Employing people in Ukraine under martial law: military registration, reservation and mobilised employees

Rules checked on 14 September 2026. Martial law changes often — each section says where to check the current version.

If you employ people in Ukraine, martial law adds duties that do not exist anywhere else in Europe: keeping military registration records, answering to territorial recruitment centres, deciding whether key staff can be reserved from mobilisation, and handling employees who are called up. This briefing explains what applies today and what to put in place.

1. Martial law is extended in 90-day steps

Martial law and general mobilisation have been in force since February 2022. Parliament extends both for 90 days at a time; the current period runs to 31 October 2026, and a further vote is expected before it ends. As long as martial law applies, the special labour rules of Law No. 2136-IX apply as well.

Check the current end date: rnbo.gov.ua and zakon.rada.gov.ua.

2. Military registration is an employer duty

Every employer in Ukraine that employs people liable for military service, conscripts or reservists must keep military registration records — whatever its ownership, foreign subsidiaries included. In practice this concerns above all the men of mobilisation age on your staff. The procedure is set by Cabinet Resolution No. 1487 of 30 December 2022.

What it means for you:

Duty	Deadline
Check the employee's military registration document	At hiring — an electronic document from Reserve+ or Diia is accepted
Notify the territorial recruitment centre (TCC) of a hiring, a dismissal or a change in an employee's registration data	Within 7 days
Employees report changes in their own registration data that cannot be taken from state registers	Within 7 days of the change
Reconcile your records with the TCC	At least once a year, on the schedule agreed with the TCC
Keep a current register of employees liable for service, with the details of their documents	Ongoing

You also name a responsible person for military registration, and pass on summonses to employees when instructed.

What changed in 2026: Resolution No. 812 of 10 June 2026, in force since 27 June 2026, started moving these procedures online. Reconciliation and data updates are shifting to the Diia portal and the state register of persons liable for service (Oberig). Paper records have not disappeared, and employers do not yet have direct access to the register.

Fines: breaches of registration rules fall under Article 210 of the Code of Administrative Offences, breaches of mobilisation law under Article 210-1. During martial law — a “special period” — the fines are:

	Individuals liable for service	Officials of a company
Special period (martial law)	UAH 17,000–25,500	UAH 34,000–59,500

Fines are imposed on the company's head or the person responsible for registration, not on the company itself. A fine must be properly established: courts have cancelled penalties where the recruitment centre could not prove, for example, that a summons was actually served. A missed deadline is therefore not automatically a fine — but keep proof of every notification you send.

What this means for hiring. In our experience, military registration through the employer is the main reason many male specialists of mobilisation age prefer to work as individual entrepreneurs (FOP) rather than as employees. That preference does not change the legal test: if the relationship is employment in substance, it can be reclassified — see our briefing on your first employees in Ukraine.

Check the current rules: Resolution No. 1487, Code of Administrative Offences.

3. Reservation: keeping key staff from being mobilised

Only a company that holds critical enterprise status — or falls into a defence category — can apply to reserve a share of its employees who are liable for service. A reserved employee is not called up for as long as the reservation lasts. The rules are in Cabinet Resolution No. 76 of 27 January 2023, the most frequently amended document in this area.

To be recognised as critical, a company must meet the mandatory conditions and at least one more:

• Always required: an average gross salary of its insured employees for the previous calendar month of at least three times the minimum wage — two and a half times for enterprises located and actually operating in areas of possible or active hostilities — and no tax arrears.
• Plus at least one of:

Additional criterion	Test
Taxes and contributions	More than the equivalent of EUR 1.5 million in the reporting year, customs payments excluded
Foreign-currency earnings	More than the equivalent of EUR 32 million a year, loans and borrowings excluded
Strategic importance	Included in the state list of strategically important enterprises
Sector criteria	Meets the criteria set by the ministry responsible for the company's sector
Regional criteria	Meets the criteria set by the regional military administration
Diia City	Resident of the Diia City regime

Sector criteria are not one universal test: each ministry sets its own, and they must match the company's real main activity. Presenting the business under a convenient but unrelated sector is a risk.

How it works: the company applies through the Diia portal with its qualified electronic signature. Reservation is granted for up to 12 months, and usually for up to half of the employees liable for service; higher shares apply in specific cases such as defence production and areas near combat. Each reserved employee must be properly registered, with current data, and not be sought by the recruitment centre. Since 1 September 2026, each reserved employee's own monthly gross salary must also be at least three times the minimum wage (two and a half times in areas of hostilities). If a company exceeds its quota, it has ten working days to apply through Diia to cancel the excess reservations. Reservation ends automatically when the company loses critical status, when the employee leaves, or when the employee's salary falls below the threshold.

Reservation does not cancel an employee's registration duties: a recruitment centre may still ask a reserved employee to appear to clarify data.

Who can reserve whom. Reservation is tied to the legal employer, not to the project someone works on:

Arrangement	Who can reserve the person	Condition
Employed directly by your company	Your company	Your company holds critical status
Employed by an employer of record	Only the employer of record	The employer of record itself holds critical status
Individual entrepreneur (FOP) on a service contract	Nobody through your company	Employer reservation does not apply to contractors

We found no rule that excludes foreign-owned companies.

What changed in 2026:

• 2 June 2026: Resolution No. 692 of 30 May 2026 came into force. It raised the company's average-salary criterion to three times the minimum wage, introduced the ten-day deadline for cancelling reservations above the quota, and required ministries to re-approve their sector criteria by 10 June 2026.
• 3 July 2026: employees with a deferral on other grounds, and employees who also work part-time at another critical enterprise, count towards the reservation quota at one workplace only — the one where they have been employed longest.
• 10 August 2026: deadline for companies to keep an existing critical-status decision by filing an average-salary certificate and their latest tax report (Resolution No. 862 of 1 July 2026).
• 1 September 2026: the three-times minimum applies to the salary of each reserved employee; existing critical-status decisions that were not re-examined lapsed by this date at the latest.

What to do: after every amendment, check that your average salary and each reserved employee's salary still clear the thresholds and that your status has not lapsed — a lapse cancels all reservations at once.

Check the current criteria and thresholds: Resolution No. 76, Resolution No. 692, Diia reservation services.

4. When an employee is mobilised

An employee who is mobilised keeps their job and position until martial law ends or until they are discharged from service (Labour Code, Article 119). Since July 2022 the employer no longer has to keep paying average earnings during service; teachers and academic staff are an exception. The job guarantee is lost only after a final court conviction for a military offence.

Check the current rules: Labour Code.

5. Other martial-law labour rules to know

• Suspending an employment contract is possible only when the employer cannot provide work and the employee cannot do it; the war alone is not a reason, as the Supreme Court confirmed in January 2026. During suspension the employer pays nothing. Since 14 March 2026 a suspension imposed by one side is limited to 90 days in total; anything longer needs both parties' agreement. An unlawful suspension can end in back pay for the whole period.
• Annual leave: under martial law an employer may limit annual leave to 24 calendar days. On 19 May 2026 the Constitutional Court ruled that this limit is unconstitutional as far as it denies minors and people with disabilities their longer paid leave (decision No. 3-р/2026); for them the full statutory leave applies again.
• Dismissal during an employee's vacation or sick leave is permitted under martial law, except during maternity or childcare leave.

Check the current rules: Law No. 2136-IX.

6. Business trips abroad

Men aged 23 to 60 may not leave Ukraine during martial law unless an exception applies; men aged 18 to 22 may. A reserved employee of a critical company can travel abroad on a genuine business trip, but the reservation is not an automatic right to cross the border — the State Border Guard Service decides on the documents, case by case.

Prepare a complete package:

• a valid passport for travel abroad;
• the current military registration document, with its verifiable electronic status;
• evidence of an active reservation;
• evidence that the employer currently holds critical status;
• a business-trip order naming the destination country, the dates, the counterparty or event, the purpose and the employee;
• the documents behind the purpose: invitation, contract, meeting agenda, trade-fair registration or client correspondence.

Issue the order before departure, make sure all dates match, avoid vague purposes such as “meetings in the EU”, and record the employee's return. Do not book non-refundable travel on the assumption that the exit will be allowed.

Check the current rules: Border Crossing Rules, Resolution No. 57, dpsu.gov.ua.

A checklist for foreign employers

1. Name the person responsible for military registration and give them access to Diia.
2. Check the registration document of every employee liable for service at hiring, and notify the TCC within seven days of every hiring, dismissal and data change — keeping proof.
3. Put the annual reconciliation with the TCC in your compliance calendar.
4. If you rely on reserved staff, re-check critical status, both salary thresholds and your quota after every amendment to Resolution No. 76 — and remember that only the legal employer can reserve.
5. Document every contract suspension: both conditions, the dates, and the 90-day limit.
6. Plan business travel for male employees with a complete document package.

How ClarusApex can help

For the people APEX AV LLC employs, we carry out the military registration of male employees of mobilisation age at hiring, keep their registration records and send the notifications to the recruitment centres. If your plans depend on reserving staff from mobilisation, remember that only the legal employer can reserve, and only with critical status — talk to us about the current position before you plan on it. For companies with their own Ukrainian entity we check registration records and critical-status documents and set up the compliance calendar. Marina Korytnyuk, our HR Director, answers questions on your situation within one business day.

This briefing is general information, not legal advice for your case.