Moratorium Interest in Russian Bankruptcy: Accrual and Calculation

Moratorium interest is a statutory form of compensation for the period in which ordinary default interest, penalties and other financial sanctions stop accruing in Russian bankruptcy. It is neither a current claim nor a replacement for principal. The calculation depends on the procedure, its commencement date, the adjudicated principal and the date of actual payment.

What Moratorium Interest Replaces

When observation begins, default penalties and similar financial sanctions on registered obligations stop accruing. Federal Law No. 127-FZ replaces them with special statutory interest on principal. The Supreme Court describes this as compensation for inflationary loss during the collective procedure.

Principal, Rate and Partial Payments

The base is the adjudicated principal amount. Penalties and moratorium interest are not automatically capitalised. The applicable provision links the rate to a specified procedure date and refers to the Bank of Russia refinancing rate.

After a partial payment, further interest is calculated on the remaining principal. A reviewable schedule should show each period, opening and closing base, rate, day count and payment.

Company Procedures from Observation to Liquidation

Article 63(4) applies in observation. Article 81 governs financial rehabilitation and its repayment schedule. Article 95 covers external administration until distributions, payment or liquidation. Article 126(2.1) continues the special regime during liquidation until actual payment.

When the procedure changes, the calculation should be separated into intervals because the governing provision and reference date may change.

Individual Debt Restructuring

Article 213.19 regulates interest on claims included in an approved restructuring plan. The Supreme Court has also held that moratorium interest runs from commencement of individual restructuring even when no plan is approved. Actual payment depends on full satisfaction of registered claims and sufficient funds.

After asset realisation, any surviving claim and remaining interest depend on the underlying liability, the completion order and the non-discharge rules.

Building an Auditable Schedule

1. collect orders opening and changing procedures;
2. reconcile principal to the claims register;
3. separate current claims and sanctions;
4. split the timeline by procedure;
5. apply the legally prescribed rate date;
6. record each partial payment;
7. reconcile the result to bank statements and distribution records.

The arithmetic alone is insufficient: every row should reveal its legal basis.

🧮 Partial repayment: checking a two-period schedule

This section was checked on 25 October 2026 against Article 126(2.1) of Law No. 127-FZ and paragraph 7 of Plenum Resolution No. 88. It concerns company liquidation proceedings.

For a rouble claim, the rate is tied to the opening date of liquidation proceedings. Do not automatically replace it with every subsequent Bank of Russia rate. Check any agreement with the insolvency practitioner: the law permits a lower interest amount or shorter accrual period. Paragraph 7 of Resolution No. 88 excludes moratorium interest on interest attached to the principal claim.

This is not a complete case calculation or a promise of payment. An actual schedule must state calendar boundaries, the basis for including each day, days in the relevant year, verified payment allocation and the rounding method. Split periods when the year or procedure changes; do not count a day twice.

Records to attach

1. The claim-admission order and register data separating principal, interest and sanctions.
2. The liquidation judgment and evidence of the rate on its date; any agreement reducing that rate.
3. The bank statement and distribution record allocating the payment between principal and interest.
4. The period table with a formula for every row and the remaining base after repayment.

A creditor’s request framework

“Please provide the moratorium-interest calculation for [amount, court order], identifying the rate date and basis, composition of principal, period boundaries, treatment of the [date, amount] payment, and any agreement changing the amount or accrual period. My schedule and supporting records are enclosed.” Identify the disputed row rather than only the overall total.

Article 126(2.1) · Plenum No. 88, paragraph 7.

Frequently Asked Questions

Official Sources

• Article 81 of Federal Law No. 127-FZ.
• Article 95.
• Article 126.
• Article 213.19.
• Supreme Court 2023 bankruptcy review.
• Supreme Court Review No. 2 (2019).

Related guides: current claims, claims register and creditor distributions.

This material is general information as at 28 August 2026. The calculation depends on the procedure, court orders, claim composition and actual payments.