Military Records at a Company in 2026: What Every Employer Must Do

Updated: July 2026 — reflecting the amendments introduced by Cabinet of Ministers Resolution No. 812 dated June 10, 2026, as well as Resolutions No. 692 and No. 862 regarding employee reservation.

In the summer of 2026, several legislative updates came into force. HR management, military records, employee reservation, and deferments now operate as a unified system. If an employee’s military registration data is outdated or they are not registered for military service, the company may lose the ability to obtain a reservation for that employee.

The government is gradually transitioning military records to a digital format. Employers must do more than simply maintain documentation — they also need to verify data promptly, interact with government registries, and comply with new legal requirements.

In this article, we’ll explain:

• who is required to maintain military records;
• what responsibilities employers have;
• what changed after June 27, 2026;
• how to organize military records in electronic format.

What Are Military Records at a Company?

Military records at a company are a system for maintaining information about conscripts, persons liable for military service, and reservists employed by the organization. The employer collects, updates, and submits information about these individuals to the Territorial Center for Recruitment and Social Support (TCRSS) in accordance with the established procedure.

Simply put, the law requires employers to maintain military records for their employees.

This obligation applies equally to large enterprises and small businesses. If a company hires an employee who is liable for military service, it must organize individual military recordkeeping for that employee.

That is why military recordkeeping has long ceased to be a standalone HR task. It directly affects hiring, HR changes, employee reservation, and interaction with government authorities.

Which Laws Regulate Military Records?

The primary legal act is the Law of Ukraine «On Military Duty and Military Service». It defines the categories of individuals subject to military registration and establishes employers’ obligation to maintain military records at employees’ place of work.

The practical procedures for HR departments are established by Cabinet of Ministers Resolution No. 1487 dated December 30, 2022, which approved the Procedure for Organizing and Maintaining Military Records of Conscripts, Persons Liable for Military Service, and Reservists (Procedure No. 1487).

This regulation governs:

• organization of military recordkeeping;
• documents employers must maintain;
• deadlines for submitting notifications;
• procedures for reconciling records;
• liability of responsible officials.

Procedure No. 1487 serves as the primary operational framework HR professionals rely on in their day-to-day work.

What Changed on June 27, 2026?

Cabinet of Ministers Resolution No. 812 dated June 10, 2026, substantially updated Procedure No. 1487. The main objective of these changes is the gradual transition from paper-based military records to electronic interaction with government registries.

For employers, this means new procedures and a revision of familiar HR workflows.

The 72-Hour Rule for Electronic Military Registration Documents

When hiring an employee, the electronic military registration document (e-MRD) must have been generated no earlier than 72 hours before the employment date.

In other words, an old PDF file or a screenshot created a week earlier is no longer sufficient. The employee must provide a current electronic document generated through Diia or the State Web Portal for National Security and Defense.

Mandatory Verification Against the Oberih Register

Employers are now required to verify more than the existence of a military registration document. They must also ensure that the information in the document matches the data contained in the Unified State Register of Conscripts, Persons Liable for Military Service, and Reservists («Oberih»).

Electronic Submission of Notifications

If notifications regarding an employee’s hiring, transfer, or dismissal are submitted through Diia using the new procedure (Appendix 28-1 to Procedure No. 1487), there is no longer any need to submit a paper copy.

This reduces paperwork and simplifies interaction with the TCRSS.

A New Approach to Data Reconciliation

Annual internal reconciliation of individual military record lists remains mandatory.

However, the legislation now provides a clearer distinction between:

• internal reconciliation of company records;
• external reconciliation with the TCRSS.

Where technically possible, external reconciliation may be conducted electronically.

Employees with Suspended Employment Contracts

If, due to the armed aggression against Ukraine, an employee cannot perform their duties or the company cannot provide working conditions, both parties may suspend the employment contract in accordance with Article 13 of Law No. 2136-IX. In such cases, the employee is not removed from the company’s individual military record lists.

This means the employer must continue maintaining that employee’s military records regardless of the suspension of the employment relationship.

What This Means for Employers

Despite the rapid digitalization, the transition is still ongoing. Some electronic services are still being implemented, so companies must continue performing certain procedures in both electronic and paper formats.

However, one fundamental rule remains unchanged:

Who Must Maintain Military Records at a Company?

All legal entities, regardless of ownership structure, company size, or subordination, are required to maintain military records.

Overall responsibility for organizing this process rests with the head of the company (Clause 8 of Procedure No. 1487). The head is also responsible for errors in military recordkeeping. However, this does not mean the director must maintain the records personally. In practice, this responsibility is usually assigned to an HR specialist or another designated employee.

The number of employees responsible for military records depends on the number of individuals subject to military registration (Clause 9 of Procedure No. 1487).

If Fewer Than 500 Individuals Are Registered

These responsibilities may be assigned to an HR inspector or another HR department employee. In this case, the employee is entitled to an additional payment of up to 50% of their base salary.

If More Than 500 Individuals Are Registered

The company must establish a dedicated Military Records Inspector position (Occupational Classification Code 3439). No additional compensation is provided because maintaining military records is part of the position’s official duties.

As the number of persons subject to military registration increases, so does the required number of inspectors. For example, companies with 4,001 to 7,000 registered individuals must employ three inspectors, with one additional inspector required for every subsequent 3,000 individuals.

What Employers Often Overlook

When organizing military recordkeeping, it is important to consider several requirements that are frequently overlooked.

• The designated responsible employee must meet the qualification requirements for the Military Records Inspector profession (Occupational Classification Code 3439).
• Assigning these responsibilities to an existing employee constitutes a change to the essential terms of employment. A management order alone is not sufficient—the employee’s written consent is also required.
• The appointment must be formalized by an official order, and the TCRSS must be notified of the appointment or dismissal of the responsible employee within seven calendar days.

Military recordkeeping is an ongoing process. If it is treated as an additional task without clearly assigned responsibility, the risk of missing reconciliation deadlines, notification deadlines, or data updates increases significantly.

Which Employees Must Be Included in Military Records?

Employers maintain military records only for individuals employed under an employment contract.

This requirement applies both to primary employees and to part-time employees. The individual military record lists must include:

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

These are the categories of employees subject to individual military recordkeeping under Procedure No. 1487.

Is It Necessary to Maintain Military Records for Individuals Working Under Civil Law Contracts?

No. Individuals who perform work or provide services under civil law contracts or gig contracts are not in an employment relationship with the company. The same applies to independent contractors operating as sole proprietors (FOPs).

Therefore, employers do not include such contractors in their individual military record lists and do not submit notifications about them to the TCRSS.

What Are an Employer’s Responsibilities Regarding Military Records?

Procedure No. 1487 establishes a clear list of employer responsibilities. Most of these obligations arise when hiring an employee, processing HR changes, or updating personal information.

Verify Military Registration Documents During Hiring

An employee cannot be hired without a military registration document.
If a candidate uses an electronic military registration document (e-MRD), it must have been generated no earlier than 72 hours before the hiring date.

At the same time, the absence of a generated e-MRD does not automatically prevent employment. The employee may generate the document immediately before the hiring process is completed.

Notify the TCRSS About HR Changes

After issuing an order for:

• hiring;
• transfer;
• dismissal,

the employer must notify the relevant TCRSS within seven days.

If the company uses the new electronic procedure through Diia, a paper copy of the notification is no longer required.

Keep Military Registration Data Up to Date

If an employee changes:

• place of residence;
• marital status;
• education;
• job position,

the HR department must update the individual military record lists within five days.

The sooner updated information is reflected in the records, the lower the risk of issues during employee reservation or inspections.

Reconcile Information Regularly

At least once a year, the employer must reconcile:

• the company’s individual military record lists;
• employees’ military registration documents;
• information held by the TCRSS.

Where technically possible, reconciliation with the TCRSS may be performed electronically.

Fulfill Employee Notification Requirements

If the company receives an official notice from the TCRSS requiring an employee to appear, the employer must:

• issue an employee notification order;
• obtain the employee’s signed acknowledgment;
• ensure the employee reports to the TCRSS or release them from work for the time required to fulfill this obligation.

Employers are not permitted to ignore these requirements.

What Should an HR Inspector Verify When Hiring an Employee?

Verification of military registration documents begins before the employment contract is signed. If an HR inspector overlooks an issue at this stage, the company may later encounter problems during employee reservation, TCRSS inspections, or updates to military registration records.

This checklist can be incorporated into the company’s internal onboarding procedures. Doing so helps avoid repeated document verification after the employee has already been hired.

What Documents and Processes Must Be in Place?

Military recordkeeping cannot be maintained without properly prepared documentation. If even one mandatory document is missing or completed incorrectly, the company risks receiving remarks during an inspection.

Keeping all required documents up to date significantly reduces the time needed to prepare for inspections.

What Happens If Military Records Are Maintained Improperly?

Improper military recordkeeping is more than just a risk of fines. The consequences may affect HR processes and the company’s operations as a whole.

The TCRSS conducts both scheduled and unscheduled inspections. If violations are identified, responsible officials may be held administratively liable.

Under Article 210-1 of the Code of Ukraine on Administrative Offenses, fines range from UAH 34,000 to UAH 59,500 for each individual violation. For example, if an employer fails to notify the TCRSS of an employee’s hiring within the required deadline.

However, financial penalties are far from the only concern. Violations of military recordkeeping requirements may result in:

• refusal to grant employee reservation;
• delays in obtaining deferments;
• additional inspections;
• the need to urgently correct documentation;
• disruptions to HR processes.

For companies employing business-critical personnel, these consequences are often far more significant than the fine itself.

Why Can’t Employee Reservation Function Without Proper Military Records?

If military records are maintained incorrectly, a company may be denied employee reservation. That is why HR recordkeeping and employee reservation can no longer be treated as separate processes.

The HR inspector must first ensure that military registration data is accurate and up to date. Only then can the company proceed with employee reservation through government services.

In 2026, this relationship became even stronger. The rules governing military recordkeeping, employee reservation criteria, and data verification in government registries were all updated simultaneously.

What This Means for HR Inspectors

While employee reservation could still be viewed as a separate process a year ago, today it is merely the final stage.

Before submitting reservation documents, the HR department must ensure that:

• the employee’s personal data is up to date;
• military records are maintained without errors;
• HR documentation is consistent with information in government registries;
• the company meets the eligibility criteria for employee reservation.

The better military recordkeeping is organized, the less time HR inspectors spend correcting errors during the reservation process.

How to Organize Military Records in Vchasno.Kadry

The more a company relies on manual recordkeeping, separate spreadsheets, and calendar reminders, the greater the risk of missing important changes. In 2026, military recordkeeping can no longer be viewed separately from HR management, employee reservation, and deferments.

That is why more and more employers are adopting systems such as Vchasno.Kadry, which help manage all these processes in one place. Military recordkeeping is fully integrated into HR workflows.

Instead of maintaining multiple separate registers, the HR inspector works with a single employee profile. Once information is entered, the system reuses it across multiple HR processes, eliminating the need to duplicate data.

Specifically, Vchasno.Kadry enables companies to:

• maintain employee profiles and military registration data in one place;
• automatically generate lists of persons liable for military service, conscripts, and reservists in accordance with Appendix 5;
• monitor deadlines for updating information;
• track reservation and deferment statuses;
• quickly identify employees who require a specific action.

For HR inspectors, this means significantly less manual work. For managers, it provides greater confidence that business-critical data remains accurate and up to date.

Military recordkeeping is a fundamental legal requirement for every employer. In 2026, the regulatory framework is evolving almost monthly: following Resolution No. 812 on electronic military records and Resolutions No. 692 and No. 862, employee reservation and military recordkeeping have become closely interconnected. Without a well-organized document management system, it is impossible to monitor all these processes simultaneously while retaining key employees.

With Vchasno.Kadry, you can easily manage all data required for military recordkeeping. This helps HR departments comply with legal requirements and protects businesses from a wide range of operational and compliance risks.