The Oberih Register: How to Check Your Data and Manage Employees’ Military Records

Oberih contains personal and official data about Ukrainian conscripts, persons liable for military service, and reservists. Entrepreneurs can check their own information through Reserve+ or contact the Register’s operating authority. If information is incorrect, identify the erroneous entry, prepare supporting documents, and submit a request through the service available for the case or to the relevant authority.

A legal entity acting as an employer checks military registration documents when hiring employees, maintains personal military records, and meets deadlines for reporting changes. Electronic exchange helps fulfill these duties; the company must continue to maintain personal military registration lists and documents. For an individual entrepreneur (FOP), the Procedure for Organizing and Maintaining Military Records of Conscripts, Persons Liable for Military Service, and Reservists, approved by Resolution No. 1487 of the Cabinet of Ministers of Ukraine (hereinafter, Procedure No. 1487), does not expressly establish the same duty to maintain employees’ personal military records. Employers’ access to information is limited by established procedures and the purpose of recordkeeping.

What Oberih is and who the Register covers

Oberih’s official name is the Unified State Register of Conscripts, Persons Liable for Military Service, and Reservists. Under Articles 1–3 of Law No. 1951-VIII, it supports the identification of citizens and military recordkeeping, provides information for staffing military formations, and gives citizens information about the fulfillment of their military duty. Military registration documents are issued using the Register’s tools.

Inclusion in the Register is determined by a Ukrainian citizen’s military registration status. The phrase “all men aged 17 to 60” does not reflect the Register’s statutory purpose or the full range of people it covers. In particular, military registration applies to women in the cases established by Articles 1 and 37 of Law No. 2232-XII “On Military Duty and Military Service”.

• Women with medical or pharmaceutical qualifications who are fit for military service based on their health and age must be registered as persons liable for military service.
• Women with other qualifications or professions related to military registration specialties on the list approved by the Ministry of Defence of Ukraine may register in this category voluntarily, provided they are fit based on their health and age.
• The law also provides for registering women as conscripts before they voluntarily enter basic military service.

An employee’s education matters to an employer even if she works as a shop assistant or administrator. Under paragraph 51 of Procedure No. 1487, a company manager must notify the relevant Territorial Recruitment and Social Support Center (TCC and SS) about female employees with medical or pharmaceutical education who are not on the military register.

Article 13 of Law No. 1951-VIII separately governs the initial creation of the database: designated state bodies transfer information about Ukrainian citizens under the age of 60 who are subject to military registration under the law. Information about people who are not conscripts, persons liable for military service, or reservists must be destroyed according to the established procedure. This process should be distinguished from the rules for maintaining existing records.

Who maintains Oberih and who can access its information

Under Article 5 of Law No. 1951-VIII, the Ministry of Defence of Ukraine is the Register’s holder and administrator, while the General Staff of the Armed Forces of Ukraine is its controller. The law identifies the bodies that administer and maintain the Register, including relevant TCCs and SS, the Ministry of Defence of Ukraine, Armed Forces of Ukraine recruitment centers, the Security Service of Ukraine (SBU), and relevant intelligence units. The SBU and intelligence bodies work with information about people registered with their bodies or units, within their respective powers.

Information about a person in Oberih is confidential. The law allows authorized bodies to access it within their powers and citizens to access their own information after identification. These rules do not provide for public searches of other people’s records by surname.

A legal entity may obtain specified information about its employees through the reconciliation procedure on the Diia Portal and use the personal recordkeeping account if technically available. The electronic reconciliation rules through the Diia Portal under Appendix 28-1 do not apply to persons liable for military service and reservists registered with the SBU or intelligence bodies. Under paragraph 3 of Appendix 28-1, an authorized representative must be entitled to act on behalf of the legal entity according to the information in the Unified State Register of Legal Entities, Individual Entrepreneurs, and Public Organizations.

The manager or such an authorized representative must also sign notices generated and signed by the responsible employee about receipt of information, changes to record data under paragraph 8 of Appendix 28-1, and completion of reconciliation. A notice about adding or deleting employment information under paragraph 5 of that appendix must be signed by the responsible employee, manager, or authorized representative. Signatories use their own qualified electronic signature or advanced electronic signature based on a qualified certificate.

If a company does not have a code from the Unified State Register of Enterprises and Organizations of Ukraine (EDRPOU) or cannot perform electronic reconciliation for technical reasons, it conducts reconciliation under paragraph 46 of Procedure No. 1487. Paragraph 34 and Appendix 28-1 to Procedure No. 1487 establish the information that may be obtained and the process to follow. This access is connected to the employment relationship and the company’s duties.

As the Ministry of Defence of Ukraine explains, the system records actions involving data, including their time, the user, the action or request, and the outcome. Access rights are differentiated. The employee responsible for military records at a company uses their own appropriate authority and electronic identification credentials.

What information the Register contains and where it comes from

Articles 6–8 of Law No. 1951-VIII define the personal and official data that may be included in the Register. To understand your own record and check personnel documents, it helps to distinguish these groups:

These are the main groups; Articles 7 and 8 of the Law provide the full list. The scope of data in the state Register does not determine what information an employer may collect for personnel administration.

Articles 13 and 14 provide for collecting information from individuals themselves and exchanging data electronically with state systems. For example, the tax authority transfers information specified by law about employment and a taxpayer’s registration number (RNOKPP). The Pension Fund of Ukraine transfers information about employment, experience in a specialty, and disability. Other sources provide data specified by law about documents, place of residence, education, medical examination results, and other circumstances.

If an error originated in the system from which the data was received, correcting it requires updated information from the relevant state body. When submitting a request, it is therefore useful to identify which source contains the incorrect information.

How entrepreneurs and employees can check their own records

Article 9 of Law No. 1951-VIII gives people the right to obtain information about whether they are included in the Register and what information about them has been entered. The Ministry of Defence of Ukraine confirms that this information is available free of charge through Reserve+, through the Diia Portal if technically available, or by submitting a written request to the district or city TCC and SS or its department where the person is registered.

Subparagraph 10 of paragraph 1 of the Military Registration Rules requires conscripts, persons liable for military service, and reservists to reconcile their personal information with the records held by the relevant TCC and SS, SBU body, or intelligence unit at least once every five years.

To check your information through Reserve+ yourself, follow the official app guide.

1. Install the official app. Check that the Ministry of Defence of Ukraine is listed as its developer. The guide specifies support for Android version 7 and later and iOS version 13 and later.
2. Complete bank electronic identification through BankID. You need an account and access to your bank’s app or online banking account. The record owner completes authorization.
3. Check your contact details. The app may prefill information from your bank. Enter your current phone number and residential address; providing an email address is optional in this process. Confirm changed contact details as directed by the app.
4. Wait for your record information. After confirming your contact details, create a passcode for future app access. The app will then send a request to Oberih and notify you when it is complete. It may take time to retrieve the information.
5. Open the full document information. Check your personal details, record type and category, registration authority, military rank and specialty, update date, and document validity period. If available, check any displayed information about a deferment, reserved status under the mobilization reservation procedure, or a violation of registration rules.
6. Write down the specific discrepancy. When you contact the relevant authority, state which field is incorrect, what it should say, and which document supports the correction.

According to the official guide, an electronic military registration document has the same legal force as a paper document. To verify it, the owner opens the document and shows its QR code, a graphic code that can be scanned to retrieve information. If the app displays the status “Needs clarification,” the electronic document and QR code are not generated; the user can see data from the Register and should find out the reason through the appropriate contact channel.

What to include in a written request for your own information

According to the Ministry of Defence of Ukraine, a request should state your surname, given name, and patronymic if applicable; date and place of birth; place of residence or stay; RNOKPP if available; and details from your Ukrainian passport. Include a phone number and email address if available.

Practical recommendation: separately ask for information about whether you are included in the Register and what information about you it processes. Keep a copy of the request and proof that it was submitted. Under paragraph 4 of part two of Article 8 of Law No. 2297-VI, a response about the processing and content of personal data must be provided within 30 calendar days of receiving the request, except in cases provided for by law. If no response arrives within the prescribed period, proof of submission can support a complaint.

How to correct an error in Oberih

Article 9 of Law No. 1951-VIII provides for submitting a reasoned application to the relevant Register operating authority about an unlawful inclusion or omission of a record and requesting correction of inaccurate information. The right to request changes to inaccurate data is also established by Article 8 of Law No. 2297-VI “On Personal Data Protection”.

1. Identify the issue. For example, an incorrect surname, a missing record, or military service that is not shown.
2. Gather supporting documents. Choose documents relevant to the specific error that establish the correct information.
3. Choose an available correction method. The official Reserve+ guide describes online requests for the cases “Data not found” and “I am serving in the military, but I am still listed as registered.”
4. For other discrepancies, contact the Register operating authority. The Ministry of Defence of Ukraine recommends submitting an application to the authority where the person is registered. If another authority entered the incorrect data, submit the request to that authority. An error originating in another state system is corrected based on updated information from the relevant state body.
5. Keep proof that you submitted the request. For an electronic request, save the available submission or receipt notice; for a written request, keep a copy marked as received or proof of delivery.
6. Check the result. After being notified that changes were made, request updated information and verify the corrected field.

For a request about military service that is not shown, the Reserve+ guide calls for the name of the TCC and SS that arranged conscription, the military unit’s name, and a brief description of the situation. For the “Data not found” case, the app generates a request for the user to confirm. Once the request is received, the information is checked; a notice of changes is sent if they are confirmed.

Reserve+ provides users with specified services and fields for updating information. Users can update only those fields offered through the available service. To correct other personal and official information, submit a request or application under the relevant procedure. Submitting a request starts its review; check the result after receiving a response.

Under paragraph 23 of Procedure No. 1487, changes to a residential address and other personal data must be reported to the relevant authorities within seven days. Subparagraph 8 of paragraph 1 of the Military Registration Rules separately provides for reporting changes to a place of residence or stay, phone number, and email address through the electronic account or in person; these details may be reported through the account no more than once every seven days. People registered with the SBU or intelligence bodies should contact the relevant body.

What companies must do and what FOPs should know

Part five of Article 34 of Law No. 2232-XII assigns personal military recordkeeping at the workplace to the heads of specified bodies, enterprises, institutions, and organizations. Paragraphs 8, 14, and 16 of Procedure No. 1487 provide further details. Private ownership and a small workforce do not, by themselves, exempt a company from keeping records.

Under paragraph 34, a company must also provide information about employees whose personal military records it maintains when requested by the relevant military registration authority. This paragraph requires the company to keep the relevant TCC and SS, SBU body, or intelligence unit continuously informed about officials who violate Procedure No. 1487 and about conscripts, persons liable for military service, and reservists who violate the Military Registration Rules.

If the company receives an order to notify employees that they have been summoned, the manager must follow paragraph 47: issue an order and inform employees, obtaining their personal signatures. For employees working remotely or from home, those on temporary sick leave, on leave, or on a business trip, notice must be sent by registered mail with an enclosure inventory and delivery confirmation. The company must send a copy of the order and proof of notification to the relevant authority within three days.

If summonses are available, they must be served on employees. The relevant authority must be notified in writing, with extracts from the orders, about employees who are temporarily unable to work or are on leave or business trips. The manager is responsible for monitoring the notification process and employees’ attendance when summoned.

The manager appoints a responsible employee from the personnel department. If the company has no such staff position, the duties are assigned to the person who maintains employee records. If fewer than 500 people are included in the company’s military registration records, paragraph 10 of Procedure No. 1487 provides for assigning these duties to a personnel department employee, with an additional payment of up to 50 percent of the position’s salary.

The number of responsible employees is determined under paragraphs 9–11 based on the number of people registered as of January 1. The responsible employee must meet the qualification requirements for a military registration inspector. Each year by October 1, the company determines whether this employee needs further training and arranges it at least once every five years. Under paragraph 12, training is provided on a contractual basis by educational institutions licensed for the relevant activity.

When choosing an institution, also check that its training program has been approved by the General Staff of the Armed Forces of Ukraine; institutions must obtain program approval every two years. Under paragraph 13, the relevant district or city TCC and SS must be notified of the appointment or dismissal of the manager and other responsible employees within seven days of the order.

Article 34 and Procedure No. 1487 do not expressly list an FOP as a separate category of employer required to maintain employees’ personal military records. Therefore, the lists, reconciliations, and notices required of companies under this Procedure should not automatically be applied to an FOP solely because they employ staff. An FOP acting as an employer must also check the documents legally required to conclude an employment contract.

Under Article 24 of the Labour Code of Ukraine, a citizen must submit the appropriate military registration document in cases provided for by legislation. Entrepreneurs fulfill their own military registration duties according to their status as citizens and personally ensure the protection of personal data they hold under Article 24 of Law No. 2297-VI.

How a legal entity should check documents when hiring

For citizens who are conscripts, persons liable for military service, or reservists, paragraph 34 of Procedure No. 1487 provides for checking the military registration document and verifying that its information matches the Register. Organize this check before hiring.

1. Check the document and its owner’s identity. Military records are maintained on the basis of the person’s Ukrainian passport and military registration document.
2. Check that the information is current. To reconcile records, use an electronic military registration document generated through the State Web Portal of Electronic Public Services in the National Security and Defence Sector, including through Reserve+, or the Diia Portal, no earlier than 72 hours before the hiring date. If technically available, the check may be performed through the personal recordkeeping account.
3. Follow the special procedure. Under this procedure, the paper document’s consistency with Register information is not checked for persons liable for military service or reservists registered with the SBU or intelligence bodies.
4. Confirm military registration. Paragraph 34 provides that employment and inclusion in the company’s personal records take place after the person registers with the relevant TCC and SS, SBU body, or intelligence unit.
5. Have the employee read the Military Registration Rules and sign an acknowledgment that they have been informed of them. Keep proof with the required recordkeeping documents.
6. Enter the information in the records and send the notice. Meet the separate deadlines for the lists and for notifying the military registration authority.

Practical recommendation: explain the requirement for a current document to the candidate before agreeing on a start date. If the hiring date changes, check again that the electronic document was generated within the 72-hour period.

For the check, the employee opens their document and presents it to be scanned. The employer checks the document under the established procedure. The employee must retain control of their personal password, bank credentials, and qualified electronic signature (QES): a personnel check does not authorize the employer to access the employee’s personal account.

Which deadlines to add to the military recordkeeping calendar

For legal entities, the main actions and deadlines are set out in paragraphs 13, 34, and 40–46 of Procedure No. 1487.

Paragraph 34 allows notices about hiring or dismissal to be submitted electronically through the Diia Portal or personal recordkeeping account if technically available. Notices submitted through these channels do not also need to be submitted on paper. If employment is arranged electronically through the Unified Information and Analytical System “Obrii,” the Procedure provides for the relevant notices to be generated and transmitted automatically.

Personal military record lists are maintained under Appendix 5, and the operational record under Appendix 12, in electronic and/or paper form. Under paragraph 36, separate lists are created for officers; enlisted, sergeant, and petty officer ranks; women; and conscripts. Under paragraph 37, the lists are kept with copies of paper military registration documents or electronic documents, including printouts. Under paragraph 38, copies of documents for citizens removed from or excluded from military registration by the relevant authority are kept in a separate file; this requirement does not apply to people who have reached the maximum age for remaining in the reserve.

Under paragraph 36, each group’s lists separately identify people with mobilization orders by their respective teams, in ascending numerical order. People serving in the military reserve are recorded as persons liable for military service with mobilization orders. Under paragraph 43, the lists also separately identify persons liable for military service who have reserved status under the mobilization reservation procedure. Under paragraph 44, information about former employees and employees released from work because they were called up or accepted for military service during a special period is kept in the lists until the end of the current year.

Employees whose employment contracts have been suspended remain on the lists. Under paragraph 35, within seven days after an employee reaches the maximum age for remaining in the reserve, the manager marks the list “Excluded from military registration due to age.” The company also maintains a log of inspection and reconciliation results under Appendix 9 and displays printed Military Registration Rules in a visible place in a publicly accessible room, as required by paragraphs 19 and 34.

What employers should do when information does not match

The practical steps depend on where the discrepancy occurred: in the company’s list, employment information, or the employee’s personal military registration record.

1. Record the discrepancy. Note exactly which details differ, which documents contain them, and when the discrepancy was found. Include only necessary supporting documents.
2. Check the personnel records that support the entry. Review the order on hiring, transfer, or dismissal and the documents used to maintain the records. If the company made the error, correct its own records and submit the required notice.
3. Use the clarification procedure. If technically available, the authorized representative acts through the Diia Portal or personal recordkeeping account. If the employee’s personal information needs correction, explain how to contact the Register operating authority.
4. Keep proof of submission. Add confirmation, rejection, and the reason for rejection to the records for the relevant action. If a request is rejected, check the reason and required documents.
5. Check the control list and confirm reconciliation. Use the Diia Portal to request current information. Under paragraph 11 of Appendix 28-1, if the company has not yet received the results of processing changes under paragraph 9, the control list includes information from the submitted notice of changes to record data. Check the control list and submit a signed notice confirming reconciliation and the accuracy of the submitted information. If the responsible employee generates the notice, the manager or authorized representative must also sign it. Under paragraphs 10–13 of Appendix 28-1, the signed notice is locked against editing and confirms that reconciliation took place. Under paragraph 16, the Register may automatically limit how often reconciliation is recorded if a company performs an excessive or unjustified number of these actions. These limits do not prevent reconciliation when actual changes to record information have occurred. Enter the result in the inspection results log. If electronic reconciliation is not technically available, the responsible employee personally submits lists and copies of military registration documents to the TCC and SS within the relevant administrative-territorial unit, according to the schedule or agreed deadlines. For TCCs and SS in other administrative-territorial units, send extracts from the lists and copies of military registration documents in two copies. For reconciliation with SBU bodies and intelligence units, send these materials in two copies by registered mail with an enclosure inventory and delivery confirmation. Keep the returned copy of the extract marked as reconciled and enter the result in the log.

Appendix 28-1 to Procedure No. 1487 provides for employment information to be clarified within 72 hours of sending a notice under specified conditions: the person is on the military register, and the relevant employment or termination of employment is confirmed by information from the Pension Fund of Ukraine.

Under paragraph 8 of Appendix 28-1, an employer may report changes to an employee’s actual, declared, or registered residential address and to the details of the order appointing them to a position. Within 72 hours of receiving the notice, the Register checks and updates the relevant information through electronic exchange with state resources. If the change cannot be confirmed through electronic exchange or needs further review, an operator at the relevant TCC and SS processes it within three business days of becoming aware of it. Formatting or data logic errors stop the clarification process through the Diia Portal. A notice is sent stating whether the changes were confirmed or rejected and giving the reason.

Example. After a shop assistant leaves, the Register continues to show them as working at the store. The responsible employee checks the dismissal order, verifies that the company’s own lists have been updated and a notice submitted, and, if the service is available, prepares a notice to delete the information from the list of employed persons. The conditions established by Appendix 28-1 must be confirmed for the information to update automatically. The employee keeps the system’s response and checks the result.

If a discrepancy is found when hiring a candidate, determine how it affects compliance with paragraph 34: whether a document is available, whether its information is current, and whether military registration is confirmed. If the check cannot be completed using the available information, arrange clarification through the relevant authority. A hiring decision should be based on established circumstances and applicable legal requirements; a technical discrepancy itself needs to be checked.

How to protect employee data during checks and requests

Part three of Article 6 of Law No. 1951-VIII allows personal data to be processed for the purposes of the Register without the person’s consent. At the same time, paragraphs 8 and 8-1 of Article 7 set a special condition: information about parents, representatives, children, marital status, and family members is entered only with the consent of the conscript, person liable for military service, or reservist.

An employer determines the legal basis for its own data processing under Article 11 of Law No. 2297-VI. Fulfilling a statutory obligation may be such a basis. Articles 6, 14, and 24 also require data to be relevant to the purpose, not excessive, adequately protected, and transferred only under lawful conditions.

To organize this work, consider adopting the following rules:

• Give access to military record files only to designated employees who need it to perform their duties.
• Keep required documents and proof in a file with restricted access. Use the channel prescribed by the procedure when transferring them.
• Collect only the information required for established forms and specific actions. Information available through a personal account may exceed the employer’s needs.
• Organize checks so that employees control access to their own accounts and present the necessary document themselves.
• Use fictional or fully anonymized examples when preparing request templates in artificial intelligence services. Keep actual military registration documents, employees’ personal data, QR codes, and military record materials within the company’s established secure process.

If a person believes their data is being processed unlawfully or receives inaccurate information, Article 8 of Law No. 2297-VI provides for a reasoned request to correct it, an appeal to the Ukrainian Parliament Commissioner for Human Rights, or a court claim. Keep the original application, proof of submission, response received, and documents supporting the discrepancy.

Liability for personal military registration, employer registration, and data protection

In Ukraine, liability depends on the obligation and the person who breached it. Check the reason for any discrepancy in the Oberih Register and identify which information needs correction.

Conscripts, persons liable for military service, and reservists are liable under Article 210 of the Code of Ukraine on Administrative Offenses (CUAO) for breaching the rules on their own military registration. For an official of an employer that is a legal entity, liability under Article 210-1 depends on that official’s breach of legislation on national defense, mobilization preparation, and mobilization. A technical discrepancy in the data does not by itself mean that a fine will automatically be imposed: a specific violation and the applicable provision must be established.

The limits below are set out in Articles 210, 210-1, and 188-39 of the CUAO. All amounts in the table are stated in non-taxable minimum incomes of citizens.

To apply part three of either article, the relevant conduct must have been committed during a special period; no prior penalty is required. Article 210-1 also provides for citizens’ liability, but the column above concerns officials of legal entities only.

The note to Article 210 provides an exception for Articles 210 and 210-1. Their provisions do not apply when the holder of the Unified State Register of Conscripts, Persons Liable for Military Service, and Reservists can obtain a conscript’s, person liable for military service’s, or reservist’s personal data through electronic information exchange with other information and communication systems, registers, including public registers, or databases (data banks). Those sources must be held, managed, or administered by state bodies.

To apply the exception, establish which personal data the violation concerns and whether the Register’s holder can obtain those data by this means. The presence of information in Oberih does not itself exempt an employer from liability for all other unfulfilled duties, such as maintaining lists or notifying employees of summonses.

Separately, part four of Article 188-39 provides for a fine of 300–1,000 non-taxable minimum incomes of citizens for officials and individual entrepreneurs who fail to follow the established procedure for protecting personal data, if this results in unlawful access to that data or a violation of the rights of the personal data subject. For a repeat of such a violation within one year, where the person has already been subject to an administrative penalty, part five sets a fine of 1,000–2,000 of those minimum incomes.

Practical recommendation: Keep documents concerning any discrepancy you identify, review employees’ access to personal data, and record the steps taken to correct errors.

Official sources for checking the requirements

• Law of Ukraine No. 1951-VIII “On the Unified State Register of Conscripts, Persons Liable for Military Service, and Reservists” — Articles 1–3, 5–10, 12–14-3: purpose, responsible entities, data, citizens’ rights, electronic exchange, and accounts.
• Resolution No. 1487 of the Cabinet of Ministers of Ukraine “On Approval of the Procedure for Organizing and Maintaining Military Records of Conscripts, Persons Liable for Military Service, and Reservists” — paragraphs 8–16, 19, 20–23, 33–47, 50–51, 72; Appendices 2, 4, 5, 9, 12, 28-1: recordkeeping, document checks, deadlines, and electronic reconciliation.
• Law of Ukraine No. 2232-XII “On Military Duty and Military Service” — Articles 1, 33, 34, 37: categories of people, registration of women, personal records at the workplace, and changes in registration status.
• Law of Ukraine No. 2297-VI “On Personal Data Protection” — Articles 6, 8, 11, 14, 24: scope and legal bases for processing, individuals’ rights, data transfers, and data protection.
• Ministry of Defence of Ukraine: how the Oberih Register works — access to personal information, error correction, information sources, and access controls.
• Official Reserve+ guide — installation, identification, contact updates, obtaining and checking a document, and specified cases for online corrections.
• Code of Ukraine on Administrative Offenses — Articles 210 and 210-1, the note to Article 210, and parts four and five of Article 188-39: conditions for liability, the exception for electronic retrieval of data, and fine ranges.
• Labour Code of Ukraine — Article 24: documents required to conclude an employment contract, including the appropriate military registration document in cases provided for by legislation.