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Is Military Registration Required for Contractors on Civil Law Agreements in Ukraine?

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.

Benefits for Veterans and Families of Fallen Service Members in Ukraine: Key Rights and Guarantees

The Law of Ukraine “On the Status of War Veterans, Guarantees of Their Social Protection” (No. 3551-XII, dated October 22, 1993) defines a system of social and labor rights for war veterans, persons with disabilities resulting from war, families of fallen military personnel, and individuals with special merits to the state. These provisions are aimed at supporting those who defended Ukraine and their loved ones.

War Veterans:

  • Have a preferential right to retain their job during downsizing or reorganization, as well as the right to priority employment if the employer is liquidated.
  • Receive temporary disability benefits at 100% of their average salary, regardless of their length of service.
  • Are entitled to take their annual leave at a time convenient for them.
  • Receive an additional paid leave of 14 calendar days.

Persons with Disabilities Resulting from War have similar rights, including the preferential right to job retention, priority employment, and enhanced social guarantees. Disability benefits can be paid for up to 4 consecutive months or up to 5 months within a year. They are also entitled to annual leave at a convenient time and an additional 14 days of paid leave.

Family Members of Fallen Service Members have the right to job retention, receive 100% temporary disability benefits, take annual leave at a convenient time, and are entitled to an additional unpaid leave of up to two weeks.

Individuals with Special Merits to the State have a preferential right to employment and job retention during downsizing, paid annual leave, and an additional unpaid leave of up to three weeks.

Recommendations for Employers:
● Consider the status of a veteran or a family member of a fallen service member when making HR decisions, especially during layoffs.
● Provide an individual approach to organizing working hours, conditions, and vacation schedules.
● Educate managers and HR specialists on the current guarantees and rights of veterans.
● Consult with the employee in advance about their needs, including opportunities for rehabilitation or medical treatment.
● Foster a corporate culture that supports employees with veteran status, thereby increasing loyalty and motivation within the team.

Adherence to these guarantees is not only a legal requirement but also an important step toward building a socially responsible business.

Jobs Prohibited for Women in Ukraine: Legal Restrictions and Exceptions

According to Article 174 of the Labor Code of Ukraine, the employment of women in heavy labor and jobs with harmful or hazardous working conditions is prohibited. This ban also extends to underground work, except for non-physical tasks or roles related to sanitary and domestic services. Additionally, women are not permitted to lift and move objects exceeding established weight limits.

The maximum weight limits for lifting and moving loads by women are established by the Order of the Ministry of Health of Ukraine No. 241 dated December 10, 1993. When lifting and moving loads in combination with other types of work (no more than twice per hour), the maximum permissible weight is 10 kg. If the lifting is performed continuously throughout a work shift, the limit is 7 kg.

The total weight of a load that a woman can move within one hour must not exceed 350 kg when lifted from a working surface (e.g., a conveyor or table) and 175 kg when lifted from the floor. The total weight includes the mass of the container and packaging.

Maximum Weight Limits for Lifting and Moving Loads by Women

Condition Maximum Load Weight (kg)
Lifting and moving loads up to 2 times per hour (combined with other work) 10 kg
Lifting and moving loads continuously during a work shift 7 kg
Total weight moved per hour from a working surface (conveyor, table) 350 kg
Total weight moved per hour from the floor 175 kg
Note: The weight of the load includes the mass of the container and packaging.  

 

According to Article 175 of the Labor Code, women cannot be engaged in night work, except in cases where it is dictated by special production needs and permitted as a temporary measure.

During martial law, the legal regime has specific features. According to Article 9 of the Law of Ukraine “On the Organization of Labor Relations under Martial Law,” women (except for pregnant women and women with a child under one year of age) may be engaged in heavy labor, jobs with harmful or hazardous conditions, and underground work with their consent. However, Article 8 of the same law prohibits engaging pregnant women and women with a child under one year of age in night work without their consent.

Thus, the legislation provides a comprehensive system of restrictions to protect women’s health, but during martial law, certain exceptions apply, allowing their involvement in difficult working conditions only with their voluntary consent.

Overview of Draft Law No. 13380: Innovations in Ukraine’s Redundancy Procedure

On June 18, 2025, Draft Law No. 13380 was registered, proposing amendments to Article 49-2 of the Labor Code of Ukraine regarding the employee dismissal process. It is important to note that this bill has not yet entered into force and is currently under review.

The current version of Article 49-2 of the Labor Code requires employers to notify employees of their upcoming redundancy at least two months in advance. Simultaneously, the employer must offer the employee another available job within the same company that matches their profession or specialty. If no suitable vacancies are available, or if the employee declines the offer, they have the right to contact the state employment service or find a new job independently.

Bill No. 13380 proposes to add a provision allowing the two-month notice period to be shortened if the employee submits a written request to do so. However, even with a reduced notice period, the employer is not exempt from the obligation to offer the employee all vacant positions matching their qualifications from the date of the initial notice until the actual day of dismissal.

This innovation offers flexibility for employees who wish to terminate their employment sooner, for instance, if they have already found another job or due to personal circumstances. At the same time, it places an additional responsibility on the employer to ensure that all relevant vacancies are offered throughout the entire shortened notice period.

Practical advice for employers: If this bill is passed, it is advisable to update internal HR documentation and procedures in advance. Specifically, companies should develop an algorithm for promptly informing employees about available vacancies, create standard forms for written notifications, and establish a procedure for recording requests to shorten the notice period. This will help prevent disputes, increase process transparency, and reduce legal risks.

It is crucial to emphasize that Draft Law No. 13380 is still under consideration, and until it becomes law, the current legal norms remain in effect.

Interesting Facts
THE FASTEST RECRUITMENT PROJECT

Just 3 calls, 2 candidates — and an agreed start of work in 30 minutes.

30

Minutes

THE LARGEST OUTPLACEMENT PROJECT

120 specialists received support after being laid off.

120

Specialists

THE LARGEST OUTSTAFFING PROJECT

3,700 specialists in Ukraine worked on the solar power plants project.

3,700

Specialists

THE LONGEST CUSTOMER COOPERATION

The contract has been in place for 21 year and is still active.

21

Year

RECRUITMENT TEAM BEFORE THE CRISIS

25 recruiters were closing up to 600 applications per year.

600

Applications/year

WOMEN'S TEAM

95% of the Ukrainian team are female.

95%

Women

CUSTOMER RETURNS

Customers who chose cheaper competitors return in 1–2 years.

1–2

Years

NO CUSTOMER LOSS DUE TO POOR QUALITY

In 25 years, not a single customer has been lost due to non-fulfillment of obligations.

0

Customer Losses

OUTSTAFFING MARKET CONCENTRATION

14 companies serve 95% of the market, two of them serve half.

14

Main players

ON-GOING PROMOTION PROJECTS

150+ active outstaffing/outsourcing projects in Ukraine.

150+

Projects

RECRUITMENT CONTRACTS

More than 100 active contracts for recruitment services.

100+

Current contracts

HIGHEST DAILY RATE

An offshore drilling rig safety engineer earned the highest daily wage.

1,200,00

Pounds/day