Digitalizing Employers’ Military Registration Duties

06/ 08/ 2026

Listen to online Stop   In brief On 10 June 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 812, “On Amendments to the Procedure for Organizing and Maintaining Military Records of Conscripts, Persons Liable for Military Service, and Reservists” (the “Resolution”). The amendments entered into force on 27 June 2026 and, among other changes, provide for the electronic exchange of information between employers and military registration authorities. In more detail When hiring an employee, employers must verify that the individual holds a valid military registration document, whether in electronic or paper form. In addition, no earlier than 72 hours before the employees start date, the employer must verify that the information contained in the military registration document matches the data maintained in the Unified State Register of Conscripts, Persons Liable for Military Service, and Reservists (the “Registry”).   Employers must continue to notify the relevant Military Registration Office (the “MRO”) of the hiring or termination of an employee within seven days of the issuance of the relevant order. Where technically feasible, employers may submit such notifications electronically through the Diia Portal or the empoyer’s personal account in the Registry. In such cases, submission of a paper notification is not required.   Employers must update employee personal data in their military registration records, including residential address, place of work, position, and other relevant information, within five days of receiving the relevant supporting documents or when such information becomes available electronically. Notifications of these changes must be submitted to the relevant MRO monthly, no later than the fifth day of each month. Such notifications may be filed electronically through the employer’s personal account in the Registry. If electronic submission is not technically feasible, notifications must be submitted in paper form.   Where technically feasible, reconciliation of an employer’s military registration records with the records maintained by the relevant MRO may be conducted through the Diia Portal or the employer’s account in the Registry. If such functionality is unavailable, the person responsible for maintaining the employers military registration records must submit the required forms and copies of employees’ military registration documents to the relevant MRO either in person or by post.   Employers must continue to retain information in their military registration records regarding: (i) employees whose employment has been terminated, and (ii) employees who have been called up for military service. Such information must remain in the employers military registration records until the end of the relevant calendar year. Information relating to employees whose employment agreements have been suspended must remain in the records until their employment is terminated.   The employers CEO is responsible for ensuring the completeness, accuracy, and timely submission of military registration information. Individuals designated as responsible for maintaining the employers military registration records may also be held liable for violations, including the submission of incorrect, outdated, or otherwise inaccurate information. Such violations may result in administrative liability, including fines of up to UAH 59,500 (approximately USD 1,330). Additional information   The Resolution establishes the legal framework for the transition to electronic information exchange between employers and MROs. Employers are encouraged to engage proactively with the relevant MROs regarding their readiness to receive notifications, conduct reconciliations and exchange information electronically through the Diia Portal. Employers should also familiarize themselves with the Registrys functionality and create a personal account as soon as the option becomes available. Such functionality is currently expected to be launched in early September 2026.   Contacts   Lina Nemchenko Partner Baker McKenzie   Mariana Marchuk Counsel Baker McKenzie   Stanislav Muzhailo Associate Baker McKenzie

In brief

On 10 June 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 812, “On Amendments to the Procedure for Organizing and Maintaining Military Records of Conscripts, Persons Liable for Military Service, and Reservists” (the “Resolution”). The amendments entered into force on 27 June 2026 and, among other changes, provide for the electronic exchange of information between employers and military registration authorities.

In more detail

1. When hiring an employee, employers must verify that the individual holds a valid military registration document, whether in electronic or paper form. In addition, no earlier than 72 hours before the employee’s start date, the employer must verify that the information contained in the military registration document matches the data maintained in the Unified State Register of Conscripts, Persons Liable for Military Service, and Reservists (the “Registry”).
    
2. Employers must continue to notify the relevant Military Registration Office (the “MRO”) of the hiring or termination of an employee within seven days of the issuance of the relevant order. Where technically feasible, employers may submit such notifications electronically through the Diia Portal or the empoyer’s personal account in the Registry. In such cases, submission of a paper notification is not required.
    
3. Employers must update employee personal data in their military registration records, including residential address, place of work, position, and other relevant information, within five days of receiving the relevant supporting documents or when such information becomes available electronically. Notifications of these changes must be submitted to the relevant MRO monthly, no later than the fifth day of each month. Such notifications may be filed electronically through the employer’s personal account in the Registry. If electronic submission is not technically feasible, notifications must be submitted in paper form.
    
4. Where technically feasible, reconciliation of an employer’s military registration records with the records maintained by the relevant MRO may be conducted through the Diia Portal or the employer’s account in the Registry. If such functionality is unavailable, the person responsible for maintaining the employer’s military registration records must submit the required forms and copies of employees’ military registration documents to the relevant MRO either in person or by post.
    
5. Employers must continue to retain information in their military registration records regarding: (i) employees whose employment has been terminated, and (ii) employees who have been called up for military service. Such information must remain in the employer’s military registration records until the end of the relevant calendar year. Information relating to employees whose employment agreements have been suspended must remain in the records until their employment is terminated.
    
6. The employer’s CEO is responsible for ensuring the completeness, accuracy, and timely submission of military registration information. Individuals designated as responsible for maintaining the employer’s military registration records may also be held liable for violations, including the submission of incorrect, outdated, or otherwise inaccurate information. Such violations may result in administrative liability, including fines of up to UAH 59,500 (approximately USD 1,330).