Author: Stanislav

Is a Military Medical Commission (MMC) required for reservation/re-reservation?
— No. The procedure for granting a deferment due to reservation does not require an MMC referral (CMU Resolution No. 560, para. 69). However, Law No. 3621-IX mandates that citizens aged 25-60 who were deemed “limitedly fit” before May 4, 2024, must undergo a repeat medical examination by June 5, 2025 (excluding persons with disabilities). Failure to comply can result in a “wanted” status in the Rezerv+ app, which technically blocks any new reservation.

Are employees with a valid reservation sent for an MMC?
— Usually, no. An MMC is not part of the conscription process while a deferment/reservation is active. However, TCCs may issue summons for an MMC in exceptional cases, such as if an employee’s previous MMC conclusion has expired or upon the individual’s own request.

Who initiates the MMC, and how long is the conclusion valid?
— The TCC initiates the process.
— An MMC conclusion issued during martial law is valid for 1 year.

How does the MMC practically affect reservation via the “Diia” portal?
— An MMC is not a prerequisite for submitting reservation lists through “Diia.”
— However, if an employee fails to update their data at the TCC’s request (including medical information), this can block the automatic transfer to special military registration when the reservation is processed in “Diia.”

Employee’s Obligations:
— Appear at the TCC when summoned to update personal data.
— Inform the TCC of any changes (health status, job, etc.) within 7 days.
— Comply with the validity periods of MMC decisions.

Key Takeaways:

1. An MMC is absolutely mandatory only for those with an outdated “limitedly fit” status.
2. A “Violation of military registration rules” or “Wanted” status in Rezerv+ (often due to an overdue MMC) makes reservation technically impossible until the issue is resolved by paying a fine and passing the MMC.
3. Individuals with no MMC data in Rezerv+ (e.g., not examined since 2022) may also be flagged as “wanted,” blocking their reservation.

Effective September 5, 2025, new rules for serving military summons have come into force in Ukraine: a registered letter from “Ukrposhta” or another official postal operator will now be considered official delivery. CMU Resolution No. 1062 formalizes the centralized printing of summonses, automatic data generation from state registers, and eliminates legal “gray areas” that previously allowed individuals to avoid receiving documents.

What Has Changed?

• Centralized Printing:Summonses can now be printed not only by TRCs (Territorial Recruitment Centers) but also by the Ministry of Defence and state-owned printing enterprises.
• Automated Data Generation:All data for summonses will be automatically generated from the Unified State Register of Conscripts, Persons Liable for Military Service, and Reservists, rather than from paper records.
• Official Postal Delivery:“Ukrposhta” (or another designated postal operator) is now an official channel for delivery. Summonses can be sent by registered mail, and this will be considered legally valid service, not just a supplementary method.

As explained by People’s Deputy Oleksandr Fedienko, the state register will now consolidate all relevant information from various other registers to automatically generate summonses. For example, the Ministry of Defence can generate a list of summonses from the register and, under a contract with “Ukrposhta,” mail them out en masse.

Previously, while summonses were also sent by registered mail, this was often challenged in court. Lawyers successfully argued that an individual had “not received” the letter (e.g., failed to pick it up from the post office, refused delivery).

The new resolution solidifies that delivery by registered mail is equivalent to official in-person service, closing these legal loopholes. This establishes a clear legislative mechanism that enables mass mailings and makes it virtually impossible to evade the service of a summons through the postal system.

Promotion has been providing personnel outstaffing services in Ukraine since 2003, managing over 150 ongoing projects and 4,000+ specialists throughout Ukraine, and is one of the largest companies in the outstaffing segment in Ukraine.

UAH 100,000,000.00+ – is the average monthly amount spent on payments to outstaffed specialists in Ukraine.

During this time (over 22 years), we have participated in hundreds of tenders, primarily conducted by international companies and their professional representatives—procurement specialists, HR managers, and others. We have successfully transitioned over 2,000 employees to our services as part of won tenders.

We have compiled a list of key questions that, in our opinion, will help you conduct a thorough market analysis to select the best outstaffing service provider according to your company’s needs.

1. A High-Quality and Comprehensive Statement of Work (SOW) is the Key to a Successful, Open, and Long-Term Professional Partnership

• A professional outstaffing provider will need minimal information to prepare a quality proposal.
• At the same time, the more details/forecasts the company provides, the more stable the provider’s offer will be (fixed for a year/years, without surprises in cost revisions, etc.).
• We recommend including the following parameters in the core components of the SOW:
  • Is the project new, or is it managed by a current partner?
  • Planned start date of cooperation.
  • Duration of cooperation.
  • For how long would the company like to fix the price proposal and payment terms?
  • What is the number of outstaffed personnel in the project, and can the company forecast an increase/decrease in this number?
  • What is the type of contract between the outstaffed specialists and the provider?
  • Main job positions of the personnel.
  • Is the involvement of personnel in high-risk work anticipated?
  • Requirements for the payroll project (bank).
  • Dates of main payments.
  • Are there additional benefits for personnel that will be managed by the provider (insurance, business trips, meals, mobile communication, car leasing, etc.)?
  • All metrics that can be calculated as of the tender/market analysis date, for example:
    • Number of personnel, plans for increase/decrease in headcount.
    • Average monthly budget for personnel maintenance (salary with taxes).
    • Average monthly budget for additional personnel benefits (insurance, mobile communication, etc.), UAH excluding VAT.
  • The company’s preferred payment procedure for the provider’s services: prepayment on main salary payment dates, 100% post-payment with one set of documents within 5, 15, 30, 45, 60, 75, 90, 120 calendar days from the Acceptance Act date, etc.

2. Key Information Companies Typically Request from Outstaffing Service Providers:

1) Basic Information about the Provider’s Legal Entity

• Company name (full/abbreviated)
• Date of state registration
• Company Registration Code (EDRPOU)
• VAT Payer Status
• Legal address of the company
• Actual address of the company
• Company website
• Full name and contact details of the company director
• Full name and contact details of the person responsible for submitting the proposal

2) Key Information on Company Performance (financials, HR and technical resources, etc.):

• Number of full-time employees directly involved in project support
• Number of outstaffed specialists managed over the last 3 years (by year)
• Revenue (excluding VAT) for the last 3 years (by year)
• Country of registration of the ultimate beneficial owner, and whether there are foreign legal/natural persons in the ownership structure
• List of related legal entities
• Main area of activity, and whether the company is engaged in other areas unrelated to its core business (e.g., trading, export-import activities), and if so, which ones

3) Quality Indicators, Expertise, and Practical Experience

• Years of experience in the relevant service area
• Experience in managing outstaffing projects with over 100 specialists
• Main outstaffing clients
• Contact details of 3-5 main clients for references (full name, position, year cooperation started, contact phone number)
• Electronic document management (yes/no, which tools are used)
• Additional information about the provider (expertise, advantages, other)
• Main competitors
• Competitive advantages
• Status as a critically important enterprise for the economy and population’s livelihood during a special period (related to the possibility of reserving personnel from mobilization)

4) Questions Related to Company Policies

• Sanctions, anti-corruption provisions, corporate requirements, etc.

During martial law, correctly managing labor relations with mobilized employees remains a critical issue. This is especially true when an employee is called to military service during their annual vacation.

Is the Unused Vacation Postponed?
According to Art. 11 of the Law of Ukraine “On Vacations,” annual leave is subject to postponement or extension if an employee performs state or public duties while retaining their average salary. However, following changes to labor legislation (effective July 19, 2022), employers are no longer required to retain the average salary for mobilized employees. Article 119 of the Labor Code only guarantees the retention of their job and position.

Therefore, if mobilization coincides with an annual vacation period, the unused vacation days are not postponed or extended. The paid vacation period is considered fully used.

Employer’s Documentation Procedure
1. Order: After receiving supporting documents, the employer issues an order to release the employee from work due to mobilization, effective from the first day after the vacation ends.
2. Timesheet: The vacation period is marked with the code “В” (Basic Leave) or “A” (Additional Leave). Starting from the day after the vacation ends, the days of service are recorded with the code “ІН” or the numerical code “22”.
3. Work Record Book: No entries regarding mobilization or release from work are made.

Payroll
Payments already made for the vacation period should not be reversed. Going forward, no salary is accrued, as it is not retained during military service.

If an employee is mobilized during their annual vacation, the employer must formalize their release from work starting the day after the vacation ends, reflect their absence in the timesheet with the appropriate codes, and ensure their job is retained. Postponement or extension of the unused part of the vacation is not provided for in this situation.