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Employer Obligations: Reconciling Military Service Personnel Registers

Обов'язки роботодавців щодо забезпечення прав військовослужбовців під час реєстрації.

Employer Responsibilities and Key Procedures for Military Register Reconciliation

Employers in Ukraine are legally required to reconcile their personal military accounting lists with Territorial Recruitment Centers (TCCs). This is a critical annual process, though TCCs may request more frequent verification in specific cases. Employers must coordinate with TCCs through two primary channels:

  • at the location of the company's official registration;
  • at the location where employees are registered for military service.

For annual reconciliation at the location of an employee's military registration, companies must comply with Clause 46 of Procedure 1487. This involves mailing two copies of extracts from the personnel lists along with document copies. One copy must be returned by the TCC marked 'Reconciled'. This process applies only to current, active employees. Individuals removed from the register, those already mobilized, or former employees are not included in these lists.

All reconciliation results must be formally recorded in a designated log (Appendix 9). Any discrepancies identified must be corrected and reported to the TCC. According to Tetiana Donets, reconciliation must occur at least annually, and companies must follow a schedule approved by local administrative or city authorities when reconciling with their local TCC.

'There is no need to search for specific schedules to reconcile employee military registration data; simply fulfilling the requirements of Clause 46 of Procedure 1487 once a year is sufficient.' Tetiana Donets

If a company misses the 2025 reconciliation deadline, Tetiana Donets advises submitting lists as soon as possible, particularly if conscripts, reservists, or other liable individuals were employed or studied there in previous years without proper military accounting. She reiterated that the process only concerns liable individuals who are currently employed or studying, as demobilized or dismissed persons are no longer considered liable for this purpose.

Maintaining accurate military personnel registers is a vital component of national defense preparedness. This process helps employers avoid legal complications and ensures reliable data for military authorities. Given the ongoing conflict, proper accounting of eligible personnel is especially crucial for effective national resource mobilization.