TCC Military Record Inspection: Common Violations and How to Prevent Them

If your company has critical enterprise status and reserved (exempted) employees, you’ve likely already heard that Territorial Recruitment Centers (TCCs) have significantly intensified audits of military registration at such enterprises.

For business owners, directors, CEOs, HR specialists, and staff responsible for military records, this creates an additional burden. Violations in maintaining military registration can lead to serious consequences — from losing critical status and the ability to protect employees through reservation, to financial penalties and administrative liability for specific officials.

The root cause of most problems is the lack of a systematic approach. Military registration is not a core business function, so in practice it is often handled formally: documents are outdated, the responsible person is not familiar with the required forms, reports are submitted late, reconciliations are not conducted, schedules are not prepared, and so on. In such cases, the TCC issues an inspection report noting the deficiencies, sets short deadlines for their correction, and imposes fines.

 Fines can reach tens of thousands of hryvnias. But the more serious issue is that disorganized military registration complicates employee reservation, increases the likelihood of repeat inspections, and creates a reputation of a company operating without proper control.

That is why responsible officers and management should already conduct an internal review of the state of military registration to ensure that all documentation is in order and to be able to pass any inspection with confidence.

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Most Common Compliance Mistakes Companies Make

To start, it’s important to remember that TCCs conduct annual inspections of companies that employ military-liable personnel who are reserved (exempted) or hold mobilization orders/assignments. That’s why having a properly organized military registration process is a key way to reduce risk.

During inspections, TCCs most often identify issues that aren’t the result of intentional non-compliance, but rather a lack of knowledge, limited experience, inattention, or an unsystematic approach to maintaining military records. Below are the main problems inspectors typically flag, along with the risks they create.

Missing Or Non-Compliant Appointment Orders For The Military Registration Officer

This internal order is the starting point for the entire military registration system in a company. If it is missing or drafted as a mere formality, a TCC inspector will typically record it as a violation right away. The document should clearly specify who is responsible for military registration, how the process is organized, where the records are kept, and which registers, forms, and logs the company maintains.

Inspectors also check for a separate order confirming the need or lack of need for professional training for the appointed responsible person. In practice, this is often overlooked. It may seem minor, but Procedure No. 1487 requires this order to be issued annually, even if management concludes that no additional training is needed that year. That decision still has to be documented in a separate order.

From the TCC’s perspective, the absence of this document is a sign that military registration is not properly organized and that the responsible officer is not following the legally established requirements.

Outdated Lists Of Military Liable Employees

By January 25 each year, a company must update two key documents based on the status as of January 1. These are the personal military registration list (Appendix 5) and the operational tracking statement (Appendix 12). After they are updated, both documents must be signed by the company head and the appointed responsible officer, and then registered in accordance with the established procedure.

In practice, many companies make the same mistakes. Lists are updated only on paper or not updated at all during the year, even though hiring and termination immediately affect the records. Companies also often fail to submit required notifications about these changes, and in some cases do not keep copies of employees’ military registration documents.

As a result, during an inspection it may become clear that the information in the lists does not match the actual situation, and that some employees cannot be confirmed with supporting documentation.

You might also like: Rules for Maintaining Military Records at an Enterprise

Inspectors also review how the company ensures employees are familiar with the Military Registration Rules. This is a process explicitly required under Procedure No. 1487. In practice, it often turns out that the acknowledgement log is not maintained at all, or contains only a handful of entries. An employee’s signature at the time of hiring is mandatory, as it confirms the person understands their obligations as a conscript or as a military liable individual.

The updated Rules must also be displayed in an accessible place where employees can realistically review them. Inspectors pay attention to this as well. If the document is kept somewhere in a folder rather than made available to staff, it is treated as a sign that the registration process is not properly organized.

Failure To Submit Reports To The TCC Or Errors In Reporting

This is one of the most closely reviewed areas during inspections. The most common issues include the following:

• Late or incomplete submission of notifications to the TCC about hiring, termination, or changes to an employee’s registration details.
• Missing notification about the appointment or dismissal of the officer responsible for military registration, or of the company head.
• Inability to prove that such notifications were submitted, for example by providing copies stamped by the TCC or electronic submission confirmations.

Deadlines for submitting notifications:

• in the case of appointment or dismissal, within 7 days from the date the order is issued;
• in the case of an employee’s hire, termination, or change of personal data, by the 5th day of the month following the change.

Formal Appointment of a Responsible Person or Insufficient Training

A common issue we have observed in most companies is the purely formal appointment of a responsible person. An internal order exists, but in practice the appointed individual does not clearly understand their duties, is unfamiliar with the required forms, does not understand the reporting procedures, and is often unable to present the necessary registers. For TCC inspectors, this is a clear signal that military record-keeping at the company is carried out nominally rather than as a functioning process.

To avoid such situations, management should ensure not only a formal appointment but also the actual readiness of the responsible person to perform their duties. After issuing an order on appointment or reappointment, the TCC must be notified in a timely manner (within seven days).

In addition, it is advisable to provide additional compensation for the increased workload. Inspectors pay attention to this aspect, as it is explicitly provided for by the Procedure for Maintaining Military Records.

During an inspection, the TCC reviews not only orders and lists, but the entire system of how military records are organized. It is important to have a log of inspection results regarding the state of military record-keeping, a schedule for regular reconciliation of employee data with TCC records, and evidence that all notifications and reports were submitted to the center on time.

It is also necessary to ensure that up-to-date copies of military registration documents are available for all employees subject to registration, so that the inspection proceeds without remarks.

Successful case: Support During a Scheduled Military Record-Keeping Inspection at an Enterprise

How to Prepare for an Inspection and Pass Without Remarks

Company executives should conduct a military record-keeping audit in advance. The main objective is to ensure full compliance of documentation and internal processes with legal requirements. This includes appointing a responsible person for maintaining records, ensuring that all required orders and document forms are in place, maintaining regular communication with the TCC, and providing training for responsible staff on current regulatory requirements.

Only a systematic and well-organized approach can ensure that inspectors see a functioning record-keeping system during the inspection, rather than merely formally completed folders.

Legal Support as a Guarantee of Peace of Mind During a TCC Inspection

When dealing with military record keeping, businesses need more than just advice. They need confidence that the system works on a daily basis. This is exactly our approach. We build a clear and predictable legal protection model for companies, where every document, process, and decision is structured so that management can focus on running the business rather than worrying about risks.

Our support includes:

• a comprehensive audit of military and HR records to identify risks before an inspection takes place;
• development of internal orders, policies, and document templates in line with current regulatory requirements;
• preparation for scheduled and unscheduled inspections, with the option of remote or in person legal representation;
• training for responsible personnel to ensure there are no blind spots during an inspection.

Pravova Dopomoha Law Firm is the place businesses turn to for precise answers and ready-made solutions. We work in a format that allows executives to delegate responsibility for proper military record keeping to professionals, save time, and avoid mistakes that can cost far more than timely legal support.

Request an audit and legal support during your company’s inspection. We will build a functioning military record-keeping system for you, without chaos, without stress, and without fines.