Military Accounting: New Criticality Requirements, Reduced Registration Periods and Mandatory e-MRDs

Material prepared by Natalia Slipchenko,
Senior HR Records Management Specialist/
 Military Records Specialist
Department for the Provision of HR Records Management 
 and Payroll Accounting Services

In December 2025, the Cabinet of Ministers of Ukraine approved several important changes to the procedure for reserving military-liable employees, issuing military registration documents and identifying critical enterprises.

These innovations are aimed at improving the effectiveness of employee protection for enterprises, digitising military registration process and ensuring transparency and compliance with modern defence sector requirements. The key aspects of these changes are outlined below, along with their impact on employers and employees, and the prospects for the further development of electronic services for businesses.

• The established 72-hour deadline for verifying reservation lists in Diia is cancelled

At the end of the current year and the beginning of the following year, many enterprises will see their employees’ reservations expire. To avoid a situation where critically important employees lose their reservations due to procedural delays, the government has temporarily simplified the reservation rules.

On 8 December 2025, the Cabinet of Ministers of Ukraine approved the amendments to the Procedure for reserving conscripts. These amendments are intended to protect the human resources of enterprises in the defence and industrial complex that support the country’s economic stability.

Among the main changes is the cancellation of the 72-hour deadline for verifying the lists of employees nominated for reservation at critical enterprises. This will enable faster decision-making and protect employees from potential mobilisation, thereby maintaining production process continuity.

However, it should be noted that these simplifications will be temporary and shall remain in effect until 1 February 2026. Following this date, the standard regulations will be reinstated.

Therefore, until 1 February 2026, critical enterprises will be able to register their employees on the Diia portal three times faster.

According to comments from representatives of the Ministry of Digital Transformation, the possibility of submitting applications to extend reservations in advance is now also being considered. This will make the process continuous, ensuring there is no gap between the expiry of the old reservation and the commencement of the new one.

• Electronic military registration documents (or printouts thereof) become mandatory

The government has also updated the procedure for issuing military registration documents: from now on, they will be created exclusively in electronic format.

To implement these changes, the Cabinet of Ministers of Ukraine has adopted amendments to the resolutions regulating the military accounting procedure and the issuance of military registration documents:

1. No. 1487 dated 30.12.2022 “On Approval of the Procedure for Organising and Maintaining Military Records of Conscripts, Persons Liable for Military Service and Reservists”
2. No. 559 of 16 May 2024 “On Approval of the Procedure for the Registration (Creation) and Issuance of Military Registration Documents for Conscripts, Persons Liable for Military Service and Reservists and the Form of Such Documents” 

The CMU resolution amending the above resolutions has not yet been published as of today. 

Thus, Reserve ID becomes the main form of military registration document for conscripts, persons liable for military service and reservists. It can be obtained directly via the Reserve+ application.

A paper version is available to citizens unable to use the electronic document at all times. It can be:
- printed personally by downloading the PDF in Reserve+ or the Diia portal.
- obtained at the TCR and SS, where the document will be generated in electronic form and a printout will be provided.

But now the question arises regarding the use of the following paper military registration documents (hereinafter — the MRDs):

1. Certificate of registration with the TCR and SS
2. Military ID 
3. Temporary registration document of a person liable for military service
4. Military registration document in the new paper form.

Currently, it is only possible to predict that paper MRDs issued before 11 December 2025 will remain valid if they are used (provided, presented) alongside e-MRDs from Reserve+.

As stated by the Deputy Minister of Defence of Ukraine for Digital Development, Digital Transformation and Digitalisation, the transition to electronic form serves to minimise the risks of loss, damage or forgery of the documents.

It is important to note that if any data changes, the QR code on the printout will no longer be valid. Furthermore, it is important to note that electronic military IDs and their printouts are valid for a period of one year.  

One of the developers of “Reserve+” also clarified that new paper documents will no longer be issued. The validity of the previous registration will be maintained until there is a change in the data of persons liable for military service. As he has stated, the Reserve ID is formed on the basis of data from the register, rather than records from paper files. The system is designed to prevent errors, such as entering inaccurate information, mixing up photos on the sticker, or confirming the validity of data based on a wet stamp that was put there a month or 20 years ago. Consequently, requests for data clarification will also become a thing of the past.

The validity of the document, as well as data on deferrals or reservations, will be verified using a QR code. In fact, this is why Reserve+ will be the preferred option, even in situations where paper documents are present.

In light of the recent developments, it can be deduced that the government is expediting preparations for the implementation of an enterprise’s electronic office for military accounting.

The Government’s Action Programme stipulates that by 31 December 2025, an electronic office for enterprises must be created to keep personal records of conscripts, persons viable for military service and reservists.

Concurrently, employers are awaiting the introduction of a new service that will facilitate digital registration of persons liable for military service, eliminating the need for paper-based procedures.

The changes introduced are part of the process of developing a modern and transparent military registration system that meets the needs of the defence sector and contributes to improving the efficiency of defence processes in Ukraine.

• Changes to the regulations for determining critically important enterprises

The government has clarified the regulations for determining critical enterprises and changed the requirements for the content of decisions on the basis of which "critical" status is granted. From now on, when documents are submitted and decisions are being made, the number of conscripts subject to reservation will be taken into account.

The government has recently updated the Criteria and Procedure for Determining Enterprises, Institutions and Organisations that are Critically Important for the Functioning of the Economy and Ensuring the Livelihood of the Population during a Special Period. This update was approved by Resolution of the Cabinet of Ministers of Ukraine No. 76 dated 27.01.2023 (hereinafter — the Criteria and Procedure). The changes were made by Resolution of the Cabinet of Ministers of Ukraine No. 1608 dated 08.12.2025, which has already entered into force (09.12.2025).

Accordingly, the Criteria and Procedure have been supplemented with a list of information that must be submitted and included in decisions on determining the criticality of an enterprise:

1. Additional information in the package of documents (p. 5 of the Criteria and Procedure) — new mandatory information is added to the list of supporting documents: the total number of employees subject to military service of the enterprise, institution or organisation. As there is no form approved by the procedure, this may be a certificate in any on the enterprise’s paper form. However, certain ministries require that the certificate be prepared according to their template.

2. New requirements for the content of the criticality decision (p. 6 of the Criteria and Procedure):

2.1 The requirement to indicate the taxpayer’s tax number has been removed from the text of the decision.
2.2 The decision must now contain additional information on the number of persons liable for military service subject to reservation for:
-    enterprises, institutions and organisations where all employees liable for military service are reserved;
-    heat and power enterprises, water utilities, hot water supply and wastewater disposal operators, as well as waste management enterprises.

3. The requirements for annual reporting have been expanded (p. 13 of the Criteria and Procedure). Another parameter has been added to this paragraph: the number of conscripts subject to reservation, which defines the information taken into account when confirming criticality for the next period.         

 

• In addition to the above innovations, there are also changes regarding compliance with the reservation quota 

As of today, the responsibility for ensuring that the number of conscripts reserved does not exceed the established limits lies with the managers of critically important enterprises. Exceeding the limit will automatically cancel the deferral and may result in the enterprise losing its critically important status.

Resolution of the Cabinet of Ministers of Ukraine No. 76 dated 27.01.2023 has been supplemented with a new paragraph 9-2, according to which:

Management of critically important enterprises and institutions is required to take measures to prevent the limits set out in paragraphs 8 and 9 of the Procedure from being exceeded with regard to the number of persons liable for military service to be reserved.

This means that the responsibility for complying with the reservation limits lies with the management. They must constantly monitor the number of reserved employees and its compliance with the established limits.

Important! Compliance with the limit must now be maintained continuously throughout the period of validity of the criticality decision. 

Previously, compliance with the limits was mandatory, but there were no specific rules or procedures for exceeding the limit. Now, however, there are.

No deadlines or transition period have been set for bringing the number of reserved employees into line with the law, so the rule is already in force. Management of critical enterprises must therefore take measures to ensure that the limits on reserved employees are not exceeded.

Furthermore, paragraph 31 of Resolution No. 76 on the cancellation of deferrals has been supplemented by subparagraph 15. As outlined in this subparagraph, the deferral will be cancelled if the head of a state authority, other state body, local government body, critical enterprise or critical institution makes a justified request, in the event that the limits set by paragraphs 8 and 9 of this Procedure regarding the number of conscripts subject to reservation are exceeded.

That is, if an enterprise exceeds the limit, the following will apply:

1. Cancellation of “excess” reservations for employees will be required in accordance with paragraph 31 of Resolution No. 76;
2. Failure to comply with this directive could result in the revocation of the criticality status.

Another option for employers is to hire new employees liable for military service in order to increase the number of employees used to calculate the limit.

Employers with a 100% reservation limit will not have to worry about this issue.

• Conclusions

The changes introduced demonstrate the Ukrainian government’s commitment to modernising and digitising military registration processes, as well as ensuring the continuity of production processes at strategically important enterprises. The temporary simplification of reservation procedures, the transition to electronic military registration documents, and the clarification of the criteria for determining critically important enterprises create conditions for more effective management of human resources during mobilisation. At the same time, employers should closely monitor compliance with the new requirements and limits to avoid the risk of losing the status of a critically important enterprise and to ensure compliance with current defence policy standards.

For more information on other key changes in military registration that happened in 2025, please refer to our article “Military Registration in 2025: What’s New”. 

BDO in Ukraine specialists have identified that the primary risks are concentrated around reservation limits and confirmation of criticality. We provide comprehensive support with regard to military accounting and the acquisition of critical status. Our services are designed to minimise the risks and ensure continuity of your business.