Reporting of Microfinance Organizations (MFOs): Forms, Procedures and Submission Deadlines
Publication date: January 26, 2018 Last updated: October 1, 2023
From the moment information about a legal entity is entered into the state register of microfinance organizations, a microfinance organization (MFO) becomes obligated to prepare and submit reports on a regular basis to the Bank of Russia and Rosfinmonitoring (RFM) using approved forms. Let's examine this issue in more detail.
Regulatory Legal Acts
Various MFO reporting forms and the procedure for their submission to the Bank of Russia and Rosfinmonitoring are established by the following regulatory legal acts of the Russian Federation:
- Federal Law No. 151-FZ dated 02.07.2010 "On Microfinance Activities and Microfinance Organizations" (hereinafter — Federal Law No. 151).
- Federal Law No. 115-FZ dated 07.08.2001 "On Countering the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism" (hereinafter — Federal Law No. 115).
- Bank of Russia Directive No. 3484-U dated 15.12.2014 "On the Procedure for Non-Credit Financial Organizations to Submit Information Provided for by the Federal Law 'On Countering the Legalization (Laundering) of Proceeds from Crime and the Financing of Terrorism' to the Authorized Body" (hereinafter — Central Bank Directive No. 3484).
- Bank of Russia Directive No. 3984-U dated 28.03.2016 "On the Procedure for the Bank of Russia to Maintain the State Register of Microfinance Organizations" (hereinafter — Central Bank Directive No. 3984).
- Bank of Russia Directive No. 4263-U dated 13.01.2017 "On the Deadlines and Procedure for Non-Credit Financial Organizations to Prepare and Submit Reports on Cash Transactions to the Bank of Russia" (hereinafter — Central Bank Directive No. 4263).
- Bank of Russia Directive No. 4383-U dated 24.05.2017 "On the Forms, Deadlines and Procedure for Microfinance Companies and Microcredit Companies to Prepare and Submit Reports to the Bank of Russia" (hereinafter — Central Bank Directive No. 4383).
- Bank of Russia Directive No. 4658-U dated 21.12.2017 "On the Procedure and Deadline for Sending Notification by a Person Who Has Directly or Indirectly Acquired the Right to Dispose of 10% or More of Votes" (hereinafter — Central Bank Directive No. 4658).
- Bank of Russia Directive No. 5515-U dated 25.06.2020 "On Submitting Reports Through the Unified Portal of State Services".
MFO Reporting Forms
In accordance with the specified regulatory legal acts of the Russian Federation, an MFO in the form of a microcredit company (MCC) is required to submit the following reports to the Bank of Russia and Rosfinmonitoring:
| No. | Report Form | Submission Frequency | Note |
|---|---|---|---|
| 1 | Report on Cash Transactions of Non-Credit Financial Organizations (f. 0420001) | Monthly, no later than the 15th business day of the month following the reporting period | Central Bank Directive No. 4263 |
| 2 | Report on Weighted Average Values of the Total Cost of Consumer Microloans (f. 0420847) | Quarterly, no later than 30 calendar days after the end of the reporting period | Central Bank Directive No. 4383 |
| 3 | Report on Microfinance Activities of a Microcredit Company (MCC) (f. 0420846) | Quarterly, no later than 20 business days after the end of the reporting period | Central Bank Directive No. 4383 (amended in 2021) |
| 4 | Annual Accounting (Financial) Statements | Annually, no later than April 1 of the year following the reporting year | Central Bank Directive No. 4383 |
| 5 | Report on the Personnel Composition of the Governing Bodies of a Microfinance Organization (f. 0420841) | Annually, no later than 30 calendar days after the reporting year and no later than 30 days after changes | Central Bank Directive No. 4383 |
| 6 | Report on the Results of Customer Verification Against the Terrorist List | Quarterly, no later than 3 business days from the date of completion of verification | Submitted to Rosfinmonitoring via Personal Account |
| 7 | Notification of Change of Address (Location) and/or Constituent Documents (Charter) | On an irregular basis, within 30 calendar days from the date of relevant changes | Central Bank Directive No. 3984 |
| 8 | Notification of Change of Other Information (Website Address, Email Address, etc.) | On an irregular basis, within 3 business days from the date of relevant changes | Central Bank Directive No. 3984 |
| 9 | Re-registration of Certificate of Entry of Information in the State Register of MFOs | On an irregular basis, within 30 calendar days | Central Bank Directive No. 3984 |
| 10 | Notification of Acquisition of the Right to Dispose of 10% or More of Votes | On an irregular basis, within 10 business days | Central Bank Directive No. 4658 |
| 11 | Notification of Appointment of a Special Official (SDO) in the Field of AML/CFT | On an irregular basis, within 3 business days | Bank of Russia Regulation No. 445-P dated 15.12.2014 |
| 12 | Report on the Results of Overdue Debt Collection Activities (f. 0420850) | Quarterly, no later than 25 business days after the end of the reporting period | Introduced in 2020 |
Additional Requirements for MFCs
Please note that in accordance with Central Bank Directive No. 4383, an MFO in the form of a microfinance company (MFC) additionally submits the following reports to the Bank of Russia:
Monthly:
- Report on Microfinance Activities of an MFC (f. 0420840).
Quarterly:
- Accounting (Financial) Statements.
Annually:
- Accounting (Financial) Statements together with the auditor's report thereon (for MFOs with capital exceeding 500 million rubles).
On an irregular basis:
- MFC Report on the Auditing Organization (Auditor) (f. 0420849).
- Report on Approval by the Authorized Body of the MFC of the Agenda of the General Meeting of Shareholders (Participants) Containing the Issue of Approval of the Auditing Organization (Auditor) (f. 0420848).
- Report on Persons to Whom the MFC Has Entrusted Identification (f. 0420839).
Features of Report Submission
Reports in all cases, unless otherwise specified, are submitted electronically through the registered Bank of Russia Personal Account or the Unified Portal of State Services (UPSS). This requirement is established in Bank of Russia Directive No. 5515-U dated 25.06.2020.
When submitting to the Bank of Russia and Rosfinmonitoring, reports must be signed with a qualified electronic signature (QES) of the MFO head. The QES must be issued by a certification center accredited by the Ministry of Digital Development of Russia (formerly — Ministry of Communications). This requirement is specified in Federal Law No. 63-FZ dated 06.04.2011 (as amended on 01.07.2021).
Additional Requirements for MFOs That Are Members of SROs
If an MFO is already a member of a self-regulatory organization (SRO), the reports listed in the table under No. 1–5, in addition to the Bank of Russia, are also duplicated to the SRO. The procedure and deadlines for submitting such reports are clarified directly with the SRO.
Important: Since 2020, the transfer of authority for receiving reports to self-regulatory organizations (SROs) has become mandatory for all MFOs that are members of SROs. This requirement is established in Federal Law No. 151-FZ dated 02.07.2010 (as amended on 29.12.2020).
Changes in Audit Requirements
According to Bank of Russia Directive No. 5658-U dated 21.12.2020, microfinance organizations with capital exceeding 500 million rubles are required to conduct an audit at least once a year. The auditor's report must be submitted together with the accounting statements by April 1 of the year following the reporting year.
Conclusion
Reporting of microfinance organizations is regulated by strict requirements of legislation and regulatory acts of the Bank of Russia. It is important to monitor changes in legislation in a timely manner to avoid fines and other sanctions. For convenience, it is recommended to use the Bank of Russia Personal Account or the Unified Portal of State Services (UPSS) for submitting reports.
Note: Currently, the authority for receiving reports from MFOs remains with the Bank of Russia, however, in case of transfer of these powers to SROs, MFOs will be required to provide reports directly to their self-regulatory organization.