Military Registration in Ukraine for Employers: Documents, Deadlines and First Steps

To establish military registration recordkeeping, a company director needs to organize three things: checking employee information, preparing the required documents, and keeping the records up to date through day-to-day work. Start with a simple question: can you use your existing documents to explain which employees the company accounts for and what it did after the most recent personnel change? A folder of military IDs cannot answer that question.

The company head is responsible for organizing these records, so any gaps are primarily a risk for that person. We discuss the possible consequences in our article on liability for military registration violations.

This article answers the questions we hear most often from company managers and HR staff:

• who must maintain military registration records at a company, and whether this applies to individual entrepreneurs (FOPs);
• where to start if no records are being kept;
• which documents need to be maintained;
• who must be included in the lists;
• which notification and reconciliation deadlines must be met.

Below is a step-by-step guide to military registration recordkeeping at a company, intended for employers setting up or restoring their records. The procedure is the same for companies of any size: having a small workforce does not remove the obligation to keep records. The rules have been checked against Procedure No. 1487 on the Organization and Maintenance of Military Registration Records, as of October 14, 2026.

In addition to Procedure No. 1487, employers’ main obligations are established by the Ukrainian laws “On Military Duty and Military Service” and “On Mobilization Preparation and Mobilization”. When notifying employees during mobilization, also take into account the Procedure for Conscription During Mobilization, approved by Cabinet of Ministers Resolution No. 560. When processing employee documents, comply with the requirements of the Ukrainian Law “On Personal Data Protection”.

We set up and maintain military registration records for companies, from document reviews to monthly support. You can read what the service includes on our military registration recordkeeping and employee reservation support page.

Who Must Maintain Military Registration Records at a Company: LLCs and Individual Entrepreneurs 

A Ukrainian limited liability company (LLC) must maintain military registration records if it employs conscripts, persons liable for military service, or reservists. Accordingly, the composition of the workforce—not critically important enterprise status or an intention to reserve employees from mobilization—determines whether military registration recordkeeping is required at a company. The obligation also applies to legal entities that do not reserve employees at all.

A small workforce does not remove the obligation either. Check all formally employed staff, including the director: not having a dedicated HR officer says nothing about whether the records are required. Conversely, if the company has no employees subject to military registration, it does not need to create records for nonexistent persons liable for military service.

Must an Individual Entrepreneur Maintain Military Registration Records?

Procedure No. 1487 does not expressly include individual entrepreneurs (FOPs) among the employers required to maintain personal military registration records. The issue of military registration recordkeeping by a FOP must therefore be considered separately, starting with the capacity in which the entrepreneur acts.

Must a FOP maintain military registration records for employees with whom employment agreements have been concluded? The employment agreement itself does not make the entire set of records maintained by an LLC mandatory for the entrepreneur. And if a FOP works without employees, there are no staff members for such recordkeeping at all.

All of this concerns the FOP as an employer. The entrepreneur’s own military registration obligations and those of the entrepreneur’s employees apply separately: registering as a FOP or working for one does not exempt them from those obligations.

Company Military Registration: Six Steps From Scratch

Start with what you already have and finish by agreeing on who will maintain the records each day and how.

1. Assess what you are working with. Compare personnel orders against the list of people actually employed, remember part-time employees, and review the existing military registration documents. Identify missing information and inconsistencies. Otherwise, the new lists will repeat the old mistakes.
2. Appoint a responsible employee. Decide who will handle day-to-day military registration recordkeeping. The appointment order and the employee’s job responsibilities must describe this work consistently. Do not copy another company’s order without checking your headcount, job positions, and the actual allocation of duties. Notify the Territorial Recruitment and Social Support Center (TCC) of the appointment. Important: a lawyer can prepare documents and identify deficiencies, but the company head’s and the responsible employee’s own duties remain theirs. For details on documenting the appointment, see our article on the employee responsible for military registration records.
3. Complete the registration forms using verified documents. Do not infer a person’s military registration category or fitness for service from their job title or what they say.
4. Arrange employee acknowledgment and document storage. Familiarize employees with the rules, organize the storage of documents, and restrict access to authorized persons.
5. Agree on a daily process: who sends personnel orders to HR, who receives updated information from employees, and who monitors deadlines.
6. Address gaps from previous periods. If notifications or reconciliations are missing for earlier periods, document the gap and determine how to remedy it. Backdated documents will not prove that actions were taken if they never occurred.

Military Registration Documents a Company Must Maintain

The easiest way to review the documents is to consider what each of them proves.

• Who maintains the records. The company order on military registration recordkeeping and the relevant job documents must show who is assigned responsibility. They should be accompanied by notifications of the appointment or dismissal of responsible persons (the form in Appendix 1 to Procedure No. 1487) and proof that the notifications were submitted.
• Who is registered. Individual records appear in the personal military registration lists under Appendix 5 to the Procedure, and aggregate headcounts appear in the operational military registration summary under Appendix 12. Each entry must be supported by a military registration document. Keep copies of these documents as required by the Procedure; electronic storage is permitted.
• What has been done. The military registration rules, employees’ signatures acknowledging the rules, the reconciliation schedule and supporting materials, and the inspection results log under Appendix 9. Having a schedule alone does not prove that the reconciliation took place.
• Specific events. A personnel order, a change in employee information, or an instruction received regarding notification or reservation of employees—each event requires its own actions and documents. Check not only the text of the notice but also the evidence that it was sent.

This does not mean that all of these documents must be produced every month. For example, employee notification documents are created only when the relevant instruction is received. Also, distinguish a mandatory form from your own filing system: keeping a separate acknowledgment log may be convenient, but giving it a particular name does not make it a legal requirement.

Military Registration of Employees: Who Must Be Included in the Lists?

Employees with confirmed military registration status are entered in the lists. For each person, HR must determine two things: the person’s confirmed status and the category of list to which they belong. Paragraph 36 of the Procedure provides for separate lists covering:

• officers;
• enlisted personnel, noncommissioned officers, and senior noncommissioned officers;
• women who are liable for military service or are reservists;
• conscripts.

Do not remove employees from the lists merely because they work remotely or part-time or are abroad. A deferment or reservation from mobilization does not terminate military registration either. The entire workforce must therefore be checked, not only those whom the company intends to reserve.

However, not everyone should be added indiscriminately:

• a foreigner employed by a Ukrainian LLC does not acquire Ukrainian military registration status simply through that employment;
• a woman is included if she has the relevant status and supporting information;
• if an employee says their military registration has ended, read the document: being “removed from the register” and being “excluded from the register” mean different things. An oral explanation is not enough to decide what to do with the employee’s entry.

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Military Registration Recordkeeping Rules: Notification Deadlines and Reconciliations

Once the recordkeeping system is in place, a company’s military registration obligations follow three cycles: action after each personnel event, monthly notifications of changes, and an annual plan. Every action must leave an evidentiary record.

Hiring an Employee

A person subject to military registration may be hired after the relevant authority has registered them. Once the start date has been agreed, HR checks the military registration document and reconciles its information with the state register (paragraph 34 of the Procedure). At the time of hiring, an electronic document must have been generated no earlier than 72 hours beforehand. A document shown by the candidate at the first interview may therefore no longer be sufficient. There is an exception to the state-register reconciliation requirement for persons registered with the Security Service of Ukraine (SBU) or intelligence agencies. Where technically available, the check may be carried out through the personal registration account.

Deadlines Following Personnel Changes

Each personnel event starts its own deadline.

One reminder to “update the records at the end of the month” is therefore not enough for HR.

Annual Plan

• Reconciliation against employee documents — annually, or more frequently if necessary, according to the company’s internal schedule.
• Reconciliation with the authority where employees are registered (the TCC, SBU, or the relevant intelligence agency) — annually, or more frequently if necessary. One type of reconciliation does not replace the other.
• By January 25 — the company head and the person responsible for recordkeeping sign the lists and the operational military registration summary containing information as of January 1, after which the documents are registered in the company’s records management system.
• By October 1 — the company determines whether the person responsible needs further professional training. No more than five years may elapse between training sessions. Appointment by an internal order does not replace this training.

What to Do When the TCC Issues an Instruction to Notify Employees

1. Order. After receiving a TCC instruction to notify employees, the company head issues an order identifying the employees, the date, time, and place where they must appear, and those responsible for notification and monitoring compliance.
2. Acknowledgment. Employees are informed of the order against their personal signatures. Summonses, if provided, are served during working hours against the employees’ personal signatures.
3. Absent employees. For employees working remotely or from home, temporarily unable to work, on leave, or on a business trip, the relevant part of the order is sent by registered mail with an inventory of enclosures and delivery confirmation.
4. Report to the TCC within three days. A copy of the order and evidence of notification must be submitted to the TCC within three days. Within the same period, the company must report in writing on the outcome of the notifications and employees’ compliance with the applicable requirements. Temporary incapacity for work, leave, or business travel must be reported in writing, accompanied by extracts from the relevant orders.
5. Refusal to accept a summons. A refusal to receive a summons must be documented and reported to the TCC immediately.
6. Appearance. The company monitors the notification outcomes and employees’ appearance and either releases them from work for the time needed to appear or arranges transportation.

How to Prove That a Notification Was Submitted

For each notification, check the permitted submission method and keep proof of submission. For example, if hiring or dismissal has already been reported through Diia or the personal registration account, there is no need to duplicate the notification on paper. What matters is actual transmission: a file that was prepared but never sent does not prove compliance with the obligation.

How Military Registration Recordkeeping Relates to Employee Reservation From Mobilization

Employee reservation relies on military registration data: if the employee information is incorrect, the electronic check may not confirm the required details. Before submitting a list of employees for reservation, we therefore reconcile their employment relationships and military registration data. An internal list alone does not establish that the information is correctly reflected in the state registers.

Obtaining deferments does not end this work: personnel changes after reservation must be processed in the same way. Specific situations are covered in our article “Military Accounting After Employee Reservation: Lists and Inspections”.

What We Find at Companies: Two Examples From Our Work

A signed order does not necessarily mean that recordkeeping has been organized, and completed forms can still contain gaps. Both findings came from one of our cases.

An order exists, but the duties are not established. When preparing a manufacturing company for an inspection, we began by reviewing the order appointing the responsible employee. The order had existed since 2023, but it was not properly aligned with the employee’s job responsibilities or compensation for additional work. We updated the organizational documents and prepared the responsible staff. Comparing the documents revealed the problem: the order alone was not sufficient.

Documents exist, but the records are incomplete. In the same matter, the lists and operational summary existed but had not been properly signed as part of the annual process. There were also deficiencies in reconciliations and notifications. We organized these materials to prepare the company for inspection. This is why, when setting up or restoring recordkeeping, we also review documents that have already been completed. Read more in our case study on support during a scheduled inspection.

The consequences of violations depend on what exactly was violated and how it was documented. See our article on fines for military registration violations.

Setting Up Military Registration Recordkeeping at a Company: What We Do and What Determines the Cost

Military registration recordkeeping rarely involves a single isolated mistake. More often, there are several gaps: lists were not updated after personnel changes, notifications were submitted without proof, or an order appointing a responsible person exists but the duties are not consistent with the job documents. That is why, before an inspection or employee reservation, after a change of HR staff, or following a period of irregular recordkeeping, it is worth assessing the entire process rather than just one form.

That is exactly what we do: identify missing documents and actions, prepare the required set of documents, and explain to the responsible employee how to maintain the records going forward. The result should be more than a set of completed forms. It should be a system under which the responsible employee understands what to do when someone is hired or dismissed, employee information changes, records are reconciled, or employees must be notified.

What you receive:

• a list of gaps — which documents and actions are missing;
• an assessment of what has already been done correctly and can remain unchanged: if the company already maintains records, we do not recreate the entire system but address the specific gaps;
• the required set of documents;
• a clear procedure for the responsible employee.

We select the scope of work for your situation: an audit of existing recordkeeping, an initial setup from scratch, or ongoing monthly support. Setup and continuing support are agreed separately; you do not have to purchase everything at once.

What determines the cost:

• how many people are subject to military registration;
• how many divisions the company has;
• the condition of the documents;
• how much work is needed to address the identified gaps.
• For our initial assessment, we need:
• the company’s EDRPOU code;
• a staff list;
• existing military registration orders;
• recordkeeping forms — the lists and operational summary;
• materials from the latest reconciliations and notifications;
• information on whether an inspection or employee reservation is planned.

We transfer personal documents using a secure method agreed separately.

Not sure whether your company’s military registration records would withstand an inspection? Submit a request on our website or call us. We will review the existing records and determine what needs to be corrected.

For more information about the service, see our legal support page for military registration recordkeeping and employee reservation.