On 6 November, the economy ministry's order No. 647 of 15 September was published and registered with the Ministry of Justice the same day under No. 89078. It sets the procedure Rosstat uses to approve the forms that Russian companies fill in, and repeals the order that had governed the same process since 2021.
The change appears in the title before it appears in the text. The old procedure covered forms and the instructions for filling them in. The new one keeps those and adds a second object: primary statistical indicators and the instructions for submitting them — a way of requiring a number without a form.
We read the whole document: 22 pages, all 36 clauses of the procedure, plus the two appendices.
The order
The order itself is two clauses. Clause 1 approves the procedure. Clause 2 repeals its predecessor:
“2. To declare no longer in force the order of the Ministry of Economic Development of Russia of 24 May 2021 No. 279 ‘On approval of the Procedure for the approval by the Federal State Statistics Service of forms of federal statistical observation and instructions for filling them in’ (registered by the Ministry of Justice of Russia on 14 September 2021, registration No. 64996).”
That quotation is also the evidence for what changed: the repeal clause sets out the old order's title in full, and it ends at forms and filling instructions. The new title runs on — “…forms of federal statistical observation and instructions for filling them in, primary statistical indicators and instructions for submitting them”. The order is signed by the minister, M. G. Reshetnikov.
What a primary statistical indicator is
The procedure's opening clause places forms inside the system the state already runs: they exist to collect data needed to produce the official statistical information set out in the Federal Plan of Statistical Work, approved by government order No. 671-r of 6 May 2008. Clause 20 gives the new object the same footing:
“20. Primary statistical indicators and the instructions for submitting them are approved for the purpose of collecting primary statistical data necessary for the formation of official statistical information provided for by the Federal Plan of Statistical Work.”
And clause 23 says who approves one, and on what:
“23. A primary statistical indicator and the instructions for submitting it are approved by the Federal State Statistics Service on the basis of an application submitted by a subject of official statistical accounting in accordance with the present Procedure.”
An application names, under clause 24, the position in the Federal Plan, the methodology, the indicator's name and classification attributes, its unit of measurement, the periodicity and deadline for submitting the data, who collects it, which categories of respondent supply it, the submission instructions, and the electronic format.
That is most of what a form contains. What it does not contain is a form.
Two routes, and the paper each one leaves
The procedure now describes two ways to arrive at a number a respondent is obliged to report, and the difference between them is not the application — it is what exists at the end.
A form. The application goes to Rosstat by telecommunication channels “in the format of text files (doc, docx)” with a covering letter signed by the head or deputy head of the body asking for it (clause 8), at least 240 calendar days before data collection is meant to start (clause 9). Rosstat has 20 working days to consider it (clause 10) and either refuses or approves (clause 11). If it approves, clause 18 has Rosstat prepare a legal act, and clause 19 sets out what that act must state: Rosstat's powers to approve the form, the position in the Federal Plan, the requisites of the act approving the methodology, the requisites of the covering letter, and the dates from which the form starts being used.
The appendices then make that authority visible. Both recommended form templates carry a box on the face of the form itself, headed “Rosstat order: On approval of the form”, with blanks for its date and number, and further blanks beneath for any order amending it. A respondent filling in the form can see the citation of the act that created it.
A primary statistical indicator. The application is prepared electronically, signed by the head or deputy head, and sent to Rosstat “by means of the state information system ‘Digital analytical platform for the provision of statistical data’” (clause 25) — again at least 240 calendar days ahead, again considered within 20 working days (clause 26), again refused or approved (clause 27). If it is approved, clause 34 says how:
“34. A primary statistical indicator and the instructions for submitting it are approved by the Federal State Statistics Service by means of entering information about it into the unified register of forms and indicators (a registry entry) in accordance with the procedure for forming and maintaining it, established by the Federal State Statistics Service.”
There is no legal act in that sentence. The approval is the registry entry. And under clause 35, the subjects of official statistical accounting are told about it “by means of the functionality of the information system, automatically”.
So one route ends in a dated, numbered order that gets printed on the form. The other ends in a row in a register, inside a platform, announced by the platform.
When this starts
The order carries no commencement clause of its own; registered acts take effect under the general rule. But the parts of the procedure that matter most here are not switched on by a date at all. Clause 36 is the last in the document:
“36. The requirements provided for by clauses 25, 30, 32, 34, 35 of the present Procedure shall be applied as and when the functionality of the information system intended for the formation and maintenance of the unified register of forms and indicators and for informing subjects of official statistical accounting is brought into operation. Information on the possibility of applying the functionality of the information system … shall be posted on the official website of the Federal State Statistics Service in the information and telecommunication network ‘Internet’.”
Every clause listed there describes the new route: the platform application, the refusal, the reconsideration, the registry entry, the automatic notification. They apply as the relevant system functions are brought online. A notice on Rosstat's website will say when that happens.
What Rosstat must still refuse
The procedure is not simply a relaxation. Clause 12 sets out an exhaustive list of grounds on which Rosstat is obliged to refuse a draft form, and clause 28 mirrors it for primary indicators. Two of them constrain the state rather than the respondent: Rosstat must refuse when the Federal Plan of Statistical Work “does not contain positions providing for the formation of official statistical information” on the basis of the data the form would collect (clause 12 “d”), and when the official statistical methodology for using that data “has not been approved” (clause 12 “e”). Clause 13 softens both: neither is a ground for refusal if a proposal to add the position, or a draft methodology, is already before Rosstat without unresolved disagreements.
One more is worth setting down, because it is the rule that keeps a number from being collected twice:
“z) the presence in the draft form of federal statistical observation of questions of the observation programme, the collection of data on which is already being carried out by the Federal State Statistics Service or another subject of official statistical accounting.”
What this does to the numbers on this page
Two of this monitor's eight series come from Rosstat, and we can say which because our own fetchers record the source: annual inflation is read from the monthly index file on Rosstat's prices page, and overdue receivables from the monthly socio-economic report. The other six come from Minfin, the central bank and the railway.
Inflation stands at 6.3% year on year in September and scores 95 of 100 against a pre-war pace of 4.6% a year and a registered trouble line at 40%. Overdue receivables stand at 1.96 times their January 2022 level in real terms — 9.09 trillion roubles as reported at the end of August — and score 4 of 100, against 1× pre-war and a trouble line at a doubling. The strength index is 47 of 100, in the stress zone; the only reading that moved this morning was money supply growth, from 13.2% to 12.1% year on year, and it crossed no registered line.
Nothing in this order changes any of that. It does not close a series, rename one, or alter a figure. It does not name the consumer price index or receivables, or any other series, anywhere in its 36 clauses. A procedure for approving future collection instruments is what it is.
What it changes is the trail. Today, if you want to know on what authority a Russian company was made to report a number, there is a Rosstat order with a date and a number, and it is printed on the form. For anything approved by the new route, there is a registry entry instead, in a system whose own rules Rosstat is still to establish, with the subjects notified automatically. We read Russian statistics closely enough to care where each number comes from, and this document decides how far that question remains answerable.
It is the second time in three days that the paperwork beneath our numbers has been rewritten. On 6 November we reported the new budget reporting forms that carry the deficit and the regional balance. That was Minfin, and budget reporting. This is the economy ministry, and statistical observation. They are separate reforms of separate frameworks, signed two weeks apart — 1 and 8 September for Minfin's four orders, 15 September for this one — and we are not claiming they are one programme. We are noting that the two frameworks that between them carry five of our eight readings were both redrafted in the same autumn.
What we do not know
Whether any primary statistical indicator exists yet. We did not search the register for one, and clause 36 suggests the mechanism may not be switched on. Nothing here says one has been approved.
How the rest of the procedure differs from the 2021 one. We did not read order No. 279. Our comparison of the two rests on the old title, which the repeal clause quotes in full, and on clauses 20 to 35 of the new document, which have no counterpart in that title. Clause-by-clause, how much else moved, we did not establish.
Whether the register itself has rules yet. Clause 34 refers the procedure for forming and maintaining the unified register of forms and indicators to an act of Rosstat under part 3 of article 6 of the federal law. We did not check whether that act has been published.
Whether this is aimed at any particular series. The order names none. The connection to inflation and receivables is ours: it is where our two Rosstat readings come from, not something the document says.
What the new route is for. No published act we read explains why a second instrument was needed, or what sort of data it is meant to gather. The procedure describes the mechanism and stops there.