In the first and second quarters of 2023, state authorities started to actively verify employers' compliance with the requirements of the "Procedure for Organisation and Maintenance of Military Registration of Conscripts, Persons Liable for Military Service and Reservists", which came into effect on 5 January 2023 ("Procedure"), and to hold their managers and other relevant employees liable for breach of obligations under the Procedure.
Key requirements of the Procedure
- The organisation of military registration record keeping is the responsibility of the company's management.
- First and foremost, the top manager must do the following, among other things:
- Appoint a person responsible for the organisation and maintenance of the military registration records and for liaison with the relevant Territorial Centre of Recruitment and Social Support (TCR)
- Inform all employees subject to military service duty of the "Rules of Military Registration" against their personal signature
- Notify TCR of changes to the personal data of the employee subject to military service duty within seven days, including if hiring or dismissing such employees
- Notify the TCR within seven days from the date of appointment or dismissal of the top manager and/or of the person responsible for the organisation and maintenance of military registration records
- Fulfil many other obligations requiring specific action, the full list of which (mostly record-keeping requirements) includes more than 30 items
- Non-compliance with the above or any other requirements of the relevant legislation triggers liability for the company's management in the form of a fine, the decision on the imposition of which is made by the chief of the relevant TCR.
Employer inspections for compliance with the military registration requirements are becoming increasingly frequent and the number of fines being imposed on management is rising rapidly.
We recommend that managers review the full text of the Procedure for a more detailed understanding of its requirements. Upon request, we can provide a summary of the Procedure (the list of employers' obligations and required actions), including in English.
