Until January 21, tax inspectors are waiting for information from organizations and entrepreneurs about the average number of employees. The rules by which this indicator must be determined for 2018 have changed.
Who submits the report and when?
Not all employers are required to submit a report on the average number of employees to the tax office. For example, entrepreneurs without staff do not need to report (Clause 3, Article 80 of the Tax Code of the Russian Federation). The table shows the organizations that are to submit the report. Check to see if your company is one of them.
Table. Who submits information about the average number of employees?
Type of organization / individual entrepreneur | When to submit a report | Base |
Company or individual entrepreneur with employees | Clause 3 of Article 80 of the Tax Code of the Russian Federation |
|
New individual entrepreneurs with hired employees | Letter of the Ministry of Finance of Russia dated July 19, 2013 No. 03-02-08/28369, |
|
An individual entrepreneur with hired staff ceased operations in the middle of the year | Letter of the Ministry of Finance of Russia dated March 30, 2017 No. 03-02-08/18588 |
|
New or reorganized company | Submit the report twice:
| Clause 3 of Article 80 of the Tax Code of the Russian Federation |
Don’t get confused - we are not talking about statistical reporting (form P-4 “Information on the number and wages of employees”).
Information on the average number of employees is submitted in the recommended form, which was approved by order of the Federal Tax Service of Russia dated March 29, 2007 No. MM-3-25/174. You can submit the report to the tax authority either electronically or in paper form.
In this case, the calculation rules apply the same as for statistical reporting and for form 4-FSS: they were approved by Rosstat Order No. 772 dated November 22, 2017 (hereinafter referred to as Order No. 772). This document replaced the previous order of Rosstat dated October 26, 2015 No. 498, which was in force until 2018, and there are differences in it.
A sample of filling out information on the average number of employees for 2018.
How to calculate the average number of employees
Let's consider step by step the calculation of the average number of employees.
Step 1. Calculate the headcount for each day of the month
Add to the report only those employees with whom employment contracts have been concluded (clause 76 of the Instructions for filling out the form, approved by Order No. 772). It doesn’t matter whether the employee is on vacation, sick leave or on a business trip. But there are employees who do not need to be shown in the average number. They are named in paragraph 78 of Order No. 772:
- employees on civil servants' contracts;
- external part-time workers;
- founders of the organization who do not receive salaries;
- lawyers, etc.
Example 1. Calculation of the number of employees
As of November 30, 2018, Sosna LLC had 12 employees. Two of them are external part-time workers, and one employee works under a contract agreement.
12 people - 2 people - 1 person = 9 people
Step 2: Determine the monthly number of full-time employees
To calculate the average number of full-time employees, use the formula:
The total headcount of full-time employees for each day of the month includes weekends and holidays.
Do not include workers on maternity leave, “children’s” leave, or part-time workers in the calculation. Also do not take into account employees who took leave at their own expense for study or to enter a university (clause 79 of Order No. 772).
Attention: If an employee works part-time while on maternity leave, do not exclude her from the average payroll. Such rules are established in Order No. 772 and have been in effect since 2018. This item was missing in the old procedure for filling out the form, approved by Rosstat order No. 498 dated 10.26.15.
Example 2. Calculation of the monthly number of full-time workers
Let's return to the conditions of Example 1. The number of employees at Sosna LLC as of November 30 is 9 people. Seven of them work full time. Two employees went on maternity leave on November 5 and 19.
Let us determine the number of employees on the payroll for all days of November:
(9 people x 4 days) + (8 people x 14 days) + (7 people x 12 days) = 232 people.
Let's calculate the average number of full-time employees:
232 people/30 days = 7.73 people
Step 3: Calculate the monthly number of part-time employees
Count part-time workers in the monthly headcount in proportion to the hours worked. Count the number in two stages (clause 79.3 of Order No. 772):
- Determine the number of man-days worked by part-time workers. To do this, divide the monthly amount of man-hours by the length of the working day.
- Calculate the monthly number. To do this, divide the number of man-days per month by the number of working calendar days in the month.
Example 3.Calculation of the monthly number of part-time workers
The number of employees at Sosna LLC as of November 30 was 9 people. Two employees work part-time: 2 and 6 hours a day.
Let's calculate the number of man-days for November:
2 person-hour x 21 days / 8 hours + 6 person-hour x 21 days / 8 hours = 21 person-day
Let's calculate the average number of employees per month:
21 person-day / 21 days = 1 person.
Step 4. Calculate the average number of employees per month
To get the average number of employees for a month, add up the number of full-time and part-time employees for this period. If you get a fractional indicator, round it to a whole value (clause 79.4 of Order No. 772).
Let's determine this indicator for November using data from previous examples:
7.73 people + 1 person = 8.73 people (rounded up to 9 people).
Step 5. Determine the average number of employees for the year
Calculate the average number of employees for the year using the formula:
Attention
To determine the number of employees for the first quarter, add up the number of employees for January, February and March and divide by 3. The number for six months and 9 months is determined in the same way.
Example 4. Final calculation of the average headcount for the year
During 2018, the average number of employees at Sosna LLC was:
Month | Average headcount, people. |
September | |
Let's determine the indicator for the year:
(8 people + 8 people + 7 people + 8 people + 8 people + 9 people + 9 people + 8 people + 8 people + 7 people + 9 people + 7 people) / 12 months = 8 people
The accountant filled out the report as shown in the example below.
It remains to add that if you submit information about the average headcount late, the inspectors will issue a fine of 200 rubles to the company or entrepreneur (Clause 1 of Article 126 of the Tax Code of the Russian Federation). For the head of an organization, the sanction will range from 300 to 500 rubles. (Article 15.6 of the Administrative Code).
Sample. Information on the average headcount for 2018 (completed sample)
One of the important indicators by which regulatory authorities evaluate the activities of companies and individual entrepreneurs is the average number of employees. In this material we will answer the main questions: who is obliged to submit such information and where? How to correctly calculate the average number of employees? Where can I get a sample form?
A certificate of the average number of employees is issued in the form KND 1110018. You can download this document and a sample of how to fill it out at the bottom of the page.
Who submits data on the average number of employees
All entrepreneurs are required to submit information on the average number of employees to the tax office (at the place of registration of the enterprise or organization). It doesn’t matter whether we are talking about an individual entrepreneur or an LLC, another form of organizing production activities. This requirement is stated in paragraph 7 of Article 5 of Law No. 268 of December 30, 2006.
Starting from 2007, even entrepreneurs who do not have employees were required to submit such data. It’s just that in this case, when preparing the appropriate reporting, they entered the number “zero” in the required column. Since 2014, for individual entrepreneurs without employees, the report on the average headcount has been cancelled.
How to calculate the average number of employees per month?
These calculations are made for the year, quarter, but to obtain these results you will definitely need to know the formula for the average number of employees per month.
To obtain the required data, that is, the average number of employees per month, you need to add up the number of employees employed on each calendar day of the month, and then divide this amount by the number of calendar days in this month.
When we talk about calendar days, we take into account both holidays and weekends. It is simply conventionally considered that on these days the number of employees is equal to the number of employees who worked at the enterprise on the last working day before. The number of employees must also include those colleagues who are on leave or vacation on the billing days, are on sick leave, or have been sent on a business trip.
Calculations for the quarter, year and rounding of figures
Knowing the average number of employees per month, it is very simple to calculate it for the quarter: add up the data for three months and divide the result by three.
Similarly, we calculate the average value for the year. The same as we were taught at school: we need to find the sum of values for all 12 months (from January to December inclusive) and divide the found figure by 12.
We don’t always end up with “round” results. But the law provides for their rounding. How to calculate the average number of employees taking into account this nuance? Also, remembering the rules that were explained to us in mathematics lessons at school. They are universal and work in this case too. Rounding is required at least so that the tax reports do not include ridiculous and frightening figures of one and a half cooks or, say, 2.7 shoe repair specialists.
So the principle is simple:
- when the number after the decimal point is 4 or less, we simply remove the decimal places. Let's say 2.3 rounded to 2.
- If the decimal point is followed by the number 5 or greater, add one to the whole number. For example, 3.7 is rounded to 4.
Some features of calculating the average number of employees
Download the 2019 average number of employees form on our website, review it, and practice filling out the form. Then there will be no difficulties when preparing the document for tax purposes.
Order of the Federal Tax Service dated March 29, 2007 No. MM-3-25 / 174 “On approval of the form of Information on the average number of employees for the previous calendar year” is the main document regulating the document flow in this area. This Order approved the form for submitting information: KND 1110018. More detailed recommendations for filling it out can be found in the letter of the Federal Tax Service of Russia dated April 26, 2007 No. CHD-6-25 / 353.
The calculations can be made by the entrepreneur himself or by the company’s accountant. Data on the average number of employees for the 2018 calendar year must be submitted to the tax authority by January 20, 2019. They will include information for the period from January 1 to December 31, 2018.
Every month, as a rule, the number of employees who work full time is calculated first. Then they count their part-time colleagues. And they add up the results for the month, then for the year. According to the rule already described above, the average figure for the year is calculated.
When calculating the average payroll number, you must be guided by the Rosstat Instructions given in Order No. 772 dated November 22, 2017. According to this document, the payroll includes those hired under an employment contract, including the founders of the company if they receive a salary.
Who is not included in the average headcount?
- lawyers;
- external part-time workers;
- military personnel;
- employees sent to work in another country;
- everyone with whom a vocational training agreement has been concluded, providing for the payment of a stipend during the apprenticeship period;
- employees studying in educational institutions and on additional leave without pay, as well as those entering educational institutions and on leave to take entrance exams without pay;
- owners of an enterprise/organization who do not receive a salary;
- everyone who performs work on the basis of civil contracts;
- employees who submitted a letter of resignation, but completed work before the notice period expired, or stopped work without warning the administration;
- women who went on maternity leave, as well as persons on additional child care leave (except for those working part-time or at home, while retaining the right to receive state social insurance benefits (clause 79.1 came into force from 01.01 .2018 by Order of Rosstat dated November 22, 2017 No. 772));
- individual entrepreneurs.
External part-time and part-time workers
There is a category of employees who are considered internal part-time workers. That is, they receive one and a half or two rates within their organization. But according to accounting, such an employee must be registered as one whole unit. The situation is different for external part-time workers. When calculating the average number of employees, they are not taken into account. Simply because they are registered at their main place of work.
The situation is a little more complicated with part-time employees. Here, accounting is proportional to the time worked. Don't forget that we should end up with rounded whole work units. Let's say the company has two employees working part-time, 4 hours a day, a full work week. The calculation here is simple: together they will give one working unit with a full day of employment.
When the number of hours worked is different, the average number of part-time employees is calculated as follows. The total number of man-hours worked by this category of employees per month is divided by the length of the working day. We divide the resulting quotient again by the number of working days in a given month.
If the initial duration of the working day is not given, we calculate it based on data on the duration of the working week. Let's say the workweek contains forty hours, then the workday will last eight hours (40 / 5).
Example calculation example
To correctly fill out a sample certificate of the average number of employees, read the calculation example.
Let’s say that in the first half of July 2018, there were 100 people in the organization. Then the staff was increased for seasonal work, and in the period from July 16 to July 30 there were 150 workers. For the entire month, two women were on maternity leave, so we must exclude them from the payroll. The rest of the employees worked full time.
We calculate the average number for July. 15 days x (100 people - 2 people) + (150 people - 2 people) x 15 days = 3690 people. Now all that remains is to divide this number by 31 (the number of calendar days in July) and round the resulting data. From division we get the number 119.032. After rounding, the result remains 119 people. We make calculations similarly for any other month, as well as a quarter and a year.
Deadlines for submitting a report on the average number of employees
The reporting deadline for different categories of individual entrepreneurs and organizations is different.
For existing individual entrepreneurs and organizations, it is necessary to provide a report on the average headcount at the end of the reporting year by January 20 of the year following the reporting year.
Newly created or reorganized organizations, in addition to the annual report on the average headcount, submit another report no later than the 20th day of the month following the month in which the organization was created. Individual entrepreneurs are exempt from such reporting.
When liquidating an organization or closing an individual entrepreneur, a report on the average headcount must be submitted no later than the date of deregistration.
Where to submit the HRC report in 2019
Reports on the average number of employees of individual entrepreneurs and LLCs are submitted to the tax authorities:
- Individual entrepreneur at the place of residence;
- LLC at the location, respectively, legal address.
Fine for violating the deadline for submitting reports on the average headcount
As with any report not submitted to the Federal Tax Service on time, violation of the deadline for submitting a report on the average number of employees is punishable by a fine:
for individual entrepreneurs - 200 rubles;
for an organization - 200 rubles, for the head of an organization from 300 to 500 rubles.
Certificate of average number of employees: sample and form
Click the button below to download the average number of employees form and a sample for filling out this document.
Information on the average number of employees for the previous calendar year is submitted to the tax office before January 20. This day in 2018 falls on a weekend, which means the deadline for submitting the average headcount is postponed to January 22, Monday.
Who passes the average number
Important! The deadline for sending information on the average headcount for 2017 for organizations and individual entrepreneurs is January 22, 2018.
Entrepreneurs are also required to submit information, but only those individual entrepreneurs who do not have employees, or rather did not have any in 2017. If the individual entrepreneur did not have any employees during this period, then there is no need to submit information, including zero calculation.
The information provided will affect the right of organizations and individual entrepreneurs to apply a special tax regime, as well as the obligation to submit tax reports in paper or electronic form, the obligation to pay or exemption from VAT, etc. This must be done within the period established by law.
Separate divisions do not independently submit information to the tax authority. They prepare the calculation and send it to the head office, and the head office submits information for the entire company, including all divisions.
Let's look at an example ⇓
The company Continent LLC was registered as a legal entity in August 2017. The first time information must be submitted by Continent LLC before September 20, 2017, as of September 1, 2017. And the second time, information must be submitted at the end of the year, before January 22, 2018, as of January 1, 2018.
But what if the organization registered at the beginning of the year, that is, in January. All organizations will have to prepare information by the 20th, but what about a newly registered organization?
To answer the question, let’s look at another example, when the organization Vesta LLC was registered only in January 2018. Do I need to submit information before January 22, 2018? Vesta LLC will also need to provide information twice for 2018. The first time - until February 20, 2018, as of February 1. The second time the information will need to be submitted in 2019, together with other organizations, by January 20, 2019. Thus, in January 2018, namely until the 22nd of Vesta LLC, there is no need to submit information.
Important! Organizations and individual entrepreneurs that registered in January 2018 do not need to submit information about the average number of employees. They must provide information only as of February 1, 2018, and the deadline for submission is no later than February 20, 2018.
How to submit information about the average number of employees
The form by which information on the number of personnel of an organization is submitted is form No. MM-3 25/174@, approved by order of the Federal Tax Service of the Russian Federation dated March 29, 2007. Information is submitted to the Federal Tax Service where the organization or individual entrepreneur is registered. If the organization has separate divisions, then they should not report separately. Information is submitted to the tax office by the parent organization for all employees, including separate divisions.
Information can be submitted both in paper and electronic form. On paper, information is submitted personally to the Federal Tax Service or sent by mail. Only those organizations whose staff does not exceed 200 people can submit information in this way. For those organizations with more than 200 people, they are required to submit information only in electronic form.
Responsibility for late submission of the average headcount
Penalties for failure to submit or untimely submission of information are provided for by the Tax Code of the Russian Federation of the Code of Administrative Offenses of the Russian Federation:
- 200 rubles – for organization
- 300 – 500 rubles – per manager.
The Federal Tax Service usually imposes a fine only on the organization. A manager can only be fined by a court decision, that is, in order for the Federal Tax Service to be able to collect a fine from the manager, it will have to go to court.
Payment of the fine does not exempt organizations from submitting information. The organization is obliged to provide information regardless of payment of the fine.
In addition to fines for late submission of reports, the tax office has the right to block the account of a company or individual entrepreneur. But the requirement applies only to tax returns, or requirements for payment of taxes, penalties or fines. As for information about the average number of employees, the Federal Tax Service does not have the right to block the current account for late submission.
Who is included in the average headcount?
The following employees are required to be taken into account when calculating the average salary:
- who are on a business trip;
- who are on sick leave;
- who works remotely;
- who is on vacation (annual or additional);
- employees who have a day off on the day of payment;
- employees on leave;
- workers who have absenteeism.
The following list contains those persons who should not be taken into account when calculating the average salary:
- external part-time workers;
- working under a civil contract;
- employees who are on maternity leave (or due to adoption);
- workers who are on maternity leave.
Formula for calculating the average number of employees
Below is the formula for calculating the average headcount:
SCh = SChm / M,
SP – average number of employees for the period,
SChm – average number of employees for each month of the period,
M – number of months in the period.
For each month, the average headcount is determined as follows:
SChm = SPp + SPn,
SPP – average number of full-time employees;
SPN – average number of employees with part-time work.
The number (on the payroll) of Continent LLC in November 2017 was from the 1st to the 20th – 62 people, from the 21st to the 30th – 38 people. Two employees were on maternity leave this month, so they should be excluded from the calculation. Let's make the calculation:
(62 – 2) x 20 days + (38 – 2) x 10 days = 1,200 + 360 = 1,560 people
The average number of employees in October will be:
1,560 / 30 = 52 people
Continent LLC has a 5-day work week with a working day of 8 hours. Three employees work part-time, equal to 5 hours.
In November, 2 of these employees worked 21 working days, and one only 15 working days.
Let's determine the total number of man-days:
5/8 x 21 x 2 + 5/8 x 15 x 1 = 26.25 + 9.375 = 36 person/day
The average headcount for these employees for November was:
36 / 21 = 1.71 people
The legislative framework
| Legislative act | Content |
| Letter of the Ministry of Finance of Russia No. 03-02-07/1/4390 dated 02/04/2014 | “On registration with the tax authority, as well as on the submission of a single (simplified) declaration and information on the average number of employees of a newly created organization that does not have objects of taxation and employees” |
| Article 126 of the Tax Code of the Russian Federation | “Failure to provide the tax authority with information necessary for tax control” |
| Article 80 of the Tax Code of the Russian Federation | "Tax return, calculations" |
| Article 15.6 of the Code of Administrative Offenses of the Russian Federation | “Failure to provide (failure to report) information necessary for tax control” |
| Letter of the Ministry of Finance of Russia No. 03-02-07/1-38 dated 02/14/2012 | “On the issue of reporting by the head office for its branches” |
The average headcount for newly created organizations is one of the first mandatory reports. Companies often forget to provide this document to the Federal Tax Service. Meanwhile, there are legislative deadlines for filing it.
Even if the company has not yet managed to conclude employment contracts with hired personnel, the average number of employees upon opening is submitted according to the general rules. Let's figure out how to fill out this form, when to submit it and where. For your convenience, at the end of the article there is a report on the average headcount of the newly created organization - a sample is available for download.
At the legislative level, the requirement to provide this report is enshrined in clause 3 of the statute. 80 Tax Code of the Russian Federation. Why do control government agencies need this information? First of all, information on the number of personnel for the past year helps to justify the format for submitting declarations and other forms to the Federal Tax Service, Social Insurance Fund and Pension Fund. If a company’s total capital indicator exceeds 100 people, it will only have to report electronically. If the value is less than 100 people, paper reporting is also allowed.
In addition, calculating the number of businesses makes it possible to justify the legality of using special regimes. For example, running a simplified business is permitted if the number does not exceed 100 people. SSC when opening an LLC is mandatory for all enterprises, regardless of the legal status of the company and the types of OKVED. Moreover, this norm is also true for entrepreneurs. True, in the latter case there are exceptions. If the individual entrepreneur does not have hired employees, you do not need to fill out and submit this report.
When and where is the average number of employees rented when opening an LLC?
Information about the average headcount of a newly created organization is provided to the territorial division of the Federal Tax Service at the place of registration of the taxpayer. The general frequency of submission of such data is annual. In this case, the document is submitted based on the results of the past year by January 20 of the next year.
But if the company has just been registered, the new organization submits information about the average number of employees by the 20th day of the calendar month following the month of opening. This requirement also applies to reorganized enterprises. Legal entities submit the form regardless of whether or not they have concluded employment contracts. Individual entrepreneur - only when registering labor relations with hired personnel.
For example, for 2017 it was necessary to report before January 22nd. According to the norms of clause 7 of stat. 6.1 The Tax Code deadline has been slightly delayed due to the coincidence of the approved filing date (January 20th) with a day off - Saturday. Let’s say the company was registered on June 19, 2018. In this case, reporting is required before July 20. And if an individual entrepreneur without hired specialists was registered on the same date, there is no need to submit information.
Average number of employees when opening an LLC - filling procedure
The standard report form is approved by the tax authorities. The current form is valid in accordance with Order of the Federal Tax Service of Russia No. MM-3-25/174@ dated March 29, 2007. The document has not changed since its development, because it is a simple type of reporting with minimal data.
The average headcount of a newly created organization, a sample is posted below, is filled out according to the general rules. The calculation of the indicator takes into account those employees with whom the company has concluded employment contracts. If the company has only one employee, who is also a director, he must be included in the calculation of the indicator. If the organization does not hire a single specialist, and there is only a founder with whom an employment contract has not been signed, the headcount indicator will be “0”.
The procedure for calculating the number of personnel in 2018 (both payroll and average payroll) is regulated by Rosstat in Order No. 772 dated November 22, 2017. It determines which categories of personnel are not included in the calculations (external part-time workers; persons hired under the GPA; women on maternity leave and etc.); which ones are included (those on sick leave, on business trips, homeworkers, etc.). The Order also provides an algorithm for mathematical calculations for indicators for a quarter, month, year (full or not).
Note! Typical recommendations from tax officials for filling out the report are contained in Letter No. CHD-6-25/353@ dated April 26, 2007. The form has one page. The certificate contains information about the company. The name of the territorial branch of the Federal Tax Service and its code are given separately. The date on which the MSS is determined is entered in the following order:
- As of 01/01/2018 – when submitting reports for the full year 2017.
- On the 1st day of the month that follows the month of opening on the calendar - when filing reports for a newly created company.
The indicator is indicated in rounded form, that is, in whole units. The TSS for the year is calculated from monthly headcount values (average) by summing the data and dividing the total by 12 months. The document is certified either by the head of the company or an authorized representative.
Average number of employees – zero reporting
In the case of information about the number (average), this option is possible when a zero indicator is indicated in the document. This is not a violation. For example, the return of the average headcount of a newly created organization will be accompanied by a zero value if the company has only a founder, but no employees.
In such a situation, it is necessary to submit the form to avoid penalties. The size of the sanction is 200 rubles. (Clause 1 of Article 126 of the Tax Code). Additionally, administrative liability is provided for under Part 1 of Art. 15.6 Code of Administrative Offences. The fine for an official, that is, a manager, is 300-500 rubles.
What is the average headcount to indicate when the LLC is not operating? When suspending activities, it does not matter for what reason the business is not being conducted. To report on the SSC, the responsible employee takes data on the number for the previous year. If there were no employees in some months, the value for that period will be zero. To determine the indicator for the year, the data by month is first summed up, then the total is divided by 12.
Average payroll when opening an LLC - example of a form
Let’s assume that the company was registered in June 2018. In the same month, the employer entered into an employment relationship with 3 employees. Information is submitted to the Federal Tax Service in accordance with the general procedure, that is, before July 20, 2018.
In this case, the company fills out a form indicating its data. Information is taken from registration documents. The date column contains “07/01/2018”. The headcount indicator is 3, including the director. The report is submitted to the territorial division of the Federal Tax Service at the place of registration of the business. Submission format: paper or electronic. When submitting “on paper”, two copies of the document are filled out - one remains with the taxpayer.
If you find an error, please highlight a piece of text and click Ctrl+Enter.
Please note that information can be submitted either electronically or on paper in person or by mail. In the latter case, you will need to send a letter with a description of the attachment and a notification of delivery.
The report form was introduced by Order of the Federal Tax Service dated March 29, 2007 No. MM-3-25/ You can download it at the end of the article. The completed sample looks like this:
Sample filling
Report form
Responsibility for failure to submit
Information on the average number of employees must be submitted by January 20 of the year following the reporting year. If this date falls on a weekend, the deadline is transferred to the next working day. If the company does not have time or forgets to submit this report, it will be fined 200 rubles: this is provided for in paragraph 1.
According to Letter No. ED-4-15/ of the Federal Tax Service dated December 20, 2018, lists of entrepreneurs who failed to fulfill their obligation within the prescribed period in 2019 will be formed on the 20th working day after the deadline expires, that is, by February 18. After this date, businesses will begin receiving notifications of fines. In addition, the tax authority, which has not received the necessary information, will begin proceedings in the case of a tax offense in the manner prescribed, “regardless of the conduct and implementation of the results of a desk tax audit of tax calculations,” as required by the Federal Tax Service in Letter dated July 16, 2013 No. AS- 4-2/12705. If a violation of the legislation on taxes and fees is proven, the company official will also be fined, but under Part 1. The fine for this is small - up to 500 rubles, but still unpleasant.
Please note that if an organization has not submitted a report, it will still be required to do so. Holding the company and its manager accountable will not solve anything; the obligation to report on the number of employees will remain. The tax authority will determine when this needs to be done.
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