According to OpenDataBot, Ukrainian courts are overturning fines imposed by Territorial Recruitment and Social Support Centers (TRSSCs) on corporate accountants for violations of military registration rules, primarily due to a lack of evidence of the employees’ personal culpability and an improper definition of their job responsibilities.
According to an OpenDataBot study published on October 16, 2026, in six out of eight identified court cases from 2024–2026, the accountants’ claims were granted in full, and in one other case, they were granted in part. Only in one instance did the court uphold the TCC’s position.
One of the main reasons for the annulment of administrative penalties was the lack of specificity regarding the violations. In particular, the TCC noted general shortcomings in the organization of military registration at enterprises but did not always specify which specific actions or omissions the accountant had committed.
The courts also noted that certain violations pertained to the organizational functions of the enterprise’s management, rather than to the employees responsible for the day-to-day maintenance of documentation.
Case No. 179/1326/26, heard on July 30, 2026, by the Magdalinivka District Court of Dnipropetrovsk Oblast, is illustrative.
The chief accountant of the municipal enterprise “Magdalynivsky Butter Plant” challenged the decision of the Tax and Customs Committee dated April 29, 2026, imposing a fine of 59,500 UAH under Part 3 of Article 210-1 of the Code of Ukraine on Administrative Offenses.
During the proceedings, the court found that there were insufficient grounds to hold the employee administratively liable. In particular, it noted the need for a clear definition of her official duties and for establishing the elements of the offense.
As a result of the proceedings, the court overturned the decision imposing a fine of 59,500 UAH and dismissed the administrative offense case due to the absence of the elements of the offense.
At the same time, the claim was partially granted, as the court denied a separate request to declare the decision unlawful, explaining that its overturning already constituted the appropriate legal assessment.
The court also ordered that 532.48 UAH in court costs be awarded to the plaintiff, to be paid from the defendant’s budgetary allocations.
According to Resolution No. 1487 of the Cabinet of Ministers of Ukraine dated December 30, 2022, the personal military registration of employees at enterprises must be carried out by responsible persons designated in accordance with established procedures.
Responsibility for organizing military registration rests with the enterprise’s director. The actual maintenance of records is typically carried out by human resources staff or other authorized employees.
Thus, the position of accountant does not in itself automatically entail the assignment of all military registration duties to the employee. At the same time, an accountant may perform the relevant duties if they have been properly assigned to him or her. In such a case, the possibility of administrative liability depends on the nature of the violation, the defined scope of authority, and the availability of evidence of guilt.
The reviewed case law underscores the importance of properly documenting responsibility for military registration at enterprises. It also confirms the need to individually establish an official’s guilt when imposing an administrative fine.
OpenDataBot is a Ukrainian platform for monitoring open government data that provides information from government registries, court decisions, and enforcement proceedings. The service also conducts analytical research on business activities, judicial practice, and economic processes in Ukraine.
Source: OpenDataBot, study dated October 16, 2026.
Court decision: Magdalynivka District Court, Case No. 179/1326/26 dated July 30, 2026.
Ukrainian courts have fully upheld six out of eight lawsuits filed by corporate accountants challenging fines imposed by Territorial Recruitment and Social Support Centers (TRSSCs) for violations of military registration rules, according to a study by OpenDataBot published on October 16, 2026.
According to analysts who used the “Babusia” court registry search engine, at least eight relevant court decisions were identified between 2024 and 2026. In six cases—or 75%—the courts ruled entirely in favor of the accountants. Another lawsuit was partially granted, while in one case the court refused to overturn the fine.
Thus, the plaintiffs’ claims were fully or partially granted in seven of the eight cases reviewed, accounting for 87.5% of the identified rulings.
In seven cases, the Tax Control Chambers imposed fines of 34,000 UAH on the accountants; in one other case, the administrative penalty amounted to 59,500 UAH. The total amount of the contested fines in the eight cases reached 297,500 UAH.
The first two court decisions are dated 2024. Three similar cases were identified in 2025, and three more decisions were issued in 2026.
The geographic scope of the legal disputes covers seven regions of Ukraine. The highest number of cases was recorded in the Khmelnytskyi region—two. Courts in the Dnipropetrovsk, Chernihiv, Ternopil, Ivano-Frankivsk, Kharkiv, and Kyiv regions each issued one ruling.
According to the analysis, the main reasons for overturning the fines were an insufficient evidentiary basis on the part of the Tax and Customs Service, a lack of specificity regarding the violations, and an improper identification of the responsible officials.
In particular, the rulings on administrative offenses did not always specify exactly what actions or omissions the accountant committed, when the violation occurred, or which specific duties were not fulfilled.
Analysts also point to cases where responsibility for organizational matters related to military registration was placed on the accountant, even though such authority belongs to the company’s management.
At the same time, the obligation to maintain military registration records does not automatically fall on an accounting department employee. Typically, these functions are performed by human resources staff or specifically designated company employees.
The eight court decisions identified do not cover all cases in which accountants were held administratively liable and do not allow for determining the overall proportion of fines imposed by the Tax and Customs Service of Ukraine that were subsequently overturned.
OpenDataBot is a Ukrainian service for monitoring open government data that provides information on companies, court decisions, enforcement proceedings, and other government registries. The company regularly publishes analytical studies on economic activity, judicial practice, and administrative procedures.
Ukrainian legal entities are required to submit information on their vehicles to the TCC and the SP twice a year, even if the company does not have any vehicles or other equipment on its balance sheet.
As explained by the Zhytomyr Regional TCC and SP in response to a request from OpenDataBot, if a company has no vehicles, it must submit a so-called “zero” report.
Information on the availability and technical condition of vehicles and equipment must be submitted annually no later than June 20 and December 20. This requirement is stipulated in the Regulations on Military Transport Obligations, approved by Cabinet of Ministers Resolution No. 1921.
Failure to submit the information or missing the deadlines may result in a fine of between 34,000 and 59,500 UAH for company officials.
However, not every violation necessarily results in a fine. An official may provide evidence of valid reasons for the delay, such as medical treatment, a business trip, or caring for a person with a disability.
In the Zhytomyr region in 2026, four companies received such resolutions; however, in all cases, the reasons for the delay were deemed valid, so no fines were imposed.
OpenDataBot recommends that companies verify in advance who exactly is designated as responsible for submitting the information and retain proof of its timely submission.
Primary sources: OpenDataBot, Regulations on Military Transport Obligations No. 1921, and Article 210-1 of the Code of Administrative Offenses.
ENTERPRISE, FINE, REPORT, TCK, TRANSPORT
