Person Responsible for Military Records: Who to Appoint and How to Formalize it in 2026

Appointing a person responsible for military registration is the first and most important question for any manager. Gone are the days when these files just gathered dust in a cabinet. In 2026, military registration at a company requires full compliance: fines for violations can reach tens of thousands of hryvnias, and Territorial Recruitment and Social Support Centers check not only the presence of journals but also the legitimacy of the person maintaining them.

Managers often face the dilemma: assign this responsibility to HR, delegate it to the accountant, or handle it personally. Each option carries hidden risks. An incorrectly drafted order, a lack of additional pay, or a missing job description, and the director becomes the primary target for administrative penalties.

In this article, we will explain who can be legally and safely appointed as responsible for military registration, how to properly formalize the documents to satisfy the Territorial Recruitment and Social Support Center, and why saving on additional pay for maintaining military records can end up costing a company much more. Additionally, we will discuss why it is now advisable for businesses to engage external professional services for military records management in order to minimize legal risks.

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Number of Responsible Persons: The Golden Rule for Staffing

How many people should manage military registration to ensure the system operates legally and without errors? The answer does not depend on the size of the business or industry, but on the number of conscripts, reservists, and persons liable for military service registered at the enterprise. This metric is the primary criterion by which legislation determines the required number of responsible personnel.

For companies, there is a clear staffing scale:

1. 501–2,000 registered personnel: one responsible person is sufficient;
2. 2,001–4,000 registered personnel: at least two responsible persons;
3. 4,001–7,000 registered personnel: three responsible persons;
4. For every additional 3,000 personnel, add one more responsible person.

In practice, these numbers also have management significance. The more military-eligible employees a company has, the more intense the processes become: updating lists, submitting notifications, interacting with the Territorial Recruitment and Social Support Center, responding to inspections, and fulfilling directives. When all these functions fall on a single person despite the actual workload, the risk of mistakes and violations increases sharply.

During inspections, the Territorial Recruitment and Social Support Center most often identifies problems not because the company refuses to comply with rules, but due to overloaded personnel and a lack of a systematic approach to recordkeeping.

Who Can Be Responsible for Military Records Keeping?

It is crucial to understand who should be appointed responsible for military records keeping. Responsibility is most often assigned to:

• Personnel inspectors;
• HR specialists;
• Accountants.

This approach seems logical since these specialists work directly with employees’ personal data. However, a key mistake many companies make is assuming that holding the position alone automatically makes someone responsible.

For a personnel inspector or accountant to be formally recognized as responsible for military records keeping during an inspection, their authority must be properly documented through an official order appointing them as responsible for military records keeping, job descriptions, and internal company regulations. Without these documents, responsibility remains effectively “blurred,” and during inspections, the focus shifts to the company’s director.

Another common question from business owners: Can the director manage military records keeping? Formally, yes. In practice, however, directors are most often fined. The reason is simple: the director combines strategic management with dozens of operational tasks, and military records keeping in this mode is almost always delayed or incomplete.

For this reason, choosing the responsible person should be based not only on documentary compliance but also on a clear understanding of the actual workload, risks, and consequences for both the company and the individual employee.

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Requirements for the Person Responsible for Military Records Keeping at a Company

The person responsible for military records keeping is not a “nominal” position or an appointment just for formality. A military records inspector should be able to:

• Work with employees’ personal data;
• Navigate personnel documentation;
• Track changes in staff composition and update information in a timely manner.

An additional critical factor is knowledge of current legislation on military records keeping. Rules change regularly, document forms are updated, and approaches to inspections are refined. The responsible person must either constantly monitor these changes or operate within a system where such updates are automatically accounted for (for example, by involving external consultants).

Step-by-Step Procedure for Appointing a Person Responsible for Military Records Keeping

The process of appointing a person responsible for military records keeping always begins with a managerial decision by the company director. The director determines who will carry the responsibility and documents this decision formally.

Step 1 is to analyze the company’s internal structure. It is important to assess the number of employees, the presence of conscripts or reservists, staff turnover, and understand who can realistically perform these duties without compromising their primary job responsibilities. At the same time, it is necessary to determine the staff position to which military records keeping will be assigned.

Next, issue an appointment order. This document must clearly record not only the fact of the appointment but also the scope of authority and responsibility, including any additional pay, since the employee’s duties are increased.

Tip: For an example of proper documentation of such authority, you can download a Sample Order for Appointing a Person Responsible for Military Records Keeping.

Resolution No. 1487 provides for the qualification enhancement of the responsible person and the subsequent notification of the Territorial Recruitment and Social Support Center about the appointment.

The next step is to update job descriptions or internal regulations. If military records keeping functions are added to an existing position, dual roles are possible, but this must be formally documented. It is also necessary to verify that the job description aligns with the official classifier of professions (code 3439) so that military records duties are correctly reflected.

The final step is to establish the military records keeping process, including creating recordkeeping journals, updating staff lists, defining the procedure for interaction with the Territorial Recruitment and Social Support Center and establishing an action plan in case of an inspection.

Additional Payment for Military Records Keeping: How Much to Pay?

Military records keeping is not part of the standard functions of most positions in a company. For this reason, the law explicitly provides financial compensation for the employee assigned these duties if military records keeping is not their primary job function.

If a company has fewer than 500 conscripts, reservists, and persons liable for military service, the responsibility is usually assigned to a personnel officer. In this case, the employee should receive additional pay of up to 50% of their base salary for handling military records at the company. For public servants, this additional pay is provided within the limits of the payroll budget savings.

A business cannot simply “add another function” to a job description without adjusting the payment terms. Military records keeping involves ongoing work with documents, deadlines, notifications, inspections, and communication with the Territorial Recruitment and Social Support Center. Performing these duties without proper compensation creates risks for both the employee and the company.

Special attention is required when the volume of records-keeping work exceeds the scope intended for the 50% salary supplement. For example, in companies with active personnel turnover or regular Territorial Recruitment and Social Support Center inspections, the workload may be comparable to a full separate position. In such cases, businesses often conclude that it is more efficient to create a separate staff position dedicated to military records keeping.

Responsibility and Penalties for the Absence of a Person Responsible for Military Records Keeping at a Company

The absence of a designated person responsible for military records keeping at a company constitutes a serious violation of legal requirements. In the event of an inspection by the Territorial Recruitment and Social Support Center or other supervisory authorities, penalties can be significant, and consequences may range from administrative liability for specific employees to the temporary suspension of certain company operations.

Typical violations that can lead to sanctions include:

• Absence of a formal appointment order for the responsible person or failure to establish additional pay;
• Mismatch between the job description and actual duties performed.

For this reason, the appointment and proper preparation of the responsible person is a key guarantee of the company’s legal compliance and operational safety.

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Outsourcing Military Records Keeping: Why It’s More Beneficial for Business

For most companies, military records keeping is a constant source of stress, especially since legislation changes faster than HR staff can update records. Not every enterprise has the internal resources or a specialist capable of competently assuming the responsibilities of the person in charge of military records keeping while continuously monitoring legal changes.

In such situations, businesses face the risk of appointing someone “just for formality,” where documents exist but the process does not function in practice. That is why more and more companies are opting to engage a legal firm to outsource the responsibilities associated with organizing and supporting the work of the responsible person.

Outsourcing military records keeping at a company allows you to:

1. Save time for management and HR: there is no need to independently study regulatory requirements, draft orders, internal regulations, or job descriptions for the responsible person.
2. Reduce personal liability risks: lawyers ensure that the assignment of duties is correctly documented, and that the scope of authority and responsibility complies with legal requirements.
3. Avoid errors in documentation: appointment orders, additional pay, job descriptions, and journals directly related to the responsible person’s work are reviewed and verified.
4. Ensure support during inspections: for example, our lawyer can accompany the responsible person remotely or in person, helping to correctly respond to requests and comments from the Territorial Recruitment and Social Support Center, even if the company is located in a different city.

This approach allows a business to focus on operational activities while leaving legally complex and risky aspects of assigning and managing the responsible person’s duties to professionals who ensure the accuracy and legal compliance of the process with current legislation.

Successful case: Support for a Scheduled Military Registration Inspection at an Enterprise by the TCC

Outsourced Military Records Keeping: Why Choose Us?

Our law firm specializes in comprehensive support for military records keeping at enterprises. We assist businesses through every stage — from appointing the responsible person to managing inspections by the Territorial Recruitment and Social Support Center, and establishing a system that withstands audits of any complexity.

By working with us, you gain a reliable partner and a ready-made solution for your legal security:

• Full audit of military records keeping: we verify the presence and correctness of all orders, journals, and employee lists.
• Document preparation: orders, job descriptions, accounting journals, and inspection result records.
• Training for the responsible person — we provide instruction on proper recordkeeping and interaction with the Territorial Recruitment and Social Support Center.
• Legal compliance guarantee: we monitor legislative changes and ensure that your records meet the latest requirements.
• “Hotline” support: the responsible person has direct access to our specialist for resolving non-standard situations in real time.
• Inspection support: we handle communication with the Territorial Recruitment and Social Support Center representatives, protecting the enterprise’s interests.

With our support, your business operates smoothly, without fines or risk of violations, while the responsible person has clear instructions and support at every step.

Unsure if your documentation will pass a Territorial Recruitment and Social Support Center inspection? Don’t wait for an inspector to identify a violation. Order a professional audit or full military records keeping services now — submit an online request or call us at the listed number.

More details about the service and the cost of outsourced military records keeping for enterprises are available here.