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October 7, 2019

How to keep military service records: A step-by-step guide

By Oksana Oleksyuk, Director of Expertise and HR Outsourcing Methodology Center
Here is in an FAQ format a step-by-step guide describing how companies should keep military service records.

This guide will be equally useful for companies that have only just started recording military service details and those that have already encountered certain difficulties in keeping military records.

To start with, we explain what military registration is and its purpose.

Military registration refers to the registration of conscript and mobilization human resources to determine their quantitative and qualitative composition. Setting up a military registration system allows the state to clearly understand at any point in time where and in what quantity human resources are located and manage them promptly.

Federal Law No. 53-FZ On Military Duty and Military Service dated March 28, 1998 requires companies to keep records of their employees' military registration. Employers failing to keep military registration faces administrative liability (Chapter 21 Russian Code of Administrative Offenses).

Military registration: sequence of actions

Step 1. Designating a person responsible for military registration
Although company heads are responsible for coordinating and keeping military registration, another employee may be designated to directly keep military records. The number of persons designated as responsible for keeping military records depends on the number of employees qualifying for military registration as set out in Russian Government Decree N 719 dated November 27, 2006:

- Under 500 people – 1 part-time officer
- From 500 to 2,000 people - 1 full-time officer
- From 2,000 to 4,000 people - 2 full-time officers
- For each subsequent 3,000 people - 1 full-time officer

Company heads must also provide the persons responsible for military registration with rooms specially equipped with iron cabinets the access to which is subject to control.

Question: Can a person authorized by the CEO of a company sign military registration documents? What is required for this?
Answer: Company heads must sign an annual military registration plan and an order appointing the person responsible for military registration. A person authorized under a power of attorney may sign other military registration documents (changes of details, hiring, dismissal records), acknowledgement in record log (Guidelines for Military Records Section III Items 27, 28, 29, 36 Duties of Employees Maintaining Military Records).

Question: Is it possible to specify in the order appointing the person responsible for keeping military records that the company head has granted the right to sign military registration documents to an authorized person? If so, how should this be formulated?
Answer: The right to sign may be documented by issuance of an order together with a power of attorney listing the military registration documents that the authorized person is entitled to sign. The signature right to obtain documents at the relevant authorities is documented in the same way.

Question: Should part-time military registration officers be included in the staffing table? Or is it enough to issue an order assigning these duties to an employee? What should be the title for this position?
Answer: If keeping military records is not included in the HR manager duties, this duty may be assigned to the HR manager only with his/her written consent and appropriate additional payment. Additional duties are documented as prescribed in Article 60.2 of the Russian Labor Code.

Step 2. Determining whether or not employees are subject to military registration
The following people are subject to military registration:
- Men are to be registered for the first time between the age of 15 and 17
- Men of military age, i.e. from 18 to 27
- Army reservists
- Women with a military career
The following people are not subject to military registration:
- Women with no military career
- People in prison or with a suspended sentence
- People permanently residing outside the Russian Federation
- People doing their military service or alternative civilian service
- People who have reached the age limit for army reservists
- People exempt from military service
- Foreign intelligence and FSB reserve officers

Question: In what cases should a foreign employee be subject to military registration, and what needs to be done in this case?
Answer: Foreign nationals are not subject to military registration in the Russian Federation. Only Russian conscripts are subject to military registration (Item 14 Regulations Approved by Russian Government Decree No. 719 dated November 27, 2006).

Question: Where can the list of military careers for women be found?
Answer: This list can be found in the appendix to Russian Government Decree No. 719 dated November 27, 2006 Approving Military Registration Regulations. This list is also attached to Guidelines for Maintaining Military Records in Organizations dated July 11, 2017.

Question: Should students doing an internship of no more than a month be registered for military purposes?
Answer: Military records are kept only for employees. Students doing an internship are not employees, so they are not subject to military registration.

Step 3. Creating a file register
A file register sets out the procedure regulating how documents are distributed into folders and describes the content of each folder and each file. The person responsible for military registration needs to create folders and save the relevant documents in these folders. The following four major files need to be set up for military registration.

1. Military registration guidelines and regulations

Constitution of the Russian Federation
Federal Law No. 53-FZ On Military Duty and Military Service dated March 28, 1998
Federal Law No. 61-FZ On Defense dated May 31, 1996
Federal Law No. 31-FZ dated February 26, 1997 On Mobilization Preparation and Mobilization in the Russian Federation
Russian Government Decree No. 719 Approving Military Registration Regulations dated November 27, 2006
Federal Constitutional Law No. 1-FKZ On Martial Law dated January 30, 2002
Section IV Federal Law No. 53-FZ On Military Duty and Military Service dated March 28, 1998
Guidelines for Maintaining Military Records in Organizations
Procedure for notifying army reservists in enterprises, institutions, educational and other organizations
Guidelines for booking Russian reservists of the Russian Federation Armed Forces, federal executive bodies and working in government bodies, local authorities and organizations
Order appointing the person responsible for military registration
Order for military registration coordination
Military registration work plan
Military registration inspection log
Draft order and statement of transfer of special registration forms and other military registration documents
Additional forms may be obtained at the local military registration office which provides them to meet any military registration needs whether special or general.

2. Individual record cards

Please note that this file needs to be updated constantly. The status report consists of 8 sections as presented in the table below. We recommend paying attention to how documents are organized in archives.
*for companies with over 500 draft-age employees.

Question: Should companies employing fewer than 500 draft-age people archive personal record cards?
Answer: As a rule, it is not required by law to keep personal record cards on Form Т-2 VUS for dismissed employees, but this does not apply to standard form Т-2.

Question: Is the personal record card for military registration special or is it the same as Т-2?
Answer: Military records may be kept using Form Т-2 and abridged Form Т-2 VUS (VUR). HR specialists still need to complete Section II Military Registration in Form Т-2 even if they have used the abridged form for military registration.

Question: Is it necessary to keep military records for part-time employees?
Answer: It is not required to keep military records for part-time employees. As for external part-timers, Federal Law No. 53 provides for no restrictions based on "full-time" or "part-time" employment, so military records must be kept for external part-time workers.

3. Military registration recordkeeping
Correspondence with military registration offices and military authorities is kept in this folder:
Log of military registration documents – incoming
Log of military registration documents – outgoing
Record of hired people
Record of dismissed people
Record of changes in military registration data
Statement of reconciliation with military registration office
Form No. 18
Form No. 6
Form No. 11MU
Lists of young men for initial military registration
Lists of women for military registration
Lists of people who should be but are not registered for military purposes

4. Liaising with people on military registration
- Log of message records
- Message record sheets

Question: What does "file" mean? Should separate folders be created?
Answer: Military registration offices require creating appropriate folders: Folder No. 1, Folder No. 2, etc. Each folder must have its own name. For example, Folder No. 2 may be called Personal Record Card File.

Step 4. Preparing documents for registering an organization with military authorities
Documents to be submitted at the place of registration of the organization:
Cover letter requesting registration for military registration purposes
Order of company head for appointment of military registration officer
Form F-18
Certified copies of registration documents
Documents to be submitted to the relevant military registration office:
Order for organization of military recordkeeping
Schedule for keeping of military records
Job description for maintaining military records
11МU report
Form 18
Military registration application

First, it is necessary to draw up and approve the duties of the person responsible for keeping military records, issue an order for organization of military recordkeeping, draw up a schedule for keeping military records and get these documents approved by the relevant military registration office. A standard job description can be found in legal systems, and it is also possible to request consultants to draw up the job description.

Duties of the employee responsible for military records:
Ensure registration of employees in the military records at the place of work;
Collect, store and process the data in the personal record cards of people subject to military registration;
Keep up to date the data in personal record cards as well as military registration documents.

Question: How long do companies have to notify the relevant military registration office of a change of military registration officer?
Answer: The law provides no deadline although guidelines (the keyword is guidelines) specify that draft orders appointing the person responsible for military records are to be approved by the relevant military registration office. They also indicate that it is good practice to get the candidate approved before he/she is appointed. Transfer and dismissal of military registration officers should also be approved by the relevant military registration office. Military registration offices do not usually approve candidates, but work based on orders already submitted.

Step 5. Submitting documents to the district authority and military registration office
After submitting the documents, it is necessary for companies to obtain a certificate of registration for military records from the district authority and military registration office.

Question: What organization is in charge of military registration: district authority, military registration office or city administration?
Answer: According to administrative local divisions and local government laws, district authorities register the organizations required to keep military records in Moscow. The local administration is in charge to do so in other cities. These state bodies fulfill the function of army conscription commission and assign a number to organizations when they apply for military registration purposes. After registering with these bodies, employers register with the relevant military registration office.

Question: A company has over 10 separate subdivisions and branches with its head office in St. Petersburg. Should this company register at the location of its branches?
Answer: Military registration is performed at the place of registration of legal entities, i.e. at the place of location of the organization's head office. It is therefore not required to register for military registration purposes at the location of branches.

Step 6. Notifying the military registration office at the location of registration of each draft-age employee

Question: Employees sometimes do not provide temporary registration, but they are removed from military registration at their permanent place of registration. How to determine which registered address is valid for the military registration office?

Answer: To determine which registered address is valid, you can first call the relevant military registration office. District authorities and the Russian Ministry of Defense assign jurisdictions. The addresses of regional and district military registration offices are listed on the website of the Russian Ministry of Defense. Jurisdiction can also be clarified by district authorities.

If an employee is deregistered from military records at his place of permanent registration, and you have no information on whether the employee is registered for military registration purposes at his place of temporary registration, then it will be necessary to register the military records for this employee at the place of registration that you know. To do so, it is necessary to send to the military registration office at the employee's place of residence (registered address as indicated in his passport) a notice stating that the employee must but is not registered with the military registration office together with a cover letter requesting assistance to register the employee.

Step 7. Regular updating of military registration data

Maintain the file register and mandatory logs
Update the draft-age and conscript men file
Check the documents of draft-age people and whether they should be registered
Issue record sheets to employees for military registration at the place of registration
Notify employees of calls (summons) from military registration offices or local authorities, clarify national service obligations
Maintain and update 1C database or other accounting system
Conduct internal audits of military records
Reconcile personal record card data with military registration office data
Prepare mandatory forms and reports for the relevant military registration office
The employee responsible for keeping military records or the professional team to whom this function has been transferred will perform this ongoing work.

Question: What can be done when the military registration office declines the records of hired and dismissed temporary employees?
Answer: Russian laws on defense and military registration make no exceptions for keeping military records of employees hired under a fixed-term employment contract.

If an employee is not in the statutory list of employees not subject to military registration (Item 15 of Regulations Approved by Russian Government Decree No. 719 dated November 27, 2006), the employee's employer should keep his military records in accordance with general practice, i.e. by sending the relevant details by mail and recording such dispatching in the outgoing documentation log. The details should not be handed over to the relevant military registration office in person.

Question: Should the transfer of an employee to another post be notified to military registration offices?
Answer: Yes.

Question: Is it necessary to check whether employees' passports have been stamped to indicate that military registration has been completed at their place of registered residence?
Answer: As set out in guidelines, employers are required to check employees' passports to verify whether they have registered for military purposes at their place of registered residence. If there is no stamp evidencing military registration in a draft-age employee's passport, the employee's employer must notify the relevant military registration office and sent him to this office with a record sheet.

Question: If the employee puts off going to the military registration office, will the employer and/or the employee be liable in this case? If so, how will they be held liable?
Answer: Employers must send their employees to the military registration office with a record sheet and check that they come back with the tear off part of the record sheet stamped by the military registration office. A special log is maintained to record the stamped tear off parts of the record sheets. The guidelines (Item 29(a)) and military registration regulations (Item 32) provide for a 2-week period for sending information. Employers are liable only for failing to meet deadlines, and a fine of RUB 500 is imposed on employees in this case.

Question: What is the procedure for military registration in the district authority and the military registration office (annually, one-time)?
Answer: Form No.18 is to be submitted to the district authority every year for number confirmation at the conscription commission. The second copy of form No.18 is also submitted to the military registration office annually, while the third copy is kept by the employer.

Question: What fines are imposed for "ignoring" military registration?
Answer: There is no administrative liability for "ignoring" military registration, but fines arising from the general obligations to keep military records are provided for:

1. Article 21.1. A fine from RUB 300 to RUB 1,000 is imposed for each failure to submit lists of people subject to initial military registration to the military registration office or another body keeping military records;
2. Article 21.2. A fine from RUB 500 to RUB 1,000 is imposed for each failure to notify that people have been summoned by the military registration office or another body keeping military records;
3. Article 21.4. A fine from RUB 300 to RUB 1,000 is imposed for failure to provide information about people who are or must be registered with the military.

Question: Are companies inspected for verification of military recordkeeping? If so, is there an inspection schedule? And who conducts such inspections?
Answer: Companies with fewer than 500 draft-age employees are inspected once every 3 years, while companies with more than 500 people registered with the military are inspected every year. No inspection schedule is published anywhere, and inspections may be conducted by the relevant military registration office, or the military registration office together with the prosecutor's office.

Keeping military records is a painstaking and labor-intensive job that may be transferred to professional consultants.

SBER Solutions specialists would be happy to help by:
  • Checking the completeness and correctness of your employees' details
  • Preparing the documents necessary for the military registration office
  • Liaising with military registration offices
  • Advising on military registration

We can also help companies that have never kept military records by:
  • Creating a file for draft-age and conscript employees
  • Registering the company for military registration purposes with the district authority and the military registration office
  • Preparing and submitting to the military registration office documentation for keeping military records

Transferring the keeping of military records to SBER Solutions would reduce the workload and burden on HR specialists and would also allow avoiding administrative liability for failure to comply with federal laws and other regulations.