Audit of military registration

What is happening

The familiar picture: military registration was inherited by an HR officer, the documents were drawn up some years ago and never revisited, and part of the data has been updated from memory. On paper everything exists — nobody has tried testing it in substance.

A change of responsible employee or of chief executive is a reason for an audit in itself. Taking the function over blind carries risk: liability for earlier periods does not disappear, and it is hard to judge the state of affairs from the inside without knowing the criteria that will be applied.

A third situation is growth: the company has opened units in other regions or gone through a reorganisation, while registration is still configured for the former structure — the wrong commissariat, the wrong addresses, the wrong volume of work and the wrong set of documents.

What the law says

• The requirements for military registration in organisations follow from the law on military duty and military service (53-FZ) and from regulations prescribing the forms, the composition of the card index and the reporting deadlines.
• An inspection by a military commissariat follows set criteria: whether the appointment order and work plan exist and what they say, whether the card index is complete and correctly kept, whether information was reported on time, and the outcome of earlier reconciliations.
• For companies with mobilisation assignments and reservation from call-up, the requirements of the law on mobilisation preparation and mobilisation (31-FZ) apply as well, with separate reporting and a separate body of documents.
• Processing of employees' registration data is governed by Federal Law 152-FZ, and the audit covers that too: the basis for processing, the categories of data collected, how the card index is stored and who has access to it.
• The Code of Administrative Offences provides for administrative liability of the company and its chief executive for breaches in military registration; most of these are formal offences, established from the documents.
• Putting matters right voluntarily before an inspection does not undo past breaches, but it does bring the function into order and lets the company prepare its position in advance.

What we do

• We request and examine the military registration document set: orders, the work plan, instructions, registers, correspondence with the commissariat and the records of earlier reconciliations.
• We test the card index: whether all relevant employees are covered, whether the registration documents are correctly completed, whether the data matches the HR files, and how the index is stored and updated.
• We assess whether information sent to the commissariat was complete and on time, and reconstruct the timeline: what was sent, when, and what evidences it.
• We check how military registration connects to your HR processes — hiring, transfers, dismissals — and where information is lost in practice.
• We look separately at personal data handling: the basis for processing, the volume of data, access to the card index and the conditions in which it is kept.
• We produce a written report: the gaps found, how material each one is, the risk attached to it, and a remediation plan with priorities and timings.

What we need from the company

• The military registration documents currently in force: orders, the work plan, instructions, policies and registers.
• Access to the card index — on your premises, or in anonymised form, as agreed.
• The staffing schedule and information on headcount, structure and units, including those in other regions.
• Correspondence with the military commissariat: requests, notices, and the records of earlier reconciliations and inspections.
• The opportunity to speak with the person responsible for registration and with the HR team about how the work is actually done.
• Details of any reorganisations, changes of address and changes of responsible employee during the period under review.