Material prepared by Natalia Slipchenko,
Senior HR Records Management Specialist/
Military Records Specialist
Department for the Provision of HR Records Management
and Payroll Accounting Services
New requirements for military registration: instructions for companies
Changes in military registration always generate significant interest from the management of enterprises, institutions, and organizations, as well as individuals responsible for military registration. In July 2025, new regulations and methodologies were adopted at the legislative level, particularly concerning military registration. These necessitate a suitable response and the immediate revision of existing procedures and documentation. Please find below the main provisions and explanations regarding the innovations that should be taken into account when conducting military registration at an enterprise.
New requirements as outlined in Resolution No. 916
Amendments to the Procedure for Organising and Maintaining Military Records of Conscripts, Persons Liable for Military Service and Reservists became effective on 31 July 2025. The amendments were approved by Resolution of the Cabinet of Ministers of Ukraine (CMU) No. 1487 dated 30 December 2022 (hereinafter referred to as Resolution No. 1487) and introduced by Resolution of KMU dated 30.07.2025 No. 916.
The main changes regarding military registration issues concern the appendices to Order No. 1487, which are maintained by enterprises, institutions, and organisations.
These changes relate to:
- Appendix 2 to Resolution No. 1487
- Appendix 5 to Resolution No. 1487
- Appendix 6 to Resolution No. 1487
Updated military registration rules: actions to be taken by employers
Appendix 2 to Resolution No. 1487 contains the updated regulations on military registration of conscripts, persons liable for military service and reservists. It should be noted that the rules for military registration have not been updated, but subparagraph 10-1 of paragraph 1 has been deleted.
The primary responsibility for all individuals involved in military registration is to:
- Update the Military Registration Rules
- Post them in a visible location. For example, on the company’s information board or on a special military registration board (if available).
As such, employees recruited after 31 July 2025 must be acquainted with the revised regulations concerning the military registration of conscripts, persons liable for military service, and reservists. All other employees may also be familiarised with the rules in a manner convenient for the enterprise, for example, by sending them to corporate email addresses or posting the rules on the corporate intranet.
New form of personal military registration lists
• Appendix 5 to Resolution No. 1487 has been revised. The title of Appendix No. 5 to Resolution No. 1487 has been revised. Previously, this appendix was titled “Personal Military Registration Lists”, but as of 31 July 2025, it is titled “Lists of Personal Military Records of Conscripts, Persons Liable for Military Service, and Reservists”' (hereinafter referred to as the Lists).
• The description for filling out the Lists has changed: before the changes, there were three descriptions, and now there is only one.
• Paragraph 37 of Resolution No. 1487 states that the Lists are compiled into a single case, whereas before the changes, it was stated that a separate case was compiled for the Lists of each group.
- Columns have been removed
The next change in Appendix 5 to Resolution No. 1487 is the removal of certain columns from the list. The columns (details) that specified the following have been removed:
- Information about education and specialisation
- Details of the Ukrainian citizen’s passport for travelling abroad
- Marital status, surname, first name and patronymic of family members and their years of birth
- Composition (training profile for officers)
- Registration category (for officers — rank)
- Fitness for military service.
- Columns have been added regarding:
- Categories of military duty (‘conscript’, ‘person liable for military service’ or ‘reservist’ should be inserted here).
- Information about a deferral (term and grounds).
- Information about active service (yes or no).
- Information about a mobilisation order (yes or no).
- Separate indication of the record number in the Unified State Register of Conscripts, Persons Liable for Military Service and Reservists (VIN code).
- Some columns have been merged or split
The address of residence is to be indicated in one of the following columns: either the declared/registered address or the actual place of residence.
In addition, previously, below the table form of the list, there was a separate list of information for categories such as:
- Conscripts and reservists of the officer corps
- Conscripts and reservists of the enlisted, sergeant and senior sergeant corps
- Conscripts
now – the List of information specified in the records of personal military registration lists of conscripts, persons liable for military service and reservists.
With effect from 31 July 2025, personal military registration Lists should be completed using the new form.
However, the Lists should be printed out and approved using the new form as of 1 January by 25 January 2026.
Resolution No. 1487 does not include any transitional provisions. The following steps should therefore be taken:
• Compile new Lists (considering the changes mentioned above)
• Keep the old Lists for 3 years.
Abolition of joint lists: what is no longer required to be submitted
Appendix 6 to Resolution No. 1487, which contained a joint list of citizens subject to military registration as conscripts, has been excluded. This list was filed with the TCR and SS on an annual basis by 1 December. From now on, there will be no need for this list to be submitted. This will mean that those responsible for maintaining military records will have one less report to compile at the end of the year.
Changes in document storage and case formation
- Forming lists into a single file
Prior to the amendments to paragraph 37 of Resolution No. 1487, the case concerning the storage of copies of military registration documents for conscripts, persons liable for military service and reservists was established separately for each of the four groups (if available). Previously, a file was created for each group, in which a separate list and copies of military registration documents were kept.
With effect from 31 July 2025, all documentation should be stored in a single file, inclusive of all relevant lists. This file will also need to contain copies of military registration documents.
However, a question arises whether there is now only one list of personal military records for all conscripts, persons liable for military service and reservists, or whether these records are still divided into groups. Paragraph 36 of Resolution No. 1487 remains unchanged, i.e., it still refers to the maintenance of personal military records for four groups, as previously.
The Ministry of Defence and the TCR have already provided relevant clarifications (see the letter from the Kyiv City TCR dated 7 August 2025, No. 11/13455, and the letter from the Ministry of Defence dated 8 August 2025, No. 321/VykhZPI/218). These records should continue to be kept separately for the four groups mentioned, but they should be compiled into a single file and stored together. If your organisation has officers, enlisted personnel, conscripts and women liable for military service, four separate lists should be kept. These lists, which should be printed out and signed at the beginning of 2026, will then be stored in a single file together with copies of military registration documents.
- Change regarding managing of citizens excluded and removed from military registration
TCR notification: how to indicate lack of information
The next change stipulates that if the military registration document does not contain the information specified in columns 3, 8, 13–16 of Appendix 5 to Resolution No. 1487, this shall be indicated in the notification of appointment/dismissal sent to the TCR and SS.The information required for the completion of the lists in Appendix 5 and the notifications in Appendix 4 shall be obtained from the passport and a military registration document. If this data is not available, the employer is required to indicate this in the notification.
However, according to Appendix 4, it is apparent that the form lacks the necessary fields to complete all the required information.
While the absence of a rank and military speciality can be indicated in Appendix 4, as it contains the appropriate fields for this, there are no such fields for entering other necessary information.
In instances where it is not possible to indicate the absence of the required information in Appendix 4, a cover letter can be prepared, in which all missing information should be indicated in accordance with the requirements of the note to Appendix 5.
For instance, if an individual subject to military service is recruited who has a rank and Military registration speciality in the military registration document but lacks a reservation, deferral, military service data, or mobilisation order, then the available details are documented in Appendix 4. The accompanying letter signifies the absence of additional information. Namely:
In accordance with the requirements of Note 1 of Appendix 5 to Resolution No. 1487, we hereby inform you that the military registration document provided by the employee subject to military service does not contain information about reservation, deferral, military service, and mobilisation orders.
“Combat” summons by post: new delivery procedure
From 31 July, TCR can send “combat” summonses by post.From now on, individuals subject to conscription based on the results of the Military Medical Commission will receive a summons to report to their place of service. This can be done in person or via post, with confirmation of delivery.
We are referring to the “combat” summons that are issued to conscripts who have already passed the medical examination for immediate conscription into military service in connection with mobilisation.
- Receiving a summons
- Under personal signature
- Sent by the TCR and SS by post as registered mail (with a description of the contents and notification of delivery).
The TCR summons is delivered by a Ukrposhta employee to the address specified by the conscript when confirming their details. If the details have not been confirmed, the summons may be sent to the address of registration.
- Summons not received or refusal to accept it
It is important to note that if the summons is sent properly, the conscript will be considered duly notified of the summons even if they do not pick up the letter and the letter is returned to the TCR and SS with a corresponding mark from Ukrposhta.
In the event of refusal to receive such a summons or failure to comply with the requirements to arrive at the place of service at the time and place specified in the summons, these persons shall be liable in accordance with Article 336 of the Criminal Code of Ukraine.
If the summons is not received, it is still considered delivered, and if it is a “combat” summons, the police will open a criminal case at the request of the TCR. The TCR enters the search data into the “Oberih” register and contacts the police.
If it is not a “combat” summons, the police have the right to search for and deliver the person to the TCR for the imposition of a fine.
If it is a “combat” summons, the police are obliged to initiate criminal proceedings, and the person will be placed on the wanted list not only in the “Oberih” database, but also in the Ministry of Internal Affairs database. This is a criminal investigation.
The initiation of a criminal case gives the police the right to conduct investigative actions and, in certain cases, even to enter a citizen’s home without a court order.
Therefore, the following is recommended for conscripts:
- Notify the TCR and SS of any change in actual place of residence
- Check a mailbox
- Apply for deferment from conscription in a timely manner, if there are grounds for doing so.
Automatic transition from conscript to military service
In accordance with the most recent amendments, the TCR will no longer be responsible for summoning citizens who have reached the age of 25 and were previously conscripted for registration. The TCR automatically enters information about their military service status into the Unified State Register of Conscripts, Persons Liable for Military Service and Reservists, assigning them the rank of “reserve soldier (sailor)” with a category 2 designation.Consequently, employers now have the opportunity to immediately change the category “conscript” to “person liable for military service” and indicate the corresponding rank in the list. It is imperative that this data is updated immediately in the Reserve+ application, enabling the employee to generate a new electronic military registration document and present it to the employer for personal military registration.
Conclusions
- A new version of the personal military registration lists in Appendix 5 will be in force on 31 July.
- The transition to the new format of the lists should be carried out gradually, with the process to be completed by the end of 2025. It is recommended that the update be initiated immediately in order to demonstrate that the enterprise has begun to implement the new requirements.
- From this point onwards, personal military registration lists are to be compiled into a single file and stored alongside copies of military registration documents.
- The Military Registration Rules have been updated; the company’s information stand shall be updated accordingly.
- In the event of hiring or dismissing employees who are subject to military service, it is essential to inform the TCR of their rank, military registration speciality, deferral, military service and mobilisation orders, or the absence of such data.
- The joint list of citizens subject to military registration, which was filed with TCR and SS by 1 December each year, has been abolished.
- From this point onwards, TCR are permitted to dispatch “combat” summons via postal delivery.
- Citizens who have reached the age of 25 and were previously conscripted no longer need to register at TCR for military service; this process will now be conducted automatically.
Finally, it should be noted that changes in the military registration procedure require companies and conscripts to be attentive and responsible in updating information and complying with established rules. Details on specific aspects of the updated Resolution No. 1487, particularly the new requirements for female medical professionals.
The team of BDO in Ukraine is prepared to assist with the implementation of electronic documents, which significantly streamline accounting processes. However, it is crucial to respond promptly to new legislative requirements. It is vital to ensure continuous communication between employees, employers and responsible/regulating authorities to avoid unforeseen consequences and violations. The timely uploading of data to electronic systems and adaptation to changes will contribute to the effective and transparent maintenance of personal military records at enterprises.
Should you require assistance, our experts are available to help you avoid risks and organise processes in accordance with the law.