheet by simply moving the balances to the trading floor according to the alcohol code and by quantity.

2. Automatic control of current balances in EGAIS will be enabled after 01/01/2017.

It turns out that from 10/01/2016 it will be necessary to add to what has not yet been sold, but purchased without EGAIS, and from 01/01/2017 any movement of AP through the system will be controlled by balances.

Special attention is paid to those organizations that are not required to keep records of sales in EGAIS. These are "rural settlements", beer trade and public catering.

Write-off of products, the retail sale of which is not subject to registration in the Unified State Automated Information System.
1. The volume of products sold before 07/01/2016 in organizations engaged in the retail sale of alcoholic products in urban settlements, until 10/01/2016 must be written off by an act of writing off products indicating the basis "Retail sales of products not subject to registration in EGAIS"

Everything is clear here. In order to fix the "fictitious sale for the period" of alcoholic products, which will bring the balances in line with the real ones, they made a special document "Act of write-off of products" with the basis "Retail sales of products not subject to registration in the Unified State Automated Information System"

2. The volume of products sold before 07/01/2017 in organizations engaged in the retail sale of alcoholic products in rural settlements must be written off no later than the next business day from the date of sale, indicating the basis "Retail sales of products not subject to registration in the Unified State Automated Information System"

"Rural settlements", which were exempted from the need to register alcohol sales in the Unified State Automated Information System, now actually have to do this, but with one final document. The logic of the FSRAR is understandable - since the Internet is enough “in the countryside” to confirm purchases of alcohol, then they will be able to record sales in a similar way. At the same time, balances in the Unified State Automated Information System for such a trading facility will no longer accumulate balances that previously only increased by confirmation of purchase, but were not written off in any way. Moreover, such final implementations must be done daily.
The situation is similar with the "public catering" - restaurants, bars and cafes.

3. The volume of products sold in organizations engaged in the retail sale of alcoholic products as part of the provision of services Catering, can be debited with the indication of the reason "Retail sales of products not subject to registration in the Unified State Automated Information System" and the date of the act corresponding to the date of sale.

The only question is the formula " can be debited ". Does this mean that a restaurant can do such a daily write-off of sales from the balances of the Unified State Automated Information System at its discretion? Or maybe not? In the first version of the methodology dated April 19, 2016, there was a clause that required “ before 01.10.2016, retail trade organizations must bring the current balances in the EGAIS system into line with the actual balances of products". And this could be done either by such daily acts or by direct registration of AP sales through EGAIS. Now there is no such requirement. This means that catering companies can determine for themselves whether they need to write off sales or not. We cannot say what will happen next and how the requirements of the FSRAR will change.

The new document of the FSRAR has not bypassed the attention of those who sell only beer:

4. The volume of sold beer products in organizations engaged in the retail sale of alcoholic products can be written off starting from 07/01/2016, indicating the basis "Retail sales of products not subject to registration in the Unified State Automated Information System" and the date of the act corresponding to the date of sale. Used for organizations keeping a hard copy retail sales register.

The logic of the FSRAR movement towards putting things in order in the EGAIS system and in accounting for the turnover of alcoholic products is generally understandable. The fact that public catering, individual entrepreneurs with beer and rural settlements had to simply confirm the fact of purchasing alcohol from suppliers and thereby constantly accumulate their balances of alcoholic products registered in the Unified State Automated Information System, without any write-offs of these balances, was illogical and incomprehensible. These remnants once had to be sorted out. The FSRAR did not lobby for the issuance of new federal laws on this topic and decided to simply “quietly” correct this situation with the help of its internal regulations. What will happen next? Whether this technique of 04/20/2016, which has neither a number nor a status, will acquire any formal form is not clear. It is also not clear who and how will demand its execution? Based on what? But now it’s clear that 01/01/17 is the date that you should pay attention to. And the procedure for working with EGAIS, prescribed in this document, too. Those. EGAIS will either be canceled completely, or still brought to mind. And judging by everything, the second is more likely than the first.