*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.