Marketplaces: Who Issues Receipts Under FBO, FBS, and DBS

A seller on Wildberries or Ozon is often convinced that they don't need to deal with cash registers at all — believing the platform "issues everything itself." This is only true for certain sales models. We break down the core principle and specific models: FBO, FBS, DBS, returns, marking, and hybrid sales.

1. Core principle: the receipt is issued by whoever accepts the money#

Federal Law No. 54-FZ ties the obligation to issue a receipt not to the party that sold the product, but to the party that actually received the payment from the individual buyer. If the platform accepted the money into its own account, it handles fiscalization, acting as a payment agent. If the seller ultimately receives the money directly (not through the platform's checkout), the obligation to issue the receipt lies with the seller, regardless of the fact that the item was sold "via a marketplace." This rule is identical for all FBO/FBS/DBS models below — from here on, it is simply a question of which party actually accepts the payment in a given model.

2. Table: marketplace operating models#

The key mistake is assuming that just because an order came "from a marketplace", a cash register is automatically not needed. You need to look not at the source of the order, but at who actually accepted the money at that specific moment.

3. FBO and FBS with Payment via the Platform — Seller's Cash Register Not Needed#

In classic FBO, the platform stores the goods in its own warehouse and fully handles settlements with the buyer — from receiving payment to delivery and issuing a receipt. The seller does not need their own cash register for these sales: the agent receipt is generated and stored by the marketplace.

FBS works similarly as long as payment goes through the platform's website during checkout: the seller only stores and packages the goods, while money handling and fiscalization are on the marketplace side. The difference between FBO and FBS has no practical significance for the topic of cash registers — what matters is specifically the point of payment acceptance, not where the goods are stored.

4. DBS/realFBS with Pay on Delivery — Seller's Responsibility#

If the seller delivers an order using their own courier and the courier accepts payment on-site (in cash or by card via a mobile terminal), the transaction occurs outside the platform's register — the marketplace does not see the payment at that moment and does not generate a receipt. The seller is required to fiscalize such a sale: via a mobile fiscal register carried by the courier or a remote cash register "outside the place of settlement" with fiscalization at the moment of payment at the door. A detailed breakdown of this process, including options for on-the-go couriers, is available in the article "Receipts on delivery".

5. Returns: Mirror Rule#

Whoever issued the original sales receipt issues the return receipt:

1. If the customer initiates a return for goods purchased via a platform-payment scheme (FBO/FBS/DBS paid on the website), the marketplace generates the return receipt; the seller does not need to issue anything extra.
2. If the goods were paid directly to the seller's courier (DBS with payment upon delivery) and the customer receives a refund, the seller issues the return receipt using the same method originally used to accept payment.

These flows must not be mixed: if the platform issued the original sales receipt, but the seller refunded the money directly bypassing the platform (or vice versa), a discrepancy will arise in reporting that is difficult to explain during an audit.

6. Sales on both marketplaces and via own channels#

If the same seller trades simultaneously on a marketplace (under an agency model) and through their own website, offline store, or social media, a POS is needed precisely for their "own" channels — there, money is accepted by the seller themselves, and the marketplace's agency receipt does not cover this part of the turnover. The general principle of "who needs a POS" and typical exceptions (self-employment, patent) are discussed in the article "Who needs an online POS" — for marketplaces, there is also a summary table on payment schemes there.

7. Reconciliation: Platform Agent Report and Revenue in Tax Return#

Even if the seller does not issue receipts for agency sales, the entire amount paid by the customer is their revenue for tax accounting purposes, not just the portion that the marketplace transferred to the seller's account after deducting commission, logistics, and other fees. The platform usually provides an agent report (report to consignor/principal) showing the total sales amount as a separate line item — it is precisely this amount, rather than the net payout received in the account, that must be reconciled with the revenue reported in the tax return. The revenue recognition procedure depends on the tax regime and the exact wording of the contract with the platform — check with your accountant on how exactly to perform this reconciliation in your case.

8. Labeling on FBS: Who Retires the Code from Circulation#

For labeled goods, the fact of sale alone is not enough — the Data Matrix code must be retired from circulation in the "Chestny ZNAK" system, specifying who exactly did it. With FBS, this can be either the marketplace itself (if it has technical integration and a corresponding clause in the agreement) or the seller — the rule is not uniform for all platforms and categories. Check specifically according to your contract and your "Chestny ZNAK" account: if the platform is supposed to retire the code, but in reality it remains unretired, the seller may be held responsible for the item in circulation. General error mechanics when working with labeling at the checkout can be found in the article "Labeling at POS".

9. Self-Employed Individuals on Marketplaces#

A seller under the Professional Income Tax regime who sells through a platform still generates sales receipts via the "My Tax" app—regardless of the order coming from a marketplace, self-employed status maintains the exemption from cash registers. The moment for generating a receipt is the receipt of income, not the act of shipment; if the platform transfers money with a delay, focus on the date the funds are received, not the order date.

10. Fines: Borne by Whoever Was Obligated to Issue the Receipt#

If the customer did not receive a receipt, liability under Article 14.5 of the Administrative Code is borne by the party that actually accepted the payment and was obligated to fiscalize the transaction — that is, either the marketplace (for its agency sales) or the seller (for DBS delivery with payment at the door or direct sales bypassing the platform). The seller is not responsible for a failure in the platform's POS for FBO/FBS sales, but is obligated to issue receipts for everything accepted directly — mixing models in reporting like "we are a marketplace, we don't need a POS" does not protect against a fine where the money was actually accepted by the seller.

11. Example#

A clothing retailer operates across three channels: FBO on Wildberries (the marketplace stores, delivers, and accepts payment — 60% of turnover), DBS on Ozon with payment upon receipt (25% of turnover — the courier uses a mobile cash register), and their own website with online payment (15% — cloud cash register). Over the month: for FBO, the seller does not issue a single receipt — they are all handled on Wildberries' side; for DBS, couriers fiscalize every payment at the doorstep; for the website, receipts are generated by the cloud cash register upon payment. When reconciling with the tax return, the accountant takes the full sales amount from the Wildberries agency report (before deducting the marketplace commission), rather than the actual amount transferred to the account.

12. How to do this in Cenaly#

• Sales through your own website and processing online payments are fiscalized automatically at the moment of payment — just like in a regular online store, see "Online Store: Moment of Receipt".
• For DBS delivery with payment to the courier upon receipt, a mobile cash register or a remote cash register "outside the place of settlement" via Cenaly Hardware Bridge is used — fiscalization occurs at the moment money is handed to the courier.
• The history of all receipts across direct channels (website, dining area, delivery) is located in POS → Receipts, see receipts and refunds; sales under marketplace agency schemes are not displayed there — the platform itself fiscalizes them, reconcile them separately with its agency report.

13. Frequently Asked Questions#

FBO/FBS: the marketplace accepts money — does that mean the platform always issues the receipt? In most cases, yes, if the payment actually goes through the platform, but not automatically — under DBS with payment to the seller's courier upon receipt, the obligation transfers to the seller, even if formally it is the same marketplace.

I sell both on a marketplace and through my own website — do I need a cash register for the entire turnover or only for a part of it? Only for channels where the seller accepts money directly: your own website, physical location, DBS with payment at the door. Your cash register does not cover and should not cover agency sales on the platform — a marketplace receipt has already been issued there.

Tracked goods are sold via FBS — am I required to withdraw the code from circulation myself? It depends on the terms of the specific contract with the platform and its technical integration with "Chestny ZNAK" — there is no single rule, check in your account dashboard who actually submits data for your goods.

Who will receive a fine if the buyer did not receive a receipt for a marketplace order? To whoever was obligated to fiscalize that specific payment: if the platform accepted the money, it's their issue; if your courier accepted the money upon delivery, the obligation and liability are yours.

Related articles: who needs a cash register · receipts upon delivery: couriers, aggregators · marking at the checkout · online store: timing of the receipt

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", methodological guidelines of the Federal Tax Service (kkt-online.nalog.ru), Art. 14.5 of the Code of Administrative Offenses of the Russian Federation.