Ukrainian Employers Face Fines Up to 59,500 Hryvnias for Failing to Report Employee Data to Military Centers

New Reporting Obligations for Employers

According to ХВИЛЯ: Ukrainian businesses are now legally required to report changes in their employees' personal data to Territorial Recruitment Centers (TCC). This mandate compels companies to submit updates on alterations to surnames, given names, patronymics, passport details, registered addresses, as well as changes in marital status, education, or job title. Failure to meet deadlines or ignoring these requirements will result in fines ranging from 34,000 to 59,500 hryvnias. The primary document for this reporting is Appendix 4. This regulation is part of broader efforts to maintain accurate national records during a period of heightened mobilization needs.

When hiring or dismissing an individual eligible for military service, employers must send the relevant data to the TCC within seven days of issuing the corresponding order. Furthermore, companies are obligated to report ongoing changes in employees' personal details by the 5th day of the month following the month in which the change occurred.

“By the 5th day of the month following the one in which changes to an employee's records occurred or discrepancies were identified during internal verification, the enterprise must send a corresponding notification to the TCC.”

Tetiana Sholkova

Electronic Reporting System

An electronic reporting system via the Diia platform is not expected to launch before the third quarter of 2026. Currently, the most reliable method for submitting reports remains using a recommended registered letter through Ukrposhta (Ukrainian Postal Service) with an inventory of the contents. If an employee reports changes with a delay, Tetiana Sholkova advises obtaining a copy of the relevant document from them, ensuring it is marked with the date it was provided.

“It is also advisable to obtain a written request from the employee asking to add the new information to their personnel file.”

Tetiana Sholkova

Compliance with these new reporting rules is therefore crucial for avoiding penalties and ensuring employee records are up-to-date. Employers must be vigilant about changes in their staff's data and respond promptly to avoid potential sanctions.

The introduction of these reporting requirements aims to enhance oversight of employees subject to military service in Ukraine, a measure of particular relevance given the ongoing security situation. These changes may impact the HR policies of many businesses, as they demand timely reactions to updates in staff personal data. Given the risk of substantial fines, employers must find efficient solutions to manage these processes. While the future Diia platform is intended to simplify reporting, for now, companies should adhere to traditional submission methods.