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
This article outlines the key changes to the requirements for military registration and the reservation of employees subject to military service. The updates cover the verification of electronic military registration documents during recruitment, the maintenance of personal military registration lists, annual data reconciliation, as well as approaches to confirming the status of a critical enterprise and determining reservation quotas.
Is your organisation ready for the new rules, and what risks might they pose to your business? Read our article to find out more.
Significant changes came into force in July 2026 regarding military registration and the reservation of employees subject to military service, directly affecting employers’ HR processes. The updates concern the procedure for verifying military registration documents during recruitment, maintaining personal military registration lists, conducting data reconciliation, confirming the status of critical enterprises, and determining reservation quotas. In light of this, enterprises should promptly review their internal procedures, update their records, and ensure they comply with the new legal requirements.
1. Update to the Order No. 1487: new requirements for maintening military registration records from 27.06.2026
On 27 June 2026, amendments to the Order for the organisation and maintenance of military registration of conscripts, persons liable for military service and reservists, approved by the Resolution No. 1487 of the Cabinet of Ministers of Ukraine dated 30.12.2022, came into force. These amendments were introduced by the Resolution No. 812 of the Cabinet of Ministers of Ukraine dated 10.06.2026.One of the key changes is the introduction of new requirements when hiring employees. From now on, the electronic military registration document (e-MRD) submitted by a candidate should have been generated no earlier than 72 hours before the employment contract is formalised. This requirement ensures that the information contained in the “Oberih” Unified State Register of conscripts, persons liable for military service and reservists is up to date. Documents generated before the specified deadline cannot be used for verification purposes.
The procedure for maintaining the Lists of personal military registration has also been clarified. In particular, column 18 stipulates the use of only the prescribed wording:
- “Dismissed from employment”
- “Removed from military registration due to age”
- “Military serviceman” with the date of mobilisation specified.
Details of mobilised and dismissed employees should be retained in the registers until the end of the current calendar year. Persons, whose employment contracts have been suspended, are not removed from the personal military registration registers.
The changes also concern the procedure for notifying territorial recruitment and social support centres (TRC and SSC). From now on, employers are not obliged to report changes to the marital status, educational background or details of the Ukrainian passport for travel abroad of employees subject to military service. At the same time, the obligation to report changes to registration details remains in force where an employee, who is liable for military service, a reservist or a conscript, has experienced a change in:
- last, first, middle name (if applicable)
- details of their Ukrainian passport
- address of their declared/registered place of residence
- address of actual residence
- place of work
- position
or the employer has made the following changes themselves:
- transfer to another position
- a change to the job title in line with an update to the Classification of Occupations
- transfer to a different place of work.
In this regard, the procedure for notifying the hiring and dismissal of employees remains in force.
Once the relevant functionality has been introduced, such notifications can be submitted electronically via the “Diia” portal or the online personal military registration account.
The annual reconciliation procedure for military registration data has also been updated. Employers must carry out an internal reconciliation at least once a year, and the electronic military registration document must be generated on the very date of such reconciliation. The procedure for liaising with the TRC and SSC at the place of registration remains unchanged. However, for the first time, a deadline has been set for reconciliation with the TRC of other administrative-territorial units — no later than 1 December of the current year.
Furthermore, the Order No. 1487 has been supplemented with a new Annex 28¹, which provides for the possibility of reconciling data from personal military registration lists with the “Oberih” register via the “Diia” portal once the relevant electronic service has been introduced.
2. Amendments to the Order No. 76: a simplified procedure for confirming critical status and new rules for reserving personnel
On 03 July 2026, amendments to the Procedure for reserving conscripts for the period of mobilisation and in wartime, approved by the Resolution No. 76 of the Cabinet of Ministers of Ukraine dated 27.01.2023, came into force. The relevant amendments were introduced by the Resolution No. 862 of the Cabinet of Ministers of Ukraine dated 01.07.2026.The amendments simplify the procedure for confirming the status of a critically important enterprise and clarify the procedure for taking into account employees who work part-time or have a deferment when determining the reservation quota.
Enterprises for which the decision to recognise them as critically important was in force on 02 June 2026 should submit a certificate of average wages and a tax calculation for the last calendar month to the authority that adopted the relevant decision by 10 August 2026. These documents should generally confirm an average wage of at least UAH 25,941.
Provided this requirement is met, the status of a critically important enterprise will be maintained for the period specified in the decision granting it, and the retention of employees will remain in force for the duration of that decision. In this case, the restriction on the validity of the status until 01 September 2026 will not apply.
Particular attention has been paid to the new accounting procedure for employees holding more than one job, and for those granted deferrals for reasons specified in Article 23 of the Law of Ukraine “On Mobilisation Preparation and Mobilisation”. From 03 July 2026, such employees will be counted towards the reservation quota for only one workplace — the one where they are employed for the longest period. This mechanism is expected to facilitate a more accurate determination of the number of employees liable for military service who are subject to reservation.
Electronic interaction between state bodies is also being expanded. The bodies responsible for designating enterprises as critically important will gain access to information regarding the number of reserved employees and compliance with the established quotas. Furthermore, provision is made for the automatic exchange of information between the Ministry of Defence of Ukraine, the Ministry of Digital Transformation of Ukraine and the Pension Fund of Ukraine.
In particular, we would like to draw your attention to the fact that the amendments allow applications to cancel a reservation to be submitted more frequently. Previously, employers could only submit such applications once every five calendar days. Following the entry into force of the relevant provisions, however, this restriction has been lifted, meaning that applications can now be submitted without having to observe the five-day interval.
3. New procedure for accounting for part-time workers and employees with deferrals: requirements of the Ministry of Economy
Following the change to the procedure for accounting for employees holding more than one job and those granted deferrals, the Ministry of Economy of Ukraine is already sending relevant letters to enterprises, requiring employers to review the lists of reserved employees for whom, following a cross-check of information from the Ministry of Defence of Ukraine and the Pension Fund of Ukraine, it has been established that the permissible reservation limits have been exceeded.The letters state that employees subject to military service who work at another critically important enterprise in addition to their full-time or part-time job should be counted towards the quota at the enterprise where they have been employed for the longest period.
Employers have been given 10 working days to cancel any excess deferrals via the “Diia” portal. The restriction of “once every 5 days” for submitting applications to cancel employee deferrals has been lifted.
Failure to comply with these requirements may result in the loss of critical enterprise status.
4. Company’s electronic personal account for military registration
The government has introduced an electronic personal account for companies to manage military registration, which will eventually enable them to cross-check lists with the TRC and SSC online, submit notifications of changes to registration details, and verify candidates’ military registration documents during the recruitment process.However, the service is currently at the technical implementation stage, so it is not yet accessible to employers.
Until it is launched, employers are required to check candidates’ military registration documents in paper or electronic form and cross-check the information against the “Oberih” register. As companies do not yet have direct access to the register, candidates are required to show their electronic military registration documents generated via the “Diia” portal or the “Reserve+” app.
Such a document must be generated no earlier than 72 hours before the employment relationship is formalised. In practice, it is advisable to use the date of issue of the employment order as a guide, as it is from this moment that the employment relationship commences and the relevant notifications are submitted.
Until the electronic portal is launched, businesses are advised to verify the electronic military registration document using the QR code generated in the “Reserve+” app or on the “Diia” portal.
The changes introduced reflect the ongoing digitalisation of military registration and conscription processes, as well as stricter requirements regarding the up-to-date and accurate nature of the data used by employers. Particular attention should be paid to the timely generation of electronic military registration documents, the correct maintenance of personal military registration lists, adherence to reconciliation deadlines, and the accurate identification of employees included in the conscription quota.
To minimise risk, companies are advised to conduct an internal audit of military registration documents and registers, check for employees holding concurrent positions and those with valid deferrals, and prepare to use the electronic services once they are launched. Failure to comply with the new requirements may have significant consequences, including the risk of losing critical enterprise status or having military service deferrals cancelled for individual employees.
Do you need support with managing military registration at your company? Do you require expert assistance in calculating your reservation quota?
At BDO in Ukraine, our specialists help businesses organise and maintain military registration processes in accordance with current legal requirements. We can analyse the current state of your military registration documentation, verify the accuracy of your personnel military registration lists, provide recommendations on data reconciliation, employee reservations, critical enterprise status confirmation and preparation for electronic service use.
Contact BDO in Ukraine to minimise risks to your business and ensure military registration is properly maintained.
