Military registration in a company: setting up the work, passing the audit, dealing with fines

What is happening

In most companies military registration lands on an HR officer as an extra duty. No order appoints anyone, no work plan is approved, the record cards are filled in as best they can be, and nothing is reported to the enlistment office. Until an audit appears, it never feels urgent.

Then a request or a reconciliation notice arrives and the company's data turns out not to match the office's: someone left two years ago, someone has no registration entry, part of the staff was never recorded at all. Each breach carries its own fine, and both the company and the responsible officer are penalised.

A separate task is the director who cannot see the scope of the duty. You need to know who keeps the records, which documents are mandatory, what must be reported to the enlistment office on hiring and dismissal and within what time, and which details you may ask an employee for and which you may not.

What the law says

• The duty to keep military registration records for employees rests on the company under the law on military duty and military service (Federal Law 53-FZ), regardless of headcount.
• The person responsible is appointed by an order of the director. The volume of work and the number of responsible officers depend on how many employees are on the register.
• The company must report to the enlistment office the hiring and dismissal of employees on the register, and changes in their details, within the time limits set by Article 8 of Federal Law No. 53-FZ on Military Duty and Military Service and the Regulation on Military Registration (Government Resolution No. 719 of 27 November 2006).
• The mandatory minimum is the appointment order, the work plan, employee record cards, and the log of audits and reconciliations.
• Breaches carry administrative fines, imposed separately on the company and on the responsible officer, and separately for each episode.
• A ruling imposing a fine can be appealed within ten days of receiving a copy, to the higher authority or to a court.

What we do

• We audit your military registration function: the orders, the record cards and the correspondence with the enlistment office, finding the gaps before an inspection does.
• We draft a document set fitted to your company: the appointment order, the work plan, the procedure for record cards and the notification forms.
• We brief HR on the procedure for hiring, dismissal and changes of details, including the deadlines for reporting.
• We prepare the company for reconciliation and audit, putting the documents in order and taking part in dealings with the inspectors.
• We appeal rulings imposing fines on the company and on its officers, raising limitation periods and the absence of proof.
• We advise on the line between military registration and data protection: which employee details you may request and pass on.

What we need from you

• An extract from the companies register and figures on your headcount.
• The order appointing the person responsible for military registration and their job description, if they exist.
• The employee record cards and the staff list or establishment table.
• Correspondence with the enlistment office: requests, reconciliation notices and the reports you sent.
• The inspection report, the offence report and the ruling on the fine, if an audit has already taken place.
• HR documents on the employees in question: hiring and dismissal orders and copies of their military registration documents.