Under current Ukrainian legislation, the obligation to maintain military registration applies exclusively to employees of enterprises, institutions, and organizations. This is clearly stated in paragraph 5 of Article 34 of the Law of Ukraine “On Military Duty and Military Service” (No. 2232-XII, dated March 25, 1992). Specifically, personal military registration of conscripts, persons liable for military duty, and reservists is conducted at their place of employment.

The Procedure for Organizing and Maintaining Military Registration, approved by the Cabinet of Ministers of Ukraine Resolution No. 1487 (dated December 30, 2022), confirms that registration applies to individuals in an employment relationship. Paragraph 14 of the Procedure states that military registration is organized and maintained by government bodies and enterprises where these individuals are employed or study.

In contrast, individuals performing work or providing services under civil law agreements (e.g., contracts for work or services) are not considered “employees” under the Labor Code of Ukraine. Their relationship with the company is governed by the Civil Code of Ukraine and has a different legal nature. They do not fall under the definition of an “employee” and are not included in the company’s staff roster.

Additionally, paragraph 46 of the Procedure explicitly states that the reconciliation of personal military registration lists is carried out for persons who are employed or studying, not for individuals collaborating on the basis of civil law agreements.

Therefore, the obligation to organize and maintain military registration does not extend to contractors under civil law agreements. This means a company should not require military registration documents from such individuals or include them in internal military registration lists.

Conclusion: The legally correct approach is to maintain military registration only for employees hired under employment contracts. Including individuals who perform work or services under civil law agreements in the registration process is not provided for and is not required by current legislation.