Setting up military registration in a company

What is happening

The duty to keep military registration records does not depend on the size of the company, or on whether anyone on the payroll is currently liable for military service: it arises for the organisation as soon as it has employees. Having no order, no work plan and no card index is a breach in its own right, even if in substance there is nobody to record yet.

Companies usually come to us in one of three situations: the company has just been formed and is registering with the military commissariat; registration nominally existed but was kept in a free format that will not survive the first reconciliation; or a request or notice has arrived from the commissariat and it has become clear that the paperwork is missing.

A separate difficulty is how the work is divided inside the company. Military registration sits where HR administration, personal data handling and dealings with public authorities meet, and without written internal rules it rests on one person and falls apart the moment they take leave or resign.

What the law says

• The duty of organisations to keep military registration records for their employees and to report information to military commissariats is set by the law on military duty and military service (Federal Law 53-FZ).
• How registration is to be kept inside an organisation is set out in detail in Government regulations and in General Staff methodological guidance, which prescribe the forms, the composition of the card index and the deadlines for reporting.
• Companies covered by mobilisation assignments and by reservation from call-up are additionally subject to the law on mobilisation preparation and mobilisation (Federal Law 31-FZ), with its own reporting and its own body of documents.
• Registration data about employees is personal data, so the card index and the exchange of information with the commissariat must fit within Federal Law 152-FZ: purpose of processing, categories of data, storage and access.
• The Code of Administrative Offences provides for administrative liability of the company and its chief executive for failures in military registration; such breaches are formal in nature and come to light during reconciliations and inspections.
• The work counts as properly organised once the company has an order appointing a responsible person, a work plan, a card index of registration documents and written rules for the HR team to follow.

What we do

• We establish how much registration work your company actually needs: headcount, whether any employees are liable for military service, whether a dedicated post or a combined role is required, and whether reservation from call-up is relevant.
• We prepare the full set of internal documents: the order appointing the responsible person, the military registration work plan, a policy or instruction, and the approval forms and registers.
• We build the card index: which registration documents are held for each employee, and how they are completed, stored and kept up to date.
• We set out dealings with the military commissariat: what information goes out and by when, who signs it, how despatch is evidenced and how reconciliations are handled.
• We embed military registration into your HR processes — hiring, transfers, dismissals, changes to personal details — so that the records update as a matter of course rather than on a reminder.
• We brief the responsible employee and the HR team, hand over the documents, and stay available for the questions that arise in the first months.

What we need from the company

• Company details: corporate particulars, the addresses where the business actually operates, and the structure of its units.
• The staffing schedule and anonymised headcount figures — no personal data is required at this stage.
• The HR documents you already have: internal labour regulations, your personal data policy, and any HR instructions.
• Any correspondence with the military commissariat, if there has been any: requests, notices and reconciliation records.
• A decision on who will be responsible for military registration, and the ability to give that person time for training.
• A contact for the chief executive or an authorised signatory, to approve and sign the set of documents.