Military registration at a Ukrainian company in 2026: employer duties and fines
Every legal entity in Ukraine that has employees under an employment contract must keep military registration records, whatever its size or sector. During the special period, Article 210-1 of the Code of Administrative Offences sets a fine for officers of legal entities of 2,000 to 3,500 tax-free minimum incomes, which the Ministry of Defence puts at UAH 34,000 to 59,500.
On 22 September 2026 the Ministry of Defence published guidance for employers: who keeps the records, which documents are required, what deadlines apply and who is liable for mistakes. Below we summarise it in our own words, check the fine against the current text of the Code and add what we see in audits: where businesses most often lose documents and money.
What has changed and what the rule rests on
The guidance does not introduce new rules, but it brings together requirements that HR staff often know only in part. The duty to keep military records at the place of work is set by the Law on Military Duty and Military Service, and the practical procedure is the Procedure approved by Cabinet of Ministers Resolution No. 1487 of 30.12.2022. Guidance text: mod.gov.ua.
Liability is set by Article 210-1 of the Code of Ukraine on Administrative Offences. In its current wording, part three provides that a breach of the law on defence, mobilisation preparation and mobilisation during the special period is punishable by a fine on officers of public authorities, legal entities and public associations of two thousand to three thousand five hundred tax-free minimum incomes. Code text: zakon.rada.gov.ua.
A detail that is often missed: the fine is imposed not on the company as such but on an officer. According to the Ministry of Defence, if no records are kept at all, the head of the entity is liable. If records are kept but with breaches, the appointed responsible person is liable.
Who is affected
- all legal entities with hired staff: LLCs, private enterprises, representative offices, NGOs and charitable organisations. Only sole proprietors (FOP) acting as employers are exempt;
- employees under employment contracts who are conscripts, persons liable for military service or reservists. These are men aged 18 to 60 (senior officers up to 65) who have not been removed from the register, and women on the military register, for example with a medical or pharmaceutical specialty;
- both main employees and part-time staff holding a second job;
- employees whose employment contract has been suspended: records for them continue.
Records are not kept for persons removed from the military register, nor for FOP contractors and people working under civil-law contracts. If an employee is mobilised, he becomes a serviceman, but his data stay in the personal registration lists until the end of the current calendar year.
We wrote separately about NGOs and what donors look at: military registration in a public organisation.
What to do and by when
| Event | Action | Deadline |
|---|---|---|
| Hiring | Check the military registration document. An electronic document (e-VOD) must be generated no earlier than 72 hours before the hiring date | Before the order is signed |
| Order on hiring, transfer or dismissal | Notify the territorial recruitment centre (TCC) | Within 7 days of the order |
| Change of address, marital status, education or position | Update the personal military registration lists | Within 5 days |
| Reconciliation with the TCC | Reconcile the lists, employees’ documents and TCC data | At least once a year |
| TCC order summoning an employee | Issue an order on notification, have the employee sign it, ensure attendance or release the employee from work for that time | On receipt of the order |
Beyond these events, a standing set of documents is needed. According to the Ministry of Defence, this includes:
- an order appointing the responsible person, with a job description, and an order on professional training;
- internal rules on military registration posted in an accessible place, with employees’ signatures confirming they have read them;
- personal military registration lists;
- a log of inspection results;
- an operational record showing the number of persons liable for military service, reserved (exempted) employees, and so on.
Who keeps the records depends on headcount. With fewer than 500 people on the register, the duties may be given to an HR inspector or another HR employee with an allowance of up to 50% of salary. Above 500, a dedicated full-time military registration inspector is required; with 2,001 to 4,000 people on the register, two inspectors; with 4,001 to 7,000, three; and one more for every further 3,000. The responsible person must meet the qualification requirements for the occupation “Military registration inspector” (code 3439).
Where technically possible, data can be reconciled and updated online via the Diia portal.
Inspections and common mistakes
Inspections are carried out by commissions that may include representatives of the TCC, state administrations, the State Tax Service (STS) and the State Labour Service. A scheduled inspection is announced 10 days in advance. An unscheduled one may take place without notice at entities that reserved employees or have employees with mobilisation orders.
The number of fines depends on the number of rulings. If breaches are found during one inspection, one case is heard and one fine is imposed for all of them. If breaches are found outside an inspection and several cases are heard, a fine is possible for each.
What we see most often when auditing HR documents:
- No order appointing a responsible person. The accountant keeps the records in practice, but there is no written appointment or job description. Questions then go straight to the head of the entity.
- The 7 days were missed. The hiring order was signed and the TCC was notified later. The Ministry of Defence cites exactly this as a typical breach.
- Part-time staff left off the lists. Records are kept only for main employees, although the rule also covers part-timers.
- An outdated e-VOD. The candidate showed a document generated more than 72 hours before hiring.
- Mobilised employees deleted from the lists. Their data must remain until the end of the calendar year.
- The fine was paid from project funds. For donor-funded organisations this is a separate risk: an administrative fine on an officer is not a project cost.
For deadlines related to the extension of martial law, reservation and e-VOD, see also martial law until 29.01.2027: what employers should do.
FAQ
What is the fine for military registration breaches at a company in Ukraine in 2026?
During the special period, Article 210-1 of the Code of Administrative Offences sets a fine for officers of legal entities of 2,000 to 3,500 tax-free minimum incomes. According to the Ministry of Defence, this is UAH 34,000 to 59,500.
Do we need military records for civil-law contractors or FOP contractors?
No. According to the Ministry of Defence, records are not kept for FOP contractors or people working under civil-law contracts. They cover only employees under employment contracts, including part-timers.
Who pays the military registration fine: the director or the HR officer?
If no records are kept, the fine is imposed on the head of the entity. For improper record keeping, the person appointed by order as responsible is liable. If breaches are found during one inspection, one fine is imposed for all of them.
How we help
We review HR documents, including orders and military registration lists, and provide outsourced HR administration so that notification deadlines do not fall between the HR officer and the accountant. See HR administration, accounting and payroll outsourcing and contacts. For NGOs we run free webinars for NGOs, including on HR issues in grant projects.
Prepared by the MK Audit team