MChD and signing a contract in 2026: authority before the deal

From 1 February 2026 the rules for a machine-readable power of attorney (MChD) tightened: the format, the requirements for identifiers, and the check of authority all change. If an employee signed the contract with a personal qualified electronic signature (UKEP) “as usual,” and the MChD is outdated or does not cover the deal, the counterparty has a reason to challenge the signature even before a dispute on the terms.

What changes for the MChD in 2026

The reference point for business is the move to the current MChD format (including format 003) and the requirements set by Ministry of Digital Development Order No. 1001. In practice, for a contract, that means the power of attorney must be machine-readable, verifiable, and compatible with the way the employee signs the document in EDO.

• Format 003 instead of outdated versions — otherwise the operator or the counterparty may refuse the MChD
• Correct identifiers of the principal and the representative (INN, SNILS — as the format requires)
• Authority codes from the classifier — not “free text instead of a code,” if the format requires a code
• The term and the possibility of revocation — checked as of the date the contract is signed

The “who signed” chain

An employee often signs with a personal UKEP of an individual and attaches the organization’s MChD. The deal rests on a chain of four links:

1. Who is named as signatory in the text of the contract (full name, position)
2. Whose UKEP is on the file (an individual’s certificate, or the organization’s)
3. Which MChD is attached, or available via the register or the operator
4. Whether the MChD covers this type of deal, and the amount or the subject

A break in any link is a reason for the counterparty not to treat the contract as signed by an authorized person.

What to check before accepting a signed contract

1. Identifiers

• The INN of the principal organization matches the contract
• The representative’s SNILS or INN matches the UKEP certificate and the MChD
• There are no typos or “old” data after a passport change or a personnel-record change

2. Authority codes

• The code (or set of codes) covers conclusion of contracts of the type you need
• There is no amount limit below the price of the deal
• There is no limit of “invoices only” or “certificates only” if the contract itself is being signed

3. Term, revocation, format

• The MChD is in force on the calendar date of the signature
• The power of attorney has not been revoked in the register or with the operator
• The format is current (the reference point is 003), and the file is readable in your EDO system

What to write into the contract and the internal procedure

• Who may sign: the sole executive body, under an MChD, or under a paper power of attorney
• A duty to attach the MChD or to state how it can be verified
• The exchange channel (EDO / a qualified signature) and the file format
• The consequences of a signature by an unauthorized person — re-signing, or the exchange being invalid

On electronic exchange and signatures, see also: electronic contracts.

Checklist before the deal

Related reading

• Electronic contracts
• Hidden clauses in a contract
• Agreeing edits in a contract
• Typical mistakes in contracts

Short conclusion

In 2026, an employee’s signature without a verifiable MChD in the required format is an operational risk of the deal. Before you accept the contract, check the chain: text, then certificate, then MChD, then authority codes. Format 003, the INN and SNILS, and the term are the minimum without which “signed” does not yet mean “authorized.”