Military registration at a company in 2026: the employer's obligations

Military registration of employees is not an internal formality of the HR department, but an obligation of the employer established by law.

Enterprises, institutions and organisations, regardless of their form of ownership, must maintain personal military registration of conscripts, persons liable for military service and reservists at their place of work. This obligation follows directly from the Law of Ukraine “On Military Duty and Military Service”.

The main regulation that defines how employers maintain military registration is Resolution of the Cabinet of Ministers of Ukraine No. 1487 of 30 December 2022, which approved the Procedure for organising and maintaining military registration of conscripts, persons liable for military service and reservists. As of September 2026, Procedure No. 1487 is in force in the version of 27 June 2026.

Let us look at what exactly an employer must do and what risks arise if military registration is not in fact maintained.

Who must maintain military registration

Personal military registration is maintained at enterprises, institutions and organisations regardless of:

• the form of ownership;
• the field of activity;
• whether the company has the status of a critically important enterprise;
• whether or not it has employees with deferments.

The law places personal registration at the place of work on the heads of enterprises, institutions and organisations.

In other words, the argument “we are not a critical enterprise, so we do not need military registration” is wrong. Critical status and deferments are separate mechanisms, and the obligation to maintain military registration exists regardless of them.

1. Appoint a person responsible for military registration

The first organisational step is to determine who actually maintains military registration. In practice this is done by an order of the head of the company on organising military registration and appointing the responsible person.

The staffing required for military registration depends on the number of conscripts, persons liable for military service and reservists registered with the organisation. If the company has a small headcount, military registration functions may be assigned to an appropriate employee, in particular from the HR department, in accordance with the requirements of Procedure No. 1487.

It is important not simply to issue an order, but to actually define:

• the duties of the responsible person;
• how information is received from the HR department;
• the deadlines for updating military registration data;
• the procedure for working with the territorial recruitment centre (TCR);
• the procedure for storing documents;
• who stands in for the responsible person during leave or absence.

The appointment and dismissal of persons responsible for organising and maintaining military registration is also formalised through the HR documents in the forms provided for by Procedure No. 1487.

2. Check military registration documents when hiring

One of the key mistakes employers make is to hire an employee first and only afterwards look into military registration.

Procedure No. 1487 provides for checking, at the time of hiring, whether the person holds a valid military registration document. The law also allows military registration documents in electronic form: the information may be checked, in particular, through the relevant electronic mechanisms where these are technically available.

The company needs to establish:

• whether the employee is subject to military registration;
• whether they are on the relevant military register;
• whether their military registration document is valid;
• whether the personal data matches other documents;
• whether the information about the employee’s status is up to date.

As of 2026, Procedure No. 1487 expressly provides that hiring and entering a person on the personal military register take place after that person has been placed on the military register with the TCR, the bodies of the Security Service of Ukraine or the relevant units of intelligence agencies, depending on the category of the person.

Therefore, the HR procedure for hiring an employee and the procedure for their military registration must be aligned with each other.

3. Maintain personal military registration lists

The company must maintain personal military registration lists. They contain the information required by law about employees who fall within the relevant categories of military registration.

Depending on the person’s status, registration covers:

• conscripts;
• persons liable for military service;
• reservists.

The difference between general and special military registration must also be taken into account. Persons liable for military service who have been granted a deferment (bronyuvannya) at the relevant enterprise, institution or organisation for the period of mobilisation and wartime are on the special military register. Other persons liable for military service and reservists are, in the cases provided for by law, on the general military register.

So if a company obtains critically important status and begins to obtain deferments for employees, this directly affects how personal military registration is maintained.

4. Notify hiring and dismissal of employees

One of the most important deadlines for an employer is 7 days.

After hiring or dismissing a conscript, a person liable for military service or a reservist, the company must notify the relevant:

• district or city TCR;
• body of the Security Service of Ukraine;
• relevant unit of an intelligence agency, if the employee falls within the relevant category.

Following the changes made in 2026, Procedure No. 1487 provides for submitting a notification of a change in registration data within seven days from the date of the order on hiring or dismissal. A corresponding obligation is set out in Article 38 of the Law of Ukraine “On Military Duty and Military Service”.

This deadline needs to be monitored separately. A typical mistake is that the HR officer issues the order, but the information reaches the person responsible for military registration several weeks later. As a result, the company misses the statutory deadline.

5. Update military registration data

Military registration cannot be maintained on the principle of “we made the spreadsheet once and never change it”. The information must be kept up to date.

For example, the following changes may matter:

• surname, first name or other personal data;
• place of residence;
• marital status;
• education;
• position;
• military registration status;
• the military registration document;
• deferments;
• military service;
• other information that is included in military registration under the law.

Employees, for their part, also have statutory obligations to report changes in their registration data. However, the employer should not assume that responsibility lies solely with the employee: the company must have an internal mechanism for receiving, verifying and entering such changes.

6. Reconcile military registration data

Military registration involves reconciling information. In 2026 the reconciliation mechanism was substantially updated.

Persons responsible for military registration may reconcile personal military registration lists with the TCR’s records:

• through the Diia portal, in the manner provided for by the Procedure;
• through the personal registration account;
• or, where this is not technically possible, by submitting the relevant documents to the TCR.

For companies not included in the approved schedule, reconciliation deadlines are agreed with the relevant TCR.

This is an important development, as military registration is gradually moving from purely paper-based interaction to electronic data exchange.

7. Familiarise employees with the military registration rules

The company must organise employees’ compliance with military registration requirements. In practice, this means that the employer should document the fact that the relevant employees have been familiarised with the military registration rules and their obligations.

It is not enough simply to place the regulation on an information board. It is important for the company to be able to demonstrate during an inspection that:

• the rules were communicated to employees;
• the responsible person carried out the relevant work;
• military registration is maintained systematically, not merely formally.

8. Comply with TCR instructions on notifying employees

The company also has obligations regarding interaction with the TCR.

Article 38 of the Law of Ukraine “On Military Duty and Military Service” expressly provides that, at the request of the relevant authorities, enterprises must notify conscripts, persons liable for military service and reservists of their summons and ensure their timely appearance. Procedure No. 1487 sets out the mechanisms for such notification in detail.

A company therefore cannot simply ignore a duly received instruction from the TCR. After receiving the document it is advisable to:

1. register it;
2. check the list of employees named in it;
3. issue an internal order or instruction, if necessary;
4. carry out the notification;
5. record the fact that the information was communicated to the employee;
6. inform the TCR of the results in the prescribed manner.

Having documentary evidence of each stage is critically important.

9. Keep proper records of employees with deferments

If the company is entitled to obtain deferments for employees, military registration becomes even more important. Persons liable for military service who have been granted deferments are on the special military register.

The company therefore needs to monitor:

• the validity of the deferment;
• the term of the deferment;
• changes in the employee’s status;
• dismissal of the employee;
• transfers;
• whether military registration data is up to date;
• whether the information in HR documents matches the data used for deferments.

Errors in military registration can create problems not only during an inspection: they can also affect the company’s ability to obtain deferments for employees correctly.

10. Prepare the company for an inspection of military registration

The organisation and state of military registration at companies may be inspected. Procedure No. 1487 provides for such inspections in accordance with established plans and procedures. They examine, in particular, the organisation of military registration, the maintenance of lists, data reconciliation, compliance with deadlines and the work of the responsible officers.

When preparing for an inspection, the company needs a systematically organised set of documents. In particular, it is worth checking that you have:

• the order on organising military registration;
• the order appointing the responsible person;
• a job description or a list of the relevant functional duties;
• personal military registration lists;
• military registration documents or properly compiled information about employees;
• notifications of hiring and dismissal;
• reconciliation documents;
• notification documents;
• documents concerning employees with deferments;
• confirmation that TCR instructions were carried out;
• other documents provided for by Procedure No. 1487.

The most common employer mistakes

In practice, problems arise not only where military registration is absent altogether. It is common for registration to be maintained on paper while in fact containing material shortcomings.

Typical mistakes include:

• no order appointing a responsible person;
• hiring employees without properly checking military registration documents;
• missing the seven-day deadline for notifying hiring or dismissal;
• no up-to-date lists;
• discrepancies between HR and military registration data;
• no reconciliation;
• incorrect records for employees with deferments;
• ignoring TCR instructions;
• inability to document that an employee was notified;
• formally assigning duties to an HR officer without actually organising the process.

A separate problem is when the entire military registration system effectively “lives in the head” of one employee. If that person resigns or goes on leave, the company loses control over deadlines and documents.

Who is liable for breaches of military registration rules

Delegating military registration to an HR officer or another employee does not mean that the head of the company is fully relieved of responsibility for organising it. The Law of Ukraine “On Military Duty and Military Service” places personal military registration at the place of work on the heads of enterprises, institutions and organisations.

Breaches of the legislation on defence, mobilisation preparation and mobilisation entail administrative liability under Article 210-1 of the Code of Ukraine on Administrative Offences. During a special period, the sanction for officials of state authorities, local self-government bodies, legal entities and civic associations ranges from 2,000 to 3,500 tax-free minimum incomes of citizens. That corresponds to a fine of UAH 34,000 to UAH 59,500, based on UAH 17 per tax-free minimum for the purposes of administrative fines.

Breaches of military registration rules can therefore no longer be treated as a purely technical HR error.

Must a sole proprietor maintain military registration for their employees?

This question requires separate analysis. In the part dealing with personal military registration, Procedure No. 1487 refers directly to enterprises, institutions and organisations.

You should therefore not automatically transfer the entire procedure for maintaining military registration by legal entities to an individual entrepreneur without analysing the specific legal provision and the status of the employer. For a sole proprietor who employs staff, we recommend analysing military registration separately, taking into account the current version of the regulations and official practice in applying them.

A practical checklist for employers

To understand whether military registration at your company is properly organised, check:

1. Has a responsible person been appointed?
2. Has the relevant order been issued?
3. Have that person’s duties been defined?
4. Are military registration documents checked when hiring?
5. Are personal military registration lists kept up to date?
6. Is the TCR notified of hiring and dismissal within seven days?
7. Are changes to registration data entered?
8. Is reconciliation carried out?
9. Are documents on employees with deferments in order?
10. Is there an algorithm for carrying out TCR instructions?
11. Can the company document compliance with each of these obligations?

If the answer to several questions is “no”, military registration needs an audit and alignment with the law.

Conclusion

Military registration at a company is a system, not a single spreadsheet with a list of employees.

The employer must:

• organise military registration properly;
• appoint responsible officers;
• check employees’ documents;
• notify HR changes on time;
• maintain and update the lists;
• carry out reconciliation;
• comply with TCR instructions;
• keep proper records of employees with deferments;
• be ready to document compliance with these obligations during an inspection.

Proper military registration is particularly important for companies that plan to obtain, or already have, critically important status and obtain deferments for employees.

ARGUS Consulting group audits companies’ military registration, reviews HR and military registration documentation, prepares the necessary orders, lists and internal documents, supports interaction with the TCR and advises on deferments for employees liable for military service.