Civil law consequences of the absence of a freight forwarder in the notification register of transport and forwarding activities

Starting from March 1, 2026, the right to engage in transport and forwarding activities is conditional upon the placement of information about the forwarder in the notification registry of the national digital transport and logistics platform "GosLog." The "GosLog" registry functions to grant access and redistribute evidentiary and risk-oriented obligations of the parties, but does not replace the analysis of the contract's content and the distribution of responsibility between the forwarder and the carrier. By establishing a public legal condition for access to the market, the legislator has remained silent on the private legal consequences of operating outside the registry, which has created a research problem. Objective: To establish how the absence of a registry entry affects the validity of the transport forwarding contract, the client's obligation to pay for services rendered, the possibility of recovering damages, and the standard of good faith of the client when selecting a counterparty. A formal legal method and comparative legal method were used, as well as an analysis of the practices of the Supreme Court of the Russian Federation and arbitration courts from 2022 to 2026, along with Russian-language doctrine from 2021 to 2026 regarding transport forwarding contracts, forwarder liability, and the principle of good faith. The "GosLog" registry amendment is examined not in the usual administrative context, but in a civil law context; a distinction is made between the access condition for professional activity and the validity test of the transaction; a multifactorial model for dispute resolution is proposed, replacing the binary scheme of "there is an entry – the contract is valid, there is no entry – the contract is void." It is argued that the absence of an entry in the registry does not, in itself, lead to the invalidity of the contract, as the special law provides for other consequences of violation – a lack of right to conduct activities and administrative liability, while in matters of payment, the proven performance governs, and in matters of damages, the contractual role of the forwarder is deciding. Practical significance: The conclusions are applicable in resolving disputes about payment and damages, in building systems for verifying counterparties, and in assessing the commercial prudence of market participants after March 1, 2026.