Penalty for military registration after July 17: when you can avoid paying
22 July 2025 14:52
The lawyers told the conscripts the good news that starting from July 17, the military registration and enlistment offices would no longer be able to hold them administratively liable for late registration, failure to update their data, etc. In general, they say, Ukrainians have misunderstood everything, and the fines are not going away. "Komersant Ukrainian" found out whether Ukrainians will be fined now
Legal channels have begun to spread the good news: starting from July 17, 2025, territorial recruitment and social support centers (TSC and SP) will lose the right to impose fines on conscripts who have not updated their credentials within the prescribed time frame. According to the Law of Ukraine No. 3633-IX “On Amendments to Certain Legislative Acts of Ukraine on Certain Issues of Military Service, Mobilization and Military Registration”, which came into force on 18 May 2024, all persons liable for military service had 60 days – until 16 July 2024 inclusive – to update their personal data. Violation of this obligation was punishable by administrative fines ranging from UAH 17,000 to UAH 25,500.
By the way, TCCs were actively using this. Since the beginning of 2025, more than 28,000 proceedings have been opened for violating the rules of military registration. Every month, the CCC issued an average of 4.7 thousand new fines. In the first half of 2024, 11,798 fines for registration violations were transferred to the executive service for enforcement, according to Opendatabot. In 2023, there were 10,337 such enforcement actions.
However, according to lawyers, according to Article 38 of the Code of Ukraine on Administrative Offenses (CAO), an administrative penalty for such violations can be imposed only within three months from the date of their detection, but not later than one year from the date of commission. That is, on July 17, 2025, a year will have passed since the deadline for updating the data, and the TCC will lose the legal grounds to bring to justice for this violation. If after this date the transfer pricing company issues a resolution on a fine for late data update, it can (and should) be challenged in court, referring to the expiration of the liability period under Article 38 of the Code of Administrative Offenses.
The fine is still unavoidable
However, according to other lawyers, it is premature to rejoice. As noted by attorney Roman Simutin, in most decisions of the SCC under Article 210 of the Code of Administrative Offenses, the actual part of the offense (the plot) does not mention that the person did not update personal data within 60 days. Usually, the resolutions state that when checking military registration documents, it was found that the person is not registered, or that there are no documents, or that the Oberig register contains outdated information.
“If on July 18 a citizen is stopped on the street by a notification group and it is found that he or she is not registered or there is no or outdated information in the Oberig register, July 18 will be the day the violation is detected. And from that moment on, the TCCs will have 3 months to bring a person to justice for violating the rules of military registration under Art. 210 of the Code of Administrative Offenses. And the expiration of the one-year term of liability for failure to specify data has nothing to do with it,” the lawyer emphasizes.
Thus, the TCC will indicate other violations in its resolutions – lack of records, lack of documents, untimely updating of information. And the period of prosecution (3 months) will start from the date of detection of the violation by the TCC employees or the police.
“The decision can be appealed only if the TCC explicitly states that the citizen did not update the data within 60 days – until July 16, 2024. But such cases are rare. Therefore, men who did not update their data by July 16 last year, are not registered or do not have documents, should not rely on the “one-year statute of limitations” – it will not save them,” Simutin summarizes.
A fine without a violation
The most interesting thing is that many persons liable for military service who are registered and even registered in the Reserve and Oberig apps have received a fine notice and an offer to pay half of it. Lawyers consider this to be a manipulation by the TCC: a fine cannot be imposed without an official resolution of the TCC under Article 210 of the Code of Administrative Offenses. It is the resolution that determines the decision and the amount of the fine. Without a resolution, there is no fine.
At the same time, the Oberig application has automatic algorithms: if the data is updated after 07/16/24, the system automatically sends a message with a proposal to pay half the fine. But this message is not a resolution.
“If there was a resolution, no one would have offered to apply to the TCC with a plea and pay 50% of the fine. If no plea is filed, the TCC has no grounds to issue a resolution. Therefore, not all notifications should be trusted and you should not rush to pay the fine – it is actually an admission of guilt,” the lawyer explains.
Author: Alla Dunina
