Military record obligations

29.09.2023
Due to the recent changes in the legislation on the registration of military eligible people and in the Code of Administrative Offences of the Russian Federation, employers are imposed some obligations to continue the registration formalities in the companies of the employees who are eligible for military service.

1. Fundamental changes

The main changes introduced into the Procedure for registration of military eligible people by Government Decree of the RF No. 1211 of July 25, 2023 (initially approved by Government Decree No. 719 of November 27, 2006) which came into force on August 5, 2023 are presented below:

  1. The identification card of a person subject to military service (military card) can now be issued in the form of an electronic document – a plastic card with a chip;
  2. Deadlines for employers to fulfill their obligations to provide information to district military authorities have been clarified or shortened as follows:
    • 5 working days (previously no deadline was set for this) - for the provision of information (1) on corrections, inaccuracies and falsifications discovered in military registration documents, on incomplete number of pages and (2) on cases in which citizens fail to fulfill their duties in the field of military registration (listed in Article 21.5 of the Code of Administrative Offenses), have not complied with mobilization preparation and mobilization;
    • 5 days (previously – 2 weeks) – regarding information on hiring or dismissal of military eligible people (also possible in electronic form via the state and municipal services portal);
    • within 5 days (previously – 2 weeks) – in the event of changes to information on marital status, education, structural unit in the organization, position, residence or place of stay, as well as health status of employees registered for military service.
  3. The law abolishes the obligation to submit lists of male citizens aged 15 to 16 years to the responsible district military authorities every September, as well as the obligation to submit by November 1st lists of male citizens who are subject to initial military registration in the following year;
  4. It was separately clarified that the district military authorities can issue employers call up papers for their employees both in paper and in electronic form. At the same time, employers can exchange information with district military authorities via the portal for state and municipal services, provided that the documents are signed with the extended qualified electronic signature of the employee responsible for internal military registration.

2. Tightening of liability measures for violations of military registration

From October 1, 2023, penalties for violations of the provisions of the military registration legislation will be significantly increased.

According to the Code of Administrative Offenses, fines currently amount to a maximum of 5,000 rubles for failure to submit information about persons subject to military registration who have been hired or dismissed or 3,000 rubles for failure to notify of call up papers issued by the district military office and for failure to transmit to the district military office lists of employees who are the subject to initial conscription registration.

The information on new fine amounts is summarized in the table below:

Type of violation
Fine amount 
Mobilization support obligations  
Failure to ensure timely notification or appearance at assembly points or military units of persons subject to mobilization, or failure to provide necessary assistance in relation to such notification or appearance 
  • For management – from 60 thousand to 80 thousand rubles;
  • For organizations – from 400 thousand to 500 thousand rubles.
Failure to notify employees upon receipt of call up papers from the district military authority or failure to ensure employees the possibility to timely visit the military authority in accordance with such call up papers. 
  • For management – from 40 thousand to 50 thousand rubles;
  • For organizations – from 350 thousand to 400 thousand rubles. 
Military eligible people registration    Failure to submit lists of employees who are subject to initial registration as military eligible people to the district military office on time 
  • For management – from 40 thousand to 50 thousand rubles;
  • For organizations – from 350 thousand to 400 thousand rubles. 
Failure to submit or non-timely submission of information necessary for the registration of military eligible people (e.g. about their hiring)  For management – from 40 thousand to 50 thousand rubles. 

The limitation periods for administrative liability are (Art. 4.5 Part 1 OWiG RF):
  • 60 calendar days – if case of failure to support the district military offices in their mobilization activities in the event of mobilization;
  • 3 years – for violations related to the military eligible people registration.

3. Main steps for implementing the military eligible people’ registration

Companies that have not yet recorded military eligible people internally are advised to consider complying with their legal obligations, given the high fines that will apply from October 1, 2023 in case of violations.


  Main steps
Comments 
1.
Appointment of a person responsible for the military eligible people’ registration  Responsible person shall be appointed by an order from the head of the organization. The form of the order must be approved with the district military office. The responsible person must complete an appropriate training before being appointed.
If the organization has fewer than 500 employees, one of the employees can be appointed to this position on a part-time basis (internally or externally). 
2.
Development and approval of necessary internal guidelines  Mandatory documents for registering military eligible people include:
  • Regulation on military eligible people’ registration;
  • Order on the organization of military eligible people’ registration;
  • Work plan for the internal registration of military eligible people and reservists;
  • Cards of employees subject to military service;
  • File of cards of employees subject to military service. 
3.
Identification of employees subject to military service  Analysis shall be made taking into account the legal criteria – list of employees who are not subject to military service in accordance with clause 15 of the Procedure for registering military eligible people. 
4.
Obtaining information from employees subject to military service  Military cards, marital status, state of health, qualifications or education, etc. 
5.
Sending data on employees subject to military service to district military authorities  The responsible employee shall transmit information about persons subject to military service to the district military office for the first time (when recruiting them or if this data was not previously transmitted), when employees are dismissed and in the event of changes in the status/documents of persons subject to military service (e.g. change in the name, marriage, divorce, study or education). 
6.
Conducting regular data audits on employees subject to military service  The information in the documents of those subject to military service shall be reviewed to ensure that it complies with the information in the military record cards at least once a year. 

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Legal department of
SCHNEIDER GROUP St. Petersburg