Explanation of documentation 44 fz. Procedure, start and end dates for providing auction participants with explanations of the provisions of the auction documentation

In case of electronic auction the customer places the documentation on such an auction in the unified information system within the time limits specified in Parts 2 and 3 of Article 63 of this Federal Law, simultaneously with the placement of a notice of such an auction. 2. Documentation of the electronic auction must be available for review without charging a fee. ConsultantPlus: note. From July 1, 2018, Federal Law No. 504-FZ of December 31, 2017 amends Part 3 of Article 65. See text in a future edition. 3. Any participant in an electronic auction that has received accreditation on an electronic site has the right to send electronic platform where such an auction is planned, a request for clarification of the provisions of the documentation for such an auction.

Answer to a request for clarification on 44 fz

Both during the electronic auction and during the open competition the customer is obliged to place in the Unified Information System (UIS) clarifications of the provisions of the procurement documentation that do not change its essence, indicating the subject of the appeal, but without indicating the name and details of the participant who asked the question. Violation of the procedure for providing answers to correctly submitted appeals threatens with administrative liability. Deadlines for responding to a request for clarification The start date for providing a response is the day following the day the request was received (p.

4 tbsp. 65 FZ No. 44-FZ). Response time for clarifications auction documentation- within two days of receipt of the request. During the specified period of time, the customer also places a response in the Unified Information System.

How to submit a request for clarification on 44‑FZ

If the request for an electronic auction is submitted in the form electronic document, then, according to an open competition, the request is sent in writing. The request form for the competition is not regulated, which means it can be issued on the letterhead of the organization. Such a request is sent in advance, and it must be taken into account that it must enter the hands of the customer no later than 5 days before the deadline for filing applications.

If it is possible to personally hand over an envelope with a request to the responsible person of the customer, it will be more reliable. A request for clarification is a tool that the supplier must be able to use, and in case of finding disputable requirements in the documentation, it is imperative to send a request for clarification to the customer. Thus, the supplier will be able to clarify the controversial issues with the customer, which he will take into account when forming the application.

Request for clarification on 44-FZ: preparation, deadlines for submission + sample request and response

• Errors or misprints in the documentation (technical specifications);
• Violation of the norms of the law;
• Lack of any information and documents (cost estimates, instructions for filling out the application, etc.);
• Excessive requirements for goods, works, services;
• Vague requirements for goods, works, services;
• Documentation format;
• Indication by the Customer of requirements restricting competition, etc.

The main reasons for submitting requests for clarification of the results of the procurement carried out include:

• Unlawful rejection of the participant's application;
• Failure to indicate the reasons for rejecting the participant's application;
• Technical failures, inability to submit price offer on the electronic platform during the electronic auction;
• Mathematical errors in the calculation of application evaluation criteria.

How to submit a request for clarification on auction documents

Attention

If your question is received by the Customer later than the deadline, then the Customer is not obliged to answer it. Tip number 6 - If filing a formal request for 44-FZ is not provided, and the documentation contains violations, send a complaint to the FAS The federal law is not provided. Therefore, if the information on these procurements contains violations or the Customer establishes requirements that restrict competition, then it is necessary to send a complaint to the Federal Antimonopoly Service.

Tip #7 - Use requests for clarification actively This does not mean that you need to bombard the Client with questions for any reason or no reason. But if the documentation contains points that are incomprehensible to you, then be sure to send your questions to the Customer. 6.

Request for clarification of auction documentation

But even if the supplier sends such a request later than the regulated period, the customer has the right not to respond to the request. The Customer has two calendar days to prepare a response to the supplier's request. At the same time, if deadline response falls on a weekend, then in accordance with Civil Code Art.

193, as well as in accordance with the clarifications

Ministry of Economic Development of Russia dated December 31, 2014 No. D28i-2882, the customer must post a response to the request on the next business day. In the case of a request for tender, the supplier must submit such a request in advance and note that the supplier must submit the request no later than five days before the deadline for submission of applications. The customer prepares a response within two working days and places it in the Unified Information System.

Within 2 working days from the date of receipt given request The customer is obliged to provide the specified participant with the relevant explanations in writing or in the form of an electronic document. And here you will probably ask yourself the question: “How to be in such a situation when the documentation requires clarification, but you do not have the opportunity to submit a formal request?” Yes, you cannot send an official request, but you can call the person responsible for the procurement. His contacts are indicated in the notice posted on the EIS website.

The main thing to remember is that, according to Article 46 of the 44-FZ, negotiations with the Customer and with members of the procurement commission are prohibited. Accordingly, the Customer is not obliged to answer your questions by phone.

How to write documentation explanations 44 ap

If the violation of the law is obvious and it is problematic for the customer to justify his position, then most often the customer makes changes to the procurement documentation, thereby bringing it into line with the requirements of the law. 2. Submitting a request for clarification The process for submitting a request for clarification is as follows. Stage number 1. Study of procurement documentation for inaccuracies, controversial issues, violations of the law Stage №2. Filling out the clarification request form (if the customer provided for such a form in the documentation) Stage No. 3. The clarification request form is signed by an authorized person (director of the company or person authorized by proxy) and then scanned. If a request for an auction is submitted, the request is submitted through the functionality of the ETP.

How to write clarifications on documentation 44 fz

Deadlines for submitting requests for clarification when participating in a request for quotations and a request for proposals I would like to note right away that requests for clarification of the provisions of the documentation on the request for proposals and for an explanation of the results of this procurement 44-FZ are not provided. Also, within the framework of 44-FZ, there is no possibility to submit requests for clarification of the provisions of the documentation on the request for quotations, since the request for quotations does not provide for the placement of full-fledged procurement documentation in the EIS. The participants in the request for quotations have only the opportunity to submit a request for clarification of the results of consideration and evaluation of applications for participation in the request for quotations after the relevant protocol for the consideration and evaluation of applications is posted in the EIS.

Such a request can be sent by the participant, both in writing and in the form of an electronic document (part 10 of article 78 of 44-FZ).
For example, a request for auction documentation must meet the following requirements:

• received through the ETP from a participant accredited on the site;
• received no later than three days before the deadline for filing applications for participation in the auction;
• the total number of applications of one participant within the framework of this tender did not exceed three.

The customer is obliged to send a response to the appeal regarding the provisions of the tender documents in writing or in the form of an electronic document, if the specified appeal was received by him no later than five days before the deadline for filing applications for participation in an open tender.
Since, within the framework of 223-FZ, each Customer must have its own Procurement Regulations, under which he conducts his purchases, the deadlines for submitting requests and the deadlines for responding to them can be set for each Customer. Also, the Customer can approve its own form of such a request and possible options his submission. However, in most cases, Customers working under 223-FZ prescribe in their Regulations the same terms as in 44-FZ. That's all I have today. If you still have questions, then ask them below in the comments to this article, and also share your experience in submitting requests for clarification of the provisions of the documentation and the results of the procurement.
At the same time, a participant in such an auction has the right to send no more than three requests for clarification of the provisions of this documentation in relation to one such auction. Within one hour from the moment of receipt of the specified request, it is sent by the operator of the electronic site to the customer. 4. Within two days from the date of receipt from the operator of the electronic site specified in part 3 this article request, the customer places in the unified information system explanations of the provisions of the documentation on the electronic auction indicating the subject of the request, but without indicating the participant in such an auction from which the specified request was received, provided that the specified request was received by the customer no later than three days before the deadline for submission bids for such an auction.
5. Explanations of the provisions of the documentation on the electronic auction should not change its essence. ConsultantPlus: note.

The documentation is not always clear and transparent. Sometimes customers make mistakes due to inattention or deliberately hide information. The law provides an opportunity to submit a request for clarification in order to clarify or specify incomprehensible points. Any participant can submit a request, even if he has not yet submitted an application. But only in two types of purchases:

• electronic auction,
• open competition.

Common reasons for filing clarifications:

Errors or incorrect data

For example, in this purchase there are a lot of errors in the characteristics of the goods and there is a partial non-compliance with state standards (they are not valid, with incorrect names). The customer responded to the request with a quote from 3 hours 66 of Art. 44-FZ in the spirit of "as we want, so we indicate." The supplier submitted the second clarification already with reference to 44-FZ that the customer must justify the impossibility of using state standards. As a result, the customer replied that he would not take into account more than half of the points when considering and left only 3 points out of 15.

Another example. The customer asked to supply a plaster mix, the grade of which should be higher than M200, and the compressive strength should be less than 12 MPa. But there is no physical combination of such characteristics. After a request for clarification, it turned out that the customer missed the HE particle and required a mixture with a strength of "NOT less than 12MPa".

Vague purchasing parameters

In this purchase, the customer, describing the dimensions of the brick, indicated 4 parameters: “more than 145 by 118 by 250 by 165”. The supplier was no longer in time to submit a request for proposals, and in telephone conversation heard that "purchasing is just not for everyone." In this case, you can complain to the FAS, but the supplier decided to refuse such a purchase.

Too complex documentation format

For example, in an electronic auction for the repair of a building, the terms of reference occupied 2268 pages in PDF format. The maximum time for preparing an application for an auction is 15 days. It is very difficult to read all the requirements and make an application in accordance with them. As a result, this purchase was canceled, but due to a complaint about the content of the draft contract.

Buying prohibited goods or goods that are included in the national regime

In this purchase, there should be preferences for Russian goods according to order No. 155, but the customer indicated another OKPD2 - 58.29.12.000 (Network software on electronic media). The code in this case should be 26.20: the customer purchases the servers, and indicates the code for the software on the media. A supplier that could receive preferences is interested in submitting a request for proposals so that the customer changes the data.

Request in an electronic auction

A request for clarification of the provisions of the auction documentation may be submitted by any participant accredited to the ETP. You can submit no more than 3 requests per auction. The request is submitted no later than 3 days before the closing date for applications.

Participants make a request and receive a response in the ETP interface, where the procedure takes place. For example, a participant submits a request for clarification to Sberbank-AST personal account. This request will not be visible to other procurement participants.

The customer must respond within two calendar days. The clarification document is published on the ETP without indicating the author of the request and is duplicated in the EIS. There it will be seen by all participants in the procurement, who may have the same questions about the documentation.

Request in an open competition

Participants of the open tender send a request in writing. The template is not regulated, but you can do it on the letterhead of the organization. Indicate the documentation item for which clarification is needed, and the actual request.

The request must be received by the customer no later than 5 days before the deadline for submission of applications. If possible, it is better to hand it over personally in an envelope so that the document is definitely accepted.

Within 2 working days from sending the request, the customer is obliged to send in written or electronic form explanations of the provisions of the tender documentation. The answer is also published in the EIS, where it is available to all other participants.

Is it possible to submit a request for clarification in the form of a scanned document with a seal and signature by e-mail?

44-FZ stipulates only the written form, but there is a letter from the Ministry of Economic Development dated May 6, 2014 N 10073-EE / D28i. It says: “A complaint filed by fax or in the form of an electronic document without the use of an electronic signature will not comply with the provisions of Law No. 44-FZ.” That is, a document signed qualified signature, is legally significant and the customer is obliged to accept it.

In practice, everything depends on customer loyalty. If it is not the formality that is important for him, but the quality of the purchased goods, he will promptly respond to the request received by e-mail. And if he wants to weed out unnecessary participants, then the request submitted "not according to the rules" will simply be ignored.

What about other procedures?

Questions may arise in other purchases. You cannot submit a formal request for clarification, but you can call the contact person listed in the documentation. According to 44-FZ, communication with the customer before signing the contract is prohibited, but it all depends on the specific specialist:

• Someone will not want to talk after hearing your question,
• Someone will answer in detail if they are interested in the purchase taking place.

If you see gross violations and restrictions on competition in the request for quotations, and the customer does not answer questions kindly, you have the right to complain to the FAS. If you are correct, the customer will be ordered to change the documentation, and the application deadline will be extended.

Customer actions

The task of a conscientious customer is to answer the supplier’s question of interest as accurately and specifically as possible and place the answer in the EIS within 2 days from the date of receipt of the request. Timely respond to requests in the interests of the customer, because a supplier who misunderstood the conditions may supply the wrong product that was needed, or save on materials if the GOST requirement was not specified, etc.

In addition, Part 1.4. Article 7.30 of the Code of Administrative Offenses provides for liability for non-posting of such information or violation of the publication deadline:

• for officials - 15,000 rubles,
• on the entity- 30,000 rubles.

If the customer does not comply with the rules for responding to requests for clarification, this may serve as a reason to invalidate the electronic auction upon the complaint of the participants.

Vendor Actions

There are several options for the behavior of participants who submitted a request for clarification

• If you are satisfied with the explanations received from the customer, you can prepare an application.
• If not, submit a second and third request, trying to refer to the articles of laws and other regulations that confirm the customer is wrong.
• If you have exhausted the request limit, the terms of the contract remain unacceptable, and you have already submitted an application, it is best to withdraw it in order to avoid the risk of not fulfilling the contract.
• If you want to continue to fight for the contract, complain to the FAS about the content of the documentation.

If the customer is interested in supplying a quality product or service, your request will be answered correctly. If not, it is most likely that he is affiliated with another supplier and there is a risk that they will still find a reason to find fault with your application.

How to correctly set the start and end dates for providing the auction participants in electronic form with explanations of the provisions of the documentation for such an auction?

Answer

Oksana Balandina, chief editor of the State Order System

From July 1, 2018 to January 1, 2019 for customers transition period– both electronic and paper procedures are allowed. From 2019, competitions, auctions, quotes and requests for proposals on paper will be prohibited, with eight exceptions.
Read what purchases to make on the ETP, how to choose a site and get an electronic signature, what are the rules for concluding contracts during the transition period and after.

According to paragraph 11 of part 1 of Art. 64 of the Federal Law of April 5, 2013 No. 44-FZ "On the contract system in the field of procurement of goods, works, services to meet state and municipal needs" (hereinafter - Law No. 44-FZ), documentation on electronic tender along with the information specified in the notice of holding such an auction, it must contain, among other things, information on the procedure, start and end dates for providing participants in such an auction with clarifications on the provisions of the documentation on such an auction.

In turn, Art. 65 of Law No. 44-FZ establishes the procedure for providing electronic tender documentation, clarifications of its provisions and amendments to it.

In part 3 of Art. 65 of Law No. 44-FZ establishes that any participant who has received accreditation on an electronic site has the right to send a request to the address of the electronic site where such an auction is planned for clarification of the provisions of the documentation for such an auction.

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Therefore, since the customer places the auction documentation in electronic form in the unified information system simultaneously with the placement of a notice of such an auction, the participant of the electronic auction has the right to send a request for clarification of the provisions of the documentation for such an auction from the moment the customer publishes such an auction, i.e. the start date for providing clarifications to bidders is the date of publication of such an auction.

Hello dear colleague! Quite often in practice one has to deal with situations where the procurement documentation or the results of the procurement require clarification. Moreover, a well-prepared request can help not only clarify all unclear points to the participant, but also convince the Customer to make appropriate changes to the documentation. Therefore, I am deeply convinced that absolutely every self-respecting supplier (procurement participant) must be able to competently prepare and send such requests to the Customer. In this article, we will consider in detail what requests for clarification on 44-FZ exist, how to prepare them and when to send them. In addition, in the article you will find the necessary samples of requests and answers to them.

1. Types of requests for clarification under 44-FZ

Tip #1- Carefully study all the documentation on the ongoing purchase

The deadlines for submitting requests for clarification of the provisions of the documentation are strictly regulated, so you need to study all the documentation and write out everything to the maximum contentious issues that require clarification. Otherwise, you may not have time to submit a new request.

Tip #2- Be specific about your questions

If you want to receive accurate and detailed answers to your questions from the Customer, then ask open questions that cannot be answered with a simple yes or no. If the Customer has violations in the documentation, then indicate which item of the documentation does not comply with the requirements of the law.

Tip #3— Use the request form proposed by the Customer

I must say right away that there is no single regulated form for a request for clarification of the provisions of the documentation. If the Customer provided his request form in the documentation, it is better to use this form. If there is no such form in the documentation, then the request can be prepared in free form on the letterhead of the procurement participant.

Below I have given one of the options for the form of such a request:

Request for clarification of tender documentation - download sample

The Customer's response to the request for clarification may look like this:

Also, procurement participants often have the following question: “Is it possible to send a request for clarification to the Customer in the form of a scanned document with a seal and a signature by e-mail?”

It all depends on the specific customer. Many Customers accept scans of requests via e-mail. Others, on the contrary, require that requests in electronic form be signed by the electronic signature of the participant, referring to the letter of the Ministry of Economic Development dated 06.05.2014. No. 10073-EE/D28i. Although this letter we are talking not about requests, but about complaints to the FAS in in electronic format.

Tip #4— Remember that the number of requests for clarification of the provisions of the auction documentation is strictly limited

The procurement participant has the right to send no more than 3 requests on giving clarifications to the provisions of the auction documentation in relation to one auction. If you send the Customer one question each time, then in practice there may be such a situation that the limit of requests has been exhausted, but there are still questions.

Tip #5- Be mindful of deadlines

Submission of requests for clarification of the provisions of the documentation is possible within a strictly established time frame. If your question is received by the Customer later than the deadline, then the Customer is not obliged to answer it.

Tip #6— If the filing of an official request 44-FZ is not provided, and the documentation contains violations, send a complaint to the Federal Antimonopoly Service

As we already spoke with you above in this article, filing requests for clarification of the provisions of the documentation when conducting a request for quotations and a request for proposals 44-FZ is not provided. Therefore, if the information on these procurements contains violations or the Customer establishes requirements that restrict competition, then it is necessary to send a complaint to the Federal Antimonopoly Service.

Tip #7- Actively use requests for clarification

This does not mean that you need to bombard the Customer with questions for any reason or for no reason. But if the documentation contains points that are incomprehensible to you, then be sure to send your questions to the Customer.

6. Responsibility of the Customer for failure to provide clarifications

The task of the Customer, to whom the request for clarification was sent, is to give an accurate and comprehensive answer to the request within the time period established by law. However, in practice there are situations when the Customer does not respond to the participant's request, or responds later than the deadline. For this, part 1.4 of article 7.30 of the Code of Administrative Offenses provides for the administrative responsibility of the Customer in the form of a fine:

• for officials - 15,000 rubles,​
• for a legal entity - 50,000 rubles.

7. Request for clarification on 223-FZ

Above, we have considered the issues of preparing and submitting requests for clarification of the documentation and the results of the purchases made under 44-FZ. Now let's talk with you about requests sent under 223-FZ.

Since, within the framework of 223-FZ, each Customer must have its own Procurement Regulations, under which he conducts his purchases, the deadlines for submitting requests and the deadlines for responding to them can be set for each Customer. Also, the Customer can approve its own form of such a request and possible options for its submission.

However, in most cases, Customers working under 223-FZ prescribe in their Regulations the same terms as in 44-FZ.

That's all I have today. If you still have questions, then ask them below in the comments to this article, and also share your experience in submitting requests for clarification of the provisions of the documentation and the results of the procurement.

P.S.: Click on the social buttons, share this article with your friends and colleagues.

ARBITRATION COURT OF NOVGOROD REGION

Bolshaya Moskovskaya street, 73, Veliky Novgorod, 173020

http://novgorod.arbitr.ru

Name Russian Federation

SOLUTION

Velikiy Novgorod

Case No. А44-9337/2015

The operative part of the decision was announced on January 25, 2016. Full text solution was made on February 01, 2016.

The Arbitration Court of the Novgorod Region composed of Judge A.The. Drachena,

when maintaining the record of the court session assistant judge D.The. Limantseva,

having considered the case at the request of the Department of Property Relations and public procurement Novgorod region (TIN 5321026264, OGRN 1025300805254)

to the Office of the Federal Antimonopoly Service for the Novgorod Region (TIN 5321047553, OGRN 1025300795552)

third parties:

Department of Health of the Novgorod Region,

society with limited liability"RTS-Tender"

limited liability company "Pharmatsevt"

limited liability company "Diamir"

on the invalidation of paragraphs 2 and 4 of the decision of 05.10.2015 No. 5560/03

with the participation:

from the applicant - representatives Kupriyanov A.G. - by proxy dated December 14, 2015, Ignatieva N.A. - by power of attorney dated December 14, 2015

from the defendant – representative Kurikov AND.A. – by power of attorney dated 18.01.2016

from the Department of Health of the Novgorod Region - the representative of Nikonorov A.V. – by power of attorney dated January 18, 2016 (before the break)

from RTS-Tender LLC - the representative did not appear, was notified, notification No. 29187,

from Pharmacevt LLC - the representative did not appear, was notified, notification No. 29188,

from Diamir LLC - the representative did not appear, notified, notification No. 29189.

installed:

The Department of Property Relations and Public Procurement of the Novgorod Region (hereinafter referred to as the Applicant, the Department) filed an application with the Arbitration Court for recognition of the decision of the Office of the Federal Antimonopoly Service for the Novgorod Region (hereinafter referred to as the Defendant, the Novgorod OFAS Russia) No. 5560/03 dated 05.10.2015 years in terms of paragraphs 2 and 4 illegal.

In support of the claims, the applicant indicated that he considered it illegal to establish in the disputed part of the decision the fact of a violation of clause 11 of part 1 of Art. 64 of the Federal Law of April 5, 2013 No. 44-FZ “On the contract system in the field of procurement of goods, works, services to meet state and municipal needs” (hereinafter referred to as the Law on the contract system).

According to clause 11, part 1, article 64 of the Law on the contract system, the procurement documentation must contain the procedure, start and end dates for providing explanations to the auction participants about the provisions of the auction documentation.

In paragraph 12.3 of the Auction Documentation posted by the applicant, there was a calendar date for the expiration of the period for providing explanations to the auction participants - 09/06/2015. This date complies with the requirements of paragraph 3 of Article 2 of Federal Law No. time."

The auction documentation does not contain any other dates.

Based on h.h. 2, 3 art. Section III. Proceedings in the arbitration court of first instance in cases arising from administrative and other public legal relations > Chapter 24. Consideration of cases on challenging non-normative legal acts, decisions and actions (inaction) government agencies, bodies local government, other bodies, organizations endowed federal law> Article 201. The decision of the arbitration court in the case of contesting non-normative legal acts, decisions and actions (inaction) of bodies exercising public powers, officials" target="_blank"> 201 APC RF for recognition decisions of bodies exercising public powers to be illegal must comply with two conditions:

Non-compliance of such decision with the law or other regulatory legal act;

Violation of the rights and legitimate interests of the applicant in the field of entrepreneurial and other economic activities.

When considering the results of an unscheduled inspection, the commission of the Novgorod OFAS Russia took into account the fact that there was no violation of the rights of procurement participants and decided not to issue orders to eliminate the violation. In fact, the decision stated the fact of violation of the principles of openness and transparency in the implementation of procurement and, as a result, clause 11, part 1, article 64 of the Law on the contract system.

The indicated principles oblige the authorized body to be attentive to all published information on procurement, avoiding ambiguities in the interpretation of certain of its provisions. Consequently, the contested decision is aimed at eliminating such situations and does not encroach on the activities of the Department regulated by law, and also does not create any obstacles to its implementation.

The decision to transfer the materials of the Complaint and an unscheduled inspection to an authorized official of the Novgorod OFAS Russia to consider the issue of initiating an administrative offense case in accordance with the Code of the Russian Federation on Administrative Offenses against an official of the authorized body - the Department of Property Relations and Public Procurement of the Novgorod Region (paragraph 4 ) adopted on the basis of paragraph 1 of Part 22 of Art. 99, part 8 of article 106 of the Law on the contract system.

At the same time, an assessment of the sufficiency of data indicating the presence of an event of an offense in the actions of the applicant's officials, all the circumstances of the offense, the degree of guilt of specific officials, its presence will be given when considering the issue of initiating an administrative offense case in accordance with the Code of Administrative Offenses of the Russian Federation.

Based on the foregoing, the decision of the Novgorod OFAS Russia dated 05.10.2015 No. 5560/03 in the disputed part does not contradict the Law on the contract system and does not violate the rights of the applicant.

The claims made should be denied.

Guided by articles -, Section III. Proceedings in the Arbitration Court of First Instance in Cases Arising from Administrative and Other Public Legal Relations state or other public authorities, officials > Article 200. Trial on cases of challenging non-normative legal acts, decisions and actions (inaction) of bodies exercising public powers, officials" target="_blank"> 200, Section III. Proceedings in the arbitration court of first instance in cases arising from administrative and other public legal relations Chapter 24 the case of contesting non-normative legal acts, decisions and actions (inaction) of bodies exercising public powers, officials" target="_blank"> 201 of the Arbitration Procedure Code of the Russian Federation, arbitration court

DECIDED:

Deny the application of the Department of Property Relations and Public Procurement of the Novgorod Region.

The decision may be filed an appeal to the Fourteenth Arbitration Court of Appeal through the Arbitration Court of the Novgorod Region within one month from the date of the decision. A decision that has entered into force after its appeal may be appealed to the Arbitration Court of the North-Western District through the Arbitration Court of the Novgorod Region within two months from the date the decision enters into force.