Agents and Commission Agents: Agent Attribute on Receipts

If a business sells a product or service that is not its own — third-party property on commission, a tour from an operator, or accepting payments for a third party — the receipt must indicate that the seller is acting in another party's interest. For this purpose, there is a separate attribute — the agent indicator for the subject of settlement — as well as details about whose product or service you are actually selling. Forgetting it or confusing it with related scenarios (simple resale, payment agent under 103-FZ) is a common mistake in intermediary schemes.

1. When the Agent Flag is Mandatory#

The agent flag is not set every time there is an intermediary in the chain, but only when legal ownership of the goods (or the right to provide the service) legally remains with another entity — the principal, consignor, tour operator, or supplier — right up to the moment of sale to the customer. If you purchased the goods outright and they became yours (even if bought from another store for resale), this is a standard sale, and no agent flag is required. It is needed specifically when you physically complete the sale but are not the legal owner of the item being billed.

For any receipt item marked with the agent flag, supplier details must also be specified — at a minimum, the name and, where applicable, the TIN (Taxpayer Identification Number) of the party on whose behalf you are acting.

2. Agent, Commission Agent, Payment Agent — What is the Difference#

3. FFD: Supported Versions#

The agent attribute is supported starting from FFD 1.05, but the set of accompanying data there is noticeably limited — effectively, you can only specify the attribute itself and a minimal set of supplier details. FFD 1.1 adds a more complete set of supplier data (name, INN) and agent data. FFD 1.2 details the structure even more precisely and is better aligned with requirements for tracked (marked) and excisable goods, which are also often sold under an agency scheme. If the POS operates on FFD 1.05 and the business is intermediary, it is worth checking with your CTO (fiscal service center) about upgrading to 1.1/1.2: otherwise, there will simply be nowhere in the receipt to place part of the mandatory supplier data.

4. Consignment store (second-hand)#

1. Accepting an item for consignment is not a settlement with the consignor: they do not sell the item to the store, but hand it over for sale under a consignment agreement; no money changes hands at this moment. No receipt is issued; only an agreement and an acceptance certificate are drawn up.
2. Selling an item to a buyer — a receipt marked as "commission agent", subject of settlement — goods, provider details — information about the consignor.
3. Individual consignor without a TIN. An ordinary individual often does not have a TIN relevant for receipt details. The provider details specify available information (full name); the TIN field for an individual provider without sole proprietor status can normally remain empty — this is a standard situation in consignment trade with individuals, not a POS error.
4. Payout to the consignor after the sale. Practice varies here:
   • more commonly, the payout is treated as a settlement under an already concluded consignment agreement based on the commission agent's report — a separate "expense" receipt is not required;
   • a more cautious approach is to still issue an "expense" receipt when paying cash directly from the cash drawer to record the movement of funds to an individual. There is no unified position on this specific issue. It is safer to choose an approach that you can consistently support with documents (consignment agreement + commission agent report + cash expense voucher) and establish it in the store's internal rules.

5. Payment Agent (103-FZ)#

A payment agent under 103-FZ is a separate case from a "commercial" agent: they do not sell a specific product or service, but mediate specifically in transferring money from an individual to a supplier (payment for telecom, utilities, fines, online services). A payment agent's receipt is required to additionally show, on a separate line, the amount of the agent's fee and state contact phone numbers — for the payment agent, the supplier, and the payment acceptance operator. If your business simply sells goods on behalf of a supplier, you need the "agent"/"commission agent" tag, not a payment agent tag; these roles should not be confused, as they have different required receipt data sets.

6. Courier Service: Whose Receipt Is Determined by the Contract#

It is precisely the wording of the contract with the courier service that determines everything. If the contract does not explicitly assign an intermediary role, by default the obligation to fiscalize the payment remains with the seller. The mechanics of physical fiscalization by the courier are covered in detail in the article "Receipts upon Delivery".

7. HOAs/Management Companies and Utility Payments#

For HOAs, housing cooperatives, and similar specialized consumer cooperatives, the law historically provided specific exemptions regarding the use of CCPs when receiving payments for housing and utility services. However, the list of exemptions in 54-FZ has changed repeatedly, making it easy to rely on an outdated rule in this narrow topic. The rule that definitely applies to any organization, including HOAs and management companies: cashless settlements without presenting an electronic payment method (a regular bank transfer based on a payment receipt, without a card) do not require a CCP at all — and in practice, this is how property owners most frequently pay for utilities. However, if an HOA/management company accepts cash at the management office or card payments via a terminal, this is a standard transaction with an individual, and the right to an exemption most likely no longer applies. Before relying on an exemption, check with your local tax authority regarding its current scope as it applies to your legal entity form and payment collection method.

8. Travel Agency: Selling a Tour on Behalf of an Operator#

When a travel agency sells a tour on behalf of a tour operator, the receipt is issued by the agency at the moment of receiving payment from the tourist — using the "agent" attribute (or "attorney", depending on the contract type), the receipt total equals the full cost of the tour paid by the tourist, rather than the agency commission. In the supplier details for the tour item, the name and TIN of the tour operator are specified. The agency commission subsequently transferred by the tour operator to the agency is a settlement between legal entities and does not require a separate receipt issued to an individual.

9. Example#

Consignment clothing store, FFD 1.2. Consignor O. Ivanova brought a jacket for consignment under agreement No. 45 (individual, without TIN). The jacket was sold for 4,000 ₽, store commission — 30% (1,200 ₽).

1. Acceptance of the jacket — no receipt is issued; only an acceptance certificate and a consignment agreement are drawn up.
2. Sale to the customer — receipt: income, "Jacket (consignment)", 1 × 4,000.00, calculation subject attribute "goods", agent attribute "commission agent", supplier data — O. Ivanova, without TIN.
3. The store pays Ivanova 2,800 ₽ (4,000 − 1,200 commission) based on the commission agent's report — a separate "expense" receipt is not issued; payment is confirmed by a cash disbursement voucher and the commission agent's report.

10. How to do this in Cenaly#

• In POS, agency and commission items are created in the catalog as a separate item type: the agent attribute and supplier details are filled in once in the item card and automatically added to every receipt.
• Receipt history with the agent tag is located in POS → Receipts (receipts), where you can also see which items have the tag and supplier details — convenient for reconciliation with commission agent or principal reports.
• For physical POS terminals, agency receipt printing is configured via Cenaly Hardware Bridge — make sure in advance that the cash register firmware supports the required FFD version (section 3).

11. Frequently Asked Questions#

I'm selling goods that I bought and recorded as my own stock — do I need an agent attribute? No. The agent attribute is set only when legal ownership of the goods/services remains with another party up until the sale to the buyer. If the goods belong to you, it is a standard sale.

I'm a courier service without a separate agency agreement, simply passing money to the store. Do I need a cash register (POS)? Most likely, the store issues the receipt via a remote POS or a mobile cash register with the courier — you are acting as a money transfer channel here, not an independent agent. If a separate agency or payment agreement is signed, see the table in Section 6.

The consignor is an individual without a TIN, but the POS requires this field to be filled in — what should I do? For an individual supplier without sole proprietor status, the TIN field in the supplier's details can normally be left blank. Make sure that the POS software does not block receipt printing when the supplier's TIN is blank — current FFD (Fiscal Data Format) versions permit this.

A homeowners association accepts utility payments by card via a terminal right in the office — can it operate without a POS? Most likely not: accepting card payments via a terminal is a payment presenting an electronic means of payment, so the exemption for non-card wire transfers does not apply here. Check with your local tax authority regarding the current list of exemptions for your legal entity form.

Related articles: gift certificates and deposits · receipts for delivery: couriers, aggregators · marketplaces: who issues the receipt · POS for salons and services

This material is for informational purposes only and does not replace professional accounting advice. Primary sources: Federal Law No. 54-FZ "On the Use of Cash Registers", Federal Law No. 103-FZ "On Payment Acceptance Activities from Individuals Performed by Payment Agents", FTS guidelines (kkt-online.nalog.ru), Art. 14.5 of the Administrative Code of the Russian Federation.