On 13 March 2026, the Diia state portal technically implemented a mechanism for the temporary reservation of employees of defence sector companies with military registration violations. The relevant amendments entered into force on 4 December 2025 pursuant to the Law of Ukraine dated 9 October 2025 No. 4630-IX “On Amendments to Certain Laws of Ukraine Regarding the Organisation of Labour Relations under Martial Law” (the “Law”).
The changes apply to defence sector companies, in particular companies that are:
- recognised as critically important for meeting the needs of the Armed Forces of Ukraine and other military formations; or;
- recognised as critically important for the functioning of the economy and ensuring the livelihood of the population during the special period in the defence-industrial complex sector.
Under the Law, military-liable employees of such companies may be reserved even if they do not have military registration documents or have documents that have been improperly issued, and/or have not updated their personal data, and/or are listed as wanted for violations of military registration rules or legislation on defence, mobilisation preparation and mobilisation.
At the same time, the Diia portal notes that in order to reserve persons with military registration violations, the employee must still be registered with the military authorities. Accordingly, if an employee is not registered with the military authorities, the Diia portal will most likely not allow the reservation to be processed.
The reservation period for such military-liable employees may not exceed 45 calendar days from the date of conclusion of the employment agreement. Such reservation may be granted to the employee no more than once per calendar year.
For more information, please contact Maksym Tesliar at maksym.tesliar@kinstellar.com or Valentyna Danyliuk at valentyna.danyliuk@kinstellar.com.
