Electronic consignment notes and trip sheets in Kazakhstan — 2026: SNT, CMR waybills, ESUTD and fines
Published:
From 1 January 2026, consignment notes for goods (SNT) in Kazakhstan are governed by the new Tax Code and by Ministry of Finance Order No. 657, while mandatory registration of trip sheets and goods transport waybills in the state ESUTD system is suspended until 1 June 2027. Issuing trip sheets and waybills themselves remains compulsory, and the fines for their absence apply in full. Below are the requirements, deadlines and penalties in force as of August 2026.
Quote is based on body, chassis and temperature range.
SNT in 2026: the new legal basis
An SNT is a consignment note for goods — an electronic document issued in the electronic invoicing system (the ESF system at esf.gov.kz).
Two documents govern it from 1 January 2026:
- Tax Code of the Republic of Kazakhstan No. 214-VIII of 18.07.2025, in force from 01.01.2026. Article 179, "Control over compliance with the procedure for issuing consignment notes for goods", sets out when the obligation to issue an SNT arises and assigns the list of goods, the forms and the document flow to the authorised body.
- Order No. 657 of the Acting Minister of Finance of 31.10.2025 (registered with the Ministry of Justice under No. 37317, in force from 01.01.2026). It approves four annexes: the list of goods, the rules for issuing SNTs and their document flow, the SNT form, and the printed SNT form for transit road carriage. The same order repealed the earlier SNT orders, including the base Order No. 1424 of 26.12.2019.
The obligation itself is not new: since 1 April 2023, SNTs have been mandatory for petroleum products, alcohol, refrigerators and freezers (with the Virtual Warehouse module), and for all goods imported into or exported from the Eurasian Economic Union (EAEU), per guidance from the State Revenue Committee. Before that a pilot ran under Ministry of Finance Order No. 1104 of 16.11.2020 (repealed by Order No. 12 of 13.01.2025). From 2026 the procedure is consolidated in Order No. 657.
Which goods require an SNT: the 2026 list
The list (Annex 1 to Order No. 657) contains nine items:
- biofuel;
- ethyl alcohol and alcoholic products;
- certain petroleum products;
- gasohol, benzanol, neftras, light hydrocarbon blends, environmental fuel;
- liquefied petroleum gas;
- narcotic drugs, psychotropic substances, their analogues and precursors;
- goods subject to traceability under the EAEU Agreement (this category includes refrigerators and freezers);
- goods imported into Kazakhstan from EAEU states;
- goods exported from Kazakhstan to EAEU states.
Tobacco products are not on the 2026 list. One practical point matters: items 8 and 9 cover any goods moving into or out of the EAEU, so cross-border carriage within the union requires an SNT whatever the cargo.
Who issues an SNT and by when
The supplier submits the SNT; on import, the consignee does (clause 16 of the Rules). For road carriage an SNT is issued separately for each vehicle (clause 14).
| Situation | Deadline for issuing the SNT |
|---|---|
| Movement, sale or dispatch within Kazakhstan | No later than the start of movement, sale or dispatch |
| Import from EAEU states | Before crossing the state border of Kazakhstan |
| Export to EAEU states, and for goods in lines 1–7 of the list also to third countries | No later than the start of movement, sale or dispatch |
No SNT is required for import or export within the EAEU by a passenger vehicle with a load capacity of 2.5 t or less (clause 14).
Confirmation by the consignee (clause 17): within 10 calendar days of the SNT being registered in the ESF system. The exception is delivery or carriage by any mode of transport — then no later than 20 working days from registration.
Link to the electronic invoice. For goods covered by an SNT, the electronic invoice is issued on the basis of the SNT: the SNT registration number goes in line 32 of the invoice, "Document confirming the supply of goods, works and services" (clause 28).
When no SNT is required
Under clause 15 of the Rules, an SNT is not required for:
- retail sales settled in cash (with a till receipt), by payment card or by electronic money;
- retail sales by filling stations of petroleum products, fuel blends and liquefied gas (lines 3, 4 and 5 of the list);
- import or export via trunk pipelines and power transmission lines;
- dispatch of returnable packaging (except packaging on the WTO exemptions list when exported to the EAEU);
- movement of goods within a single entity between premises at the same address;
- import or export within the EAEU of goods for the personal use of individuals.
An important detail: the exemption for internal movements covers only premises at the same address. Movement between an entity's units at different addresses generally requires an SNT (clause 14).
A paper SNT only when the system fails
A paper SNT is permitted in one case: where the impossibility of issuing it because of technical faults in the ESF system is confirmed on the State Revenue Committee website (clause 43). Paper SNTs are entered in a dedicated register (the form is Annex 3 to the Rules) and uploaded to the ESF system within 3 working days of the faults being resolved (clause 44).
Trip sheets and waybills: what is compulsory in 2026
The governing document is the Rules for the Carriage of Goods by Road (Order No. 546 of the Minister for Investment and Development of 30.04.2015).
Trip sheets and waybills are issued by the carrier on paper or as an electronic document: for one shift or trip, before that shift or trip begins, separately for each goods vehicle (clauses 19–20). Part of the waybill data is completed by the consignor or consignee. The waybill is the primary carriage document and is drawn up in four paper copies. Paper trip sheets and waybills are entered in registers and kept by the carrier for 5 years.
Liability for the data is allocated: loss caused by incorrect, inaccurate or incomplete waybill data is compensated by the consignor (clause 14).
Medical checks. The carrier arranges pre-trip and post-trip medical checks for drivers and a pre-trip technical inspection of the vehicle (clause 11 of Order No. 546; Ministry of Health Order No. KR DSM-131/2020). Where a driver makes several trips in a day, the pre-trip examination is carried out once, before the first trip (clause 11-1). The entry "Driver medical examination" is mandatory information on the trip sheet (Annex 1). Mandatory confirmation of the pre-trip medical check through ESUTD has been deferred to 01.01.2027 following proposals from the Atameken business chamber; during the transition either a medical worker confirms the check in the system or the carrier enters it on the trip sheet and answers for its accuracy.
ESUTD: registration suspended until 1 June 2027
ESUTD is the unified transport document management system: an information system for registering, recording, processing and storing documents relating to carriage (clause 5(9) of Order No. 546; the ESUTD provisions were added by Order No. 307 of 16.06.2021). The portal is esutd.gov.kz and use of the system is free of charge, according to industry reports.
Clause 22 of Order No. 546 requires that, where trip sheets and waybills are issued on paper for a goods vehicle with a technically permissible maximum mass over 3.5 tonnes, the carrier and consignor register them in ESUTD — the trip sheet before the shift or trip begins, the waybill before the cargo departs.
How that obligation has moved:
| Period | Status of ESUTD registration | Basis |
|---|---|---|
| Until 01.06.2026 | Suspended | Order No. 185 of the Minister of Transport of 05.06.2025 |
| From 01.06.2026 | Obligation resumed | Clause 22 of Order No. 546 |
| From late July 2026 to 01.06.2027 | Suspended again | Order No. 189 of the Acting Minister of Transport of 23.07.2026 (in force after first official publication; industry sources give 28.07.2026) |
The position in August 2026: registering trip sheets and waybills in ESUTD is voluntary until 1 June 2027, but issuing them — on paper or electronically — remains compulsory, as clauses 19–20 of Order No. 546 were never suspended.
Among the regulator's plans: the Ministry of Transport put out for public consultation, until 07.03.2025, a draft amendment to Article 30(2) of the Road Transport Act making electronic waybills mandatory for consignors and carriers using category N3 tipper trucks (over 12 t). The fate of that draft is not tracked in open sources as of August 2026.
Fines in 2026
The monthly calculation index (MCI) for 2026 is 4,325 tenge (Law on the republican budget for 2026–2028).
SNT — Article 283-1 of the Administrative Offences Code
| Part | Offence | Individuals | Small business and NPOs | Medium business | Large business |
|---|---|---|---|---|---|
| 1 | Failure to submit an SNT, or late submission | 5 MCI (21,625 KZT) | 10 MCI (43,250 KZT) | 20 MCI (86,500 KZT) | 30 MCI (129,750 KZT) |
| 2 | The same, repeated within one year | 10 MCI | 20 MCI | 40 MCI | 60 MCI |
| 3 | Mismatched description, incorrect quantity or volume, incorrect PIN code — for petroleum products, alcohol and biofuel | 10 MCI | 20 MCI | 40 MCI | 50 MCI |
| 4 | The same, repeated | 20 MCI | 40 MCI | 60 MCI | 100 MCI |
| 5 | Failure to issue an SNT, and trade in certain petroleum products or biofuel, or trade in and movement of alcohol without an SNT * | 20 MCI | 50 MCI | 100 MCI | 200 MCI |
| 6 | The same, repeated * | 40 MCI | 100 MCI | 200 MCI | 400 MCI (1,730,000 KZT) |
* Parts 5 and 6 carry confiscation of the goods concerned (alcohol, certain petroleum products, biofuel) and of any proceeds. NPO means non-profit organisation.
Trip sheets and waybills — Article 571-1
The current wording of the article, as regards failure to register in ESUTD, was introduced by Law No. 155-VIII of 10.01.2025 and has applied since 18.03.2025.
| Part | Offence | Individuals | Small business | Medium business | Large business |
|---|---|---|---|---|---|
| 1 | Failure by the carrier to produce a waybill (or measurement or weighing report) or trip sheet; carriage without registering them in ESUTD; leaving them blank or entering knowingly false data | 20 MCI (86,500 KZT) | 40 MCI (173,000 KZT) | 50 MCI (216,250 KZT) | 60 MCI (259,500 KZT) |
| 2 | The same, repeated within one year | 30 MCI | 60 MCI | 70 MCI | 80 MCI (346,000 KZT) |
A conflict worth noting: the offence of "carriage without ESUTD registration" remains in the Code, while the registration duty itself (clause 22 of Order No. 546) is suspended until 01.06.2027. No official guidance on applying the provision during the suspension has been published. Fines for failing to issue or produce the trip sheets and waybills themselves apply in full regardless of the suspension.
A separate warning from accounting advisers, which is not a rule of law: without a properly issued waybill, transport costs may be disputed during tax audits.
Connecting to the systems in practice
The ESF system, for SNTs. A digital signature from the National Certification Authority of Kazakhstan is required. Registration is at esf.gov.kz: a legal entity registers through its head, a sole trader with an individual's digital signature, and a system usage agreement is signed. Since 02.10.2023 registration with biometric identification is available (a number in the Mobile Citizens database plus a webcam or smartphone). SNTs are issued in the web cabinet, in the Virtual Warehouse module, or via API from an accounting system — integration with 1C and others is provided for by clause 11 of the Rules. A registration guide is published at kgd.gov.kz.
ESUTD, for trip sheets and waybills. Registration is at esutd.gov.kz with a digital signature; at registration a role is chosen — carrier, consignor or consignee, and more than one is possible. Every employee who issues documents needs a signature. The carrier creates the trip sheet before the shift or trip begins, for each vehicle; a waybill is issued for each trip and each vehicle and signed digitally by the parties. Electronic waybills are given a QR code, and the driver presents either the paper copy or the electronic document for inspection, via the mobile app or the mobile version of ESUTD, according to industry reports.
What this means for commercial vehicle owners
Carriage paperwork in Kazakhstan is moving to electronic form in stages: SNTs are already issued only through the ESF system, and after 1 June 2027 registering trip sheets and waybills in ESUTD becomes compulsory for trucks with a technically permissible maximum mass over 3.5 tonnes. The requirements are tied to the vehicle characteristics recorded in its documents, so the mass, body type and intended use on paper must match the actual build. When a body is built or retrofitted — an insulated or refrigerated van, a dry freight body, a flatbed platform — the manufacturer issues documents for it, and the changes are registered in the vehicle registration certificate on that basis; a correctly documented vehicle passes carriage-document checks without discrepancies. Bodies on goods chassis are built and retrofitted by the COND plant in Almaty.
FAQ
Is an SNT required to carry food products within Kazakhstan? For domestic carriage an SNT is required only for goods on the list of nine items in Order No. 657, and food is not among them. For import from and export to EAEU states an SNT is required for any goods, food included.
Is registering a trip sheet and waybill in ESUTD compulsory in 2026? No. Order No. 189 of the Acting Minister of Transport of 23.07.2026 suspended mandatory registration until 1 June 2027. Issuing the trip sheet and waybill, on paper or electronically, remains compulsory, and their absence is fined under Article 571-1.
How long does the consignee have to confirm an SNT? Within 10 calendar days of the SNT being registered in the ESF system. Where the goods are delivered or carried by any mode of transport, no later than 20 working days from registration.
Can an SNT be issued on paper? Only where the impossibility of issuing it because of technical faults in the ESF system is confirmed on the State Revenue Committee website. A paper SNT is entered in a register and uploaded to the ESF system within 3 working days of the faults being resolved.
Source legislation
Full texts in the official Kazakh legal database Adilet:
- Order No. 657 of the Acting Minister of Finance of 31.10.2025 (list and SNT rules): https://adilet.zan.kz/rus/docs/V2500037317
- Tax Code No. 214-VIII of 18.07.2025 (Article 179): https://adilet.zan.kz/rus/docs/K2500000214
- Administrative Offences Code, Articles 283-1 and 571-1: https://adilet.zan.kz/rus/docs/K1400000235
- Rules for the Carriage of Goods by Road (Order No. 546, with the suspension notes to 01.06.2027): https://adilet.zan.kz/rus/docs/V1500012463
- Law No. 155-VIII of 10.01.2025 (new wording of Article 571-1): https://adilet.zan.kz/rus/docs/Z2500000155
- Ministry of Finance Order No. 1104 of 16.11.2020 (the SNT pilot, repealed): https://adilet.zan.kz/rus/docs/V2000021631
- Law on the republican budget for 2026–2028 (MCI 2026 = 4,325 KZT): https://adilet.zan.kz/rus/docs/Z2500000239