In accordance with clause 7 of the article 8 of the Federal Law dated 28.03.1998 No. 53-FZ “On Military Duty and Military Service,” all organizations in the Russian Federation are required to maintain military registration of their employees.
Please note that starting from 01.10.2023, penalties for violations related to military registration have been significantly increased (Federal Law dated 31.07.2023 No. 404-FZ).
A penalty can be imposed on both a legal entity and an official (for more details, see below).
How to start military registration?
Military registration is a set of actions that allows an organization to collect data on conscripts and employees subject to conscription and report to military commissariats.
An organization that has not previously maintained military registration must be registered with the military commissariat at its location. If it has, for example, branches, then there is no need to register the organization with the military commissariat in every city wh ere it has a branch.
Before submitting documents to the military commissariat, it is recommended to contact the territorial (district) administration at the location of the organization for registration and assignment of an organization number for military registration.
Who is responsible for maintaining military registration?
Responsibility for maintaining military records is carried by the head of the organization, as well as the employee or several employees who are assigned to this work. They are required to prepare documents for registering those subject to conscription and carry out planned work to prepare employees for mobilization when necessary.
With consideration to clause 12 of the Regulations on military registration, approved by Decree of the Government of the Russian Federation dated 27.11.2006 No. 719, the number of persons responsible depends on how many employees of the organization are registered with the military commissariat.
Who controls maintaining military registration?
Maintaining military registration is controlled by the governing authorities of the Armed Forces of the Russian Federation, military commissariats of the constituent entities of the Russian Federation, military commissariats of municipalities and local government authorities (clause 33 of the Regulations on military registration, approved by Decree of the Government of the Russian Federation dated 27.11.2006 No. 719, clauses 55 – 57 of the Instruction on organization of work to ensure the functioning of the military registration system, approved by Order of Minister of Defense of the Russian Federation dated 22.11.2021 No. 700).
If an organization has more than 500 employees, the inspection will be annual. If 500 or less, at least once every three years.
Responsibility for violation of military registration obligations
From 01.10.2023 the punishment for those employers who do not fulfill their military registration obligations has been significantly tightened.
Thus, article 21.1 of the Code of the Russian Federation on Administrative Offenses provides that failure to submit to the military commissariat (another authority carrying out military registration) within the prescribed period the lists of citizens subject to initial military registration entails the imposition of an administrative penalty:
Failure to submit or untimely submission by officials of organizations in the manner established by federal law of information necessary for maintaining military registration shall entail the imposition on such officials of an administrative penalty in the amount of 40.000 to 50.000 rubles (article 21.4 of the Code of the Russian Federation on Administrative Offenses).
In addition, the employer faces liability in the form of an administrative penalty under article 21.2 of the Code of the Russian Federation on Administrative Offenses, if the employer does not notify the employee of the call (conscription notice) from the military commissariat (another authority carrying out military registration) upon receipt, including in electronic form, of such a call (conscription notice), or does not provide the employee with the opportunity to appear on such a call (conscription notice) in a timely manner:
When failing to provide timely notification and appearance of citizens subject to conscription for military service for mobilization, to assembly stations or military bases, not providing assistance in organizing such notification and attendance, the penalty will be (part 1 of the article 19.38 of the Code of the Russian Federation on Administrative Offenses):
Limitation period for bringing to administrative responsibility (part 1 of the article 4.5 of the Code of the Russian Federation on Administrative Offenses):
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