Maintaining Military Records at Enterprise

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Maintaining Military Records at Enterprise

Military records at the enterprise is an important part of the state system of mobilization training and civil protection.

Military records is a complex and mandatory procedure that every enterprise in Ukraine must follow. It covers accounting, control and reporting on the martial law of citizens, employees, equipment and vehicles that can be used for military needs in accordance with a number of laws that were adopted in early 2024:
  • Law of Ukraine No. 3127-IX “On Amendments to the Law of Ukraine “On Military Duty and Military Service"
  • Law of Ukraine No. 3549-IX of January 16, 2024 “On Amendments to Certain Laws of Ukraine on Improving the Procedure for Processing and Using Data in State Registers for Military Registration and Acquiring the Status of a War Veteran during Martial Law”
  • Law of Ukraine No. 3621-IX of April 23, 2024 “On Amendments to Certain Laws of Ukraine on Ensuring the Rights of Military Personnel and Police Officers to Social Protection”
  • Law of Ukraine No. 3633 of April 11, 2024 “On Amendments to Certain Legislative Acts of Ukraine on Certain Issues of Military Service, Mobilization and Military Registration”.
At the same time, the main document for maintaining military records at the enterprise is the Procedure for organizing and maintaining military registration of conscripts, persons liable for military service and reservists, approved by the Resolution of the Cabinet of Ministers of Ukraine dated 30.12.2022 No. 1487.

Regardless of the ownership structure of the company, industry or its location, the company must appoint a person responsible for maintaining military records, his duties include, in particular, the following:
  • Document management: Ensuring the accuracy and timeliness of military records.
  • Compliance with submissions: Timely preparation and submission of mandatory military registration documents, including reports, plans, schedules, notifications, decrees (orders) and responses to requests from the TCR and SS.
  • Control: Ensuring the completeness and quality of registration of all persons liable for military service, compliance with the Rules of Military Registration by employees liable for military service, verification of military registration documents when hiring persons liable for military service.
  • Deferral of conscription for military service: Registration and submission of documents for the booking of employees liable for military service.
  • Promotion activities: Conducting awareness work among employees liable for military service regarding their compliance with the rules of military registration. Informing employees and management of their rights, obligations and consequences of non-compliance with the rules of military registration.
  • Cooperation: Interaction with territorial recruitment and social support centers regarding the terms and methods of reconciling data from military registration, notifying persons liable for military service and informing about violations of military registration rules. 


The Code of Administrative Offences (CAO) provides for liability for violation of the rules of military registration and legislation on defence, mobilisation preparation and mobilisation — Article 210-1 "Violation of legislation on defence, mobilisation preparation and mobilisation".

Thus, it is as follows:
for violation of the rules of military registration by conscripts, persons liable for military service, reservists (Article 210 of the Code of Administrative Offences):
  • in peacetime - from UAH 3400 to 5100;
  • repeatedly during the year - from 5100 to 8500 UAH;
  • during a special period - from UAH 17,000 to 25,500.

for violation of the legislation on defence, mobilisation preparation and mobilisation of officials (Article 210-1 of the CAO):
  • in peacetime - from 5,100 to 8,500 UAH for citizens, from 17,000 to 25,500 UAH for officials and legal entities;
  • repeatedly during the year - from UAH 8,500 to UAH 11,900 for citizens, from UAH 25,500 to UAH 34,000 for officials and legal entities;
  • during a special period - from UAH 17,000 to UAH 25,500 for individuals, including for failure to fulfil the obligation to update data from 18.05.2024 within 60 days, i.e. until 17.07.2024, from UAH 34,000 to UAH 59,500 for officials and legal entities.

How can BDO in Ukraine help with military registration?
Among its areas of expertise, BDO in Ukraine offers services in military records and booking services for businesses of all sizes and industries. Our comprehensive services include:
1. Development of initial package of mandatory documents on military registration:
  •  Creation of the necessary forms and templates for maintaining military records.
2. Collection and processing of data on persons liable for military service:
  • One-time collection of data on employees liable for military service
  • Filling in the Lists of personal military registration and operational accounting information
  • Formation of cases of persons liable for military service and other mandatory documents
3. Updating military registration data:
  • Constant updating and verification and updating of data in the Personal Military Registration Lists
  • Interaction with the Territorial Recruitment and Social Support Centers
4. Preparation of documents for booking of persons liable for military service:
  • Drawing up a package of documents for the booking of employees
  • Submission of documents to the relevant authority
  • Preparation of quarterly reports on the number of booked employee
5. Information about vehicles and equipment:
  • Preparation and submission of information on the availability and condition of vehicles and equipment twice a year
  • Collection of data on citizens working in the enterprise using this technique
6. Submission of lists of conscripts:
  • Annual submission of lists of conscripts to the Territorial Center for Recruitment and Social Support
If your company needs additional advice on maintaining military records, please contact the specialists of BDO in Ukraine. Be sure of reliable support and professional experience of our specialists in the military records.

Key Contact

Viktor Nevmerzhitsky

Viktor Nevmerzhitsky

Tax & BSO Partner
View bio

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FAQ

  • What is military registration at an enterprise?

Military registration is a crucial component of the state’s mobilisation preparedness strategy. It encompasses a range of activities conducted by enterprises to record, accumulate and analyse human mobilisation resources in accordance with military registration criteria, implementing measures to ensure strict compliance with established military registration rules by conscripts, persons liable for military service and reservists. Furthermore, enterprises are required to submit comprehensive information on conscripts, persons liable for military service and reservists to the TCR and SS for maintaining the Unified State Register of Conscripts, Persons Liable for Military Service and Reservists.

Maintaining military records is mandatory for all legal entities and includes registration, control and reporting on the military registration of employees, equipment and vehicles of an enterprise that may be involved in the military needs of the Armed Forces of Ukraine.

Military registration involves adhering to the stipulated requirements of the Procedure for Organising and Maintaining Military Registration of Conscripts, Persons Liable for Military Service and Reservists, as approved by the Resolution of the Cabinet of Ministers of Ukraine dated 30.12.2022 No.1487.

  • Who is responsible for maintaining military records at enterprise?

The organisation of military registration at enterprises is the responsibility of relevant  managers.

Each company must appoint a designated individual as the military registration officer, responsible for ensuring that military registration is maintained in accordance with the stipulated legal requirements, checking military registration documents during the hiring process for persons liable for military service, maintaining and updating personal military registration lists, and informing employees subject to military service about the Rules of Military Registration. The role also involves conducting explanatory work among employees, liaising with the TCR and SS by sending relevant notifications about changes in the data of employees subject to military service, notifying employees at the request of the TCR and SS, and conducting both external and internal verifications.

  • What is the liability for violating military registration rules?

Violation of legislation on defence, mobilisation preparation and mobilisation entails the imposition of a fine on officials of state authorities, local self-government bodies, legal entities and public associations — from 2,000 to 3,500 tax-free minimum incomes (UAH 34,000 — 59,500) (Article 210-1 of the Code of Administrative Offences). Violations of military registration rules are punishable by administrative liability — a fine of between UAH 17,000 and 25,500 for each particular violation.

  • What military registration services does BDO in Ukraine provide?

BDO in Ukraine provides a comprehensive range of services, including:

•    Developing a primary set of mandatory documents for military registration and templates for other possible documents; collecting and processing data on persons liable for military service

•    Filling out personal military registration lists and updating them

•    Preparing notifications of changes in data to the TCR

•    Preparing a package of documents to notify employees about their summons to the TCR

•    Submitting of reservation requests to Diia

•    Preparing reports on the availability of vehicles and equipment

•    Preparing documents for annual reconciliation with the TCR and SS

•    Informing clients about changes in legislation on military registration and mobilisation

•    Advising clients on military registration and reservation issues

•    Supporting during the process of obtaining the status of a critical enterprise.

  •  How often is information about vehicles provided?

Information on vehicles and equipment is to be provided twice a year.

  • How often military registration data need to be updated?

The data need to be constantly updated. Information on conscripts is to be checked and updated on a regular basis.

  • Which authorities are the lists of conscripts filed with?

In the event of an external reconciliation with the TCR and SS, the lists of personal military records shall be filed with such TCR and SS once a year, together with copies of the military registration documents of employees subject to military service.

Glossary

Updating military registration data — regular updating, verification and clarification of information about employees subject to military service.

Reservation — preparation of documentation to grant deferment from military service to employees who are essential to the operation of the enterprise.

Military registration — a system for the registration of citizens, equipment and vehicles that can be used for military purposes.

Person liable for military service — an individual who is on the military account and may be called up during mobilisation.

Document flow — the process of preparing, storing and submitting military registration documentation at an enterprise.

CUAO (Code of Ukraine on Administrative Offences) — a legislative act that defines administrative liability for violations of legislation on defence and mobilisation.

Mobilisation preparation — a set of measures aimed at ensuring the readiness of the state and enterprises for mobilisation.

Resolution of the Cabinet of Ministers No. 1487 — the main regulatory document that defines the procedure for organising and maintaining military records of conscripts, persons liable for military service, and reservists.

Conscript — a citizen subject to conscription for military service.

Authority — a state institution with which documents relating to the reservation of employees subject to military service are filed.

Reservist — a citizen subject to military service who is enrolled in the military reserve of the Armed Forces of Ukraine.

TCR and SS (Territorial Centre of Recruitment and Social Support) — a body that maintains military records, receives reports, notifies persons liable for military service and monitors compliance with military registration rules.