Head of Medical Law Practice
Specializes in medical, corporate, and migration law. Has extensive experience working with medical and pharmaceutical businesses, particularly in licensing, circulation of medicines, and comprehensive legal support of healthcare institutions, including corporate, tax, and employment matters, as well as market entry projects of foreign companies into Ukraine.
Military registration in medical institutions in 2026: how to prepare for the TCC inspection?
Table of Contents:
- Why are medical institutions at risk?
- What requirements do the CCC and the SP impose on medical institutions during inspections?
- What is checked during inspections?
- Stages that should be put in order now in a medical facility
- Legal support for military accounting medical clinics: how to minimize risks?
In 2026, military registration has become a zone of increased control by the state. This especially applies to healthcare institutions, because they work with a category of employees, almost all of whom are subject to military service.
It is important to clearly understand that all legal entities that employ military service employees are required to maintain military registration. This category includes:
- doctors,
- nurses,
- pharmacists,
- rehabilitation specialists,
- laboratory technicians,
- and other medical workers.
That is, in fact, every private clinic, medical center, dentistry or laboratory automatically falls under these requirements.
- how to keep military records in a medical institution
- what documents are required
- terms for submitting information to the TCC
- the responsibility of the head of the medical institution and the person responsible for military records.
For the medical business, this means one thing: military records are part of the compliance of a medical institution, just like a license, NHSU or medical documentation.
Why are medical institutions at risk?
In practice, most clinics allow systemic violations:
- they accept doctors without military registration documents
- they do not notify the CCC of their acceptance or dismissal
- they do not maintain up-to-date lists of personnel
- they do not appoint a responsible person
The result is fines from 34,000 to 59,500 UAH and increased attention from regulatory authorities. But financial sanctions are not the only problem. During inspections or searches, military registration often becomes a “weak point” through which other violations are discovered.
What requirements do the CCC and the SP impose on medical institutions during inspections?
To avoid risks, the head of the medical business needs to keep the following points under control:
Recruitment only with military documents
Such documents are:
- military card or temporary certificate
- electronic VOD (extract from Reserve+)
- prescribed for conscripts.
Appointment of a person responsible for military registration in the MC
Each medical institution must issue an order from the medical institution on the appointment of a person who is responsible for military registration in the medical center and send a corresponding notification to the CCC (term of 7 days)
It is this person who ensures the fulfillment of all requirements for registration in the MH of those liable for military service and is responsible during the verification of the CCC and SP.
Maintaining personal military records
A medical institution must form lists of employees by category, update them with any changes and maintain internal records. This is also important for the medical business because the staff changes often.
Regular communication with the TCC
The responsible person is obliged to transmit information about the acceptance/discharge/change of data of military personnel to the medical institution. The deadline for such notification is up to 7 days. And it is this point that is most often violated by clinics.
Annual data reconciliation
Medical institutions must reconcile internal data, submit information to the CCC, prepare extracts and copies of documents. This is a regular process, not a one-time action. The mistake of most clinic owners is to delegate this issue “to the personnel officer” and not control it.
In reality: military accounting is the area of responsibility of the manager and part of the legal security of the medical business. It is he who signs orders, is responsible for the accounting system and bears the risk of fines.
What is checked during inspections?
During inspections by the TCC or other bodies, they analyze:
- the availability of military registration documents
- the correctness of list maintenance
- the timeliness of notifications
- internal orders
- the actual correspondence of data
And if the system is not built, it is immediately visible.
Stages that should be put in order now in a medical facility
In practice, most medical centers keep military records in a fragmented manner - until the first inspection. To avoid this, it is important to build the system correctly from the very beginning.
What needs to be done:
- The first step is a management decision. The head of the medical facility must officially appoint a person responsible for maintaining military records and confirm this by order. It is this person who becomes the point of control and responsibility before the CCC.
- Next are the deadlines that are often ignored. The CCC must be notified within 7 days of the appointment. Violation of this obligation is one of the most common grounds for fines.
- The next block is the visible part of compliance. The facility must have up-to-date regulatory documents, including the Military Records Rules. This is the first thing that is checked during the visit.
- An important stage is the formation of military records lists. Employees must be systematically divided into categories, and the information must be up-to-date and synchronized with their military registration documents. This is where most errors occur in medical institutions.
In parallel, it is necessary to keep operational accounting information - this is a database that reflects the real state of personnel from the point of view of military accounting.
And the most risky moment is personnel changes. Each acceptance or dismissal of a military employee must be accompanied by a notification to the CCC within 7 days. Ignoring this obligation is a direct path to fines.
Legal support for military accounting medical clinics: how to minimize risks?
In practice, the most effective solution is not to “fix mistakes”, but to immediately build the right system.
Legal support allows you to:
- conduct an audit of military accounting in a clinic
- identify risks before the inspection
- correctly draw up documents
- build processes in accordance with legal requirements
- protect the manager from fines
Contact us if you need
- to check whether military accounting is being conducted correctly
- to prepare turnkey documents
- or to protect the clinic during inspections by the CCC and SP
We work with the medical business systematically and know exactly where risks arise that are not visible from the inside.
Calculate the price of assistance:
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How and when should the annual reconciliation of TCC lists be carried out?
The timing and frequency of reconciliation are not defined, so you agree on the reconciliation date yourself, but reconciliation of these lists with the VOD data must precede the annual reconciliation with the TCC.
What are the requirements for advanced training for the person responsible for military registration?
The responsible person of a medical institution must be promoted once every 5 years.
What documents and orders should be issued each year for the proper organization of military registration?
By February 1, an order on the status of military registration for the previous year and tasks for the next year.
Should managers approve these military registration rules?
No, they shouldn’t, because they’ve already been approved by Cabinet of Ministers Resolution No. 1487. Oversight of businesses is tightening every year. And medical institutions are among the first to be inspected. The reason is simple: the large number of military personnel and their social importance.
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