Women's military registration. What will change from October 1, 2023?

Nataliia SLIPCHENKO,

Senior HR Administration Specialist
 of HR Administration and Payroll Division of BDO LLC

 

In accordance with Article 1 of the Law of Ukraine “On Military Duty and Military Service”, beginning on October 1, 2023, women in Ukraine are mandated to undergo military registration. However, this statement is not entirely accurate.

Currently, military registration for women in Ukraine remains voluntary. However, starting from October 1, 2023, women who possess medical or pharmaceutical qualifications will be obligated to register with the Territorial Centers of Recruitment and Social Support (TCRRSS). This requirement applies exclusively to doctors, nurses, and pharmacists.

The specified medical/pharmaceutical specialties falling under this obligation are detailed in List No. 313:

• Physical therapy, occupational therapy, medical and psychological rehabilitation, public health, physical rehabilitation, industrial pharmacy, sanitation, and expertise;
• Dentistry, medicine, nursing, pharmacy, medical diagnostic and treatment technologies;
• Veterinary medicine and veterinary hygiene.

 

Important Note: registration of women does not entail automatic conscription into military service.

Military registration of women having medical and pharmaceutical specialties does not imply automatic conscription or deployment to conflict zones. Being registered for military service does not automatically entail a woman's conscription into active military service, according to official sources.

Furthermore, authorities have noted that the Armed Forces of Ukraine currently have enough medical personnel.

Who is subject to military registration?

Women aged 18-60, who have obtained medical or pharmaceutical qualifications and are deemed physically qualified by the medical board (VLK), are required to register for military service. Disabilities previously established in a woman's medical history do not automatically consider her unfit for military service. The VLK may assess her state of health differently.

 

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Exemptions from military registration for certain medical and pharmaceutical professionals

For women who completed their education before the approval of changes to the Law on Military Duty and Military Service (i.e., before December 30, 2022), a transitional period is in effect. This means that until the end of 2026, they will have the opportunity to be employed without military service obligations.

Thus, during 2026, they must register for military service. Women, who fail to comply with this requirement, will not be able to find a job in the specialty from the beginning of 2027.

Graduates from medical and pharmaceutical institutions are given a one-month period after completing their education to register. If they do not contact the centers of recruitment during this time, they may be imposed a fine ranging from 850 to 1700 UAH.

 

Who can voluntarily register for military service?

All other physically fit women aged 18-60, who possess a profession and/or specialty related to military registration, may voluntarily register for military service.

 

Professions and specialties covered by voluntary military service registration

Professions and specialties eligible for military registration according to List No. 313 include, among others:

• Professionals in life and medical sciences, medical professionals (excluding nurses), practitioners in medicine, dental professionals, scientific researchers (dentistry), dentists, professionals in pharmacy, pharmacists, professionals in medical and preventive care, scientific researchers in medical and preventive care, other medical professionals (excluding nursing and midwifery), auxiliary personnel in modern medicine, physiotherapy, pharmacy (excluding nurses), medical assistants, dental assistants, physiotherapists and masseurs, pharmacists, and other assistants to professionals in modern medicine (excluding nurses).
• Professionals in pathology, toxicology, pharmacology, physiology, and epidemiology, pathologists, toxicologists, pharmacologists, physiologists, and epidemiologists, scientific researchers (medical practice), physicians, specialists in medical and preventive care, professional nurses and midwives, professionals in nursing and midwifery, nurses and midwives, hygienists, optometrists and opticians, nurse and midwife assistants to professionals, assistant midwifes.
• Medical equipment operators, workers servicing equipment in pharmaceutical and cosmetic product manufacturing, and healthcare department managers.

 

How can women register for military service?

The registration process for military service is conducted at the TCR.

The required documents are:

• Application for registration.
• Passport or ID card.
• Identification number.
• Document proving the specialty/profession (diploma).
• Notice from work indicating the specialty in which the woman is employed.
• Birth certificates of children or guardianship documents.
• Marriage certificate.
• 3x4 photographs.

 

When a woman comes to the TCR to register for military service, a personnel file is created for her.

She is then scheduled for a medical examination, which will determine her fitness or unfitness for military service. The medical examination for women subject to military service is similar to that of men. It includes examinations by a surgeon, therapist, neurologist, psychiatrist, ophthalmologist, otolaryngologist, dentist, dermatologist, and gynecologist, in addition to other general medical assessments.

 

Responsibilities for women on military registration

Women who are on military registration may be called up for military service or assigned to perform tasks related to the defense of the state during wartime. These women fulfill their military duty equally with men.

Women subject to military service have the same responsibilities as men. They must:

• Register for military service.
• Undergo military training.
• Notify the military recruitment office of changes in registration/residence, marital status, disability, etc.

 

The legislation does not differentiate between women and men subject to military service.

 

Are TCRRSS to be visited independently?

According to paragraph 51 of Resolution of the CMU No. 1487, women who have obtained education in medical or pharmaceutical specialties and have not been registered with the TCRRSS, or received a military registration document, can be employed as non-military service personnel until the end of 2026.

In doing so, employers who hire women with education in medical or pharmaceutical specialties and who are not on the military account must notify the respective TCRRSS about the employment of such women. The company made a decision to notify the TCRRSS about such women at the end of 2023.

Unemployed women come to the respective TCRRSS independently to register for military service.

 

Travel regulations for women after October 1, 2023

It should be noted that Ukrainian law does not differentiate between the genders of conscripts. According to the law, women who are fit for military service are subject to the same travel restrictions as men.

However, there have been objections from the State Border Guard Service on this matter. According to the spokesperson of this service, the fact that some women will become conscripts as of October 1 does not automatically mean that they will be prohibited from leaving Ukraine, as is the case for conscripted men.

Going abroad of women with medical and pharmaceutical specialties who have enlisted in the military is currently not restricted by the rules of crossing the state border. Currently, the restrictions only apply to men aged 18-60.

Since border guards currently lack the technical capability to verify information about women, who are on military registers, when they cross the border due to a lack of access to such information, and there are no requirements to present any additional documents other than a passport when crossing the border, these restrictions on the right to cross the border apply only to conscripted men aged 18-60.

As such, there are no changes regarding restrictions on the right of women, who are on the military accounts to travel abroad. In other words, regardless of their specialty, profession, being on the military accounts, or having the status of conscripts, women are allowed to cross the border.

Also, there are no grounds to require women to present diplomas at the border crossing point to prove their education.

Deputy Minister of Defense Hanna Maliar has previously stated that there is no need for compulsory mobilization of women in the Armed Forces of Ukraine, and there are no plans to impose restrictions on women's travel abroad. With her words, since the beginning of the full-scale war in Ukraine, no women have been forcibly mobilized, including since the start of the invasion in 2014. The only exception is women working in government positions during martial law.

There is also a presumption that restrictions on travel abroad will apply only to mobilized women and not to those, who are on the military accounts.

 

Travel restrictions for pregnant women and women with children under 3 years old

According to the law, exceptions include pregnant women and those on maternity leave. According to Article 73 of the disability schedule in accordance with the Regulations on the Military Medical Board, pregnant women are considered unfit for military service, regardless of the stage and progress of pregnancy.

Women who have been conscripted during mobilization have the right to be released from military service due to pregnancy (regardless of its stage and term) and due to being on maternity leave to care for a child until the child reaches the age of three. They also have the right to be released if the child requires home care for a duration specified in a medical certificate, but not exceeding the child's sixth birthday.

 

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Women eligible for military service and exemptions

Women with medical and pharmaceutical specialties, who are on the military accounts can be mobilized during wartime. However, there is a list of exceptions when such women are not allowed to be sent to the front.

According to the Law on Mobilization Training and Mobilization, the following categories are exempt from military service during mobilization:

1.	Reserved medical personnel. The reservation of conscripts involves granting them a temporary deferral from mobilization for a period of 6 months.
2.	Women, who have been temporarily declared unfit for military service by the Medical Board (VLK) due to health conditions for a period of up to six months.
3.	Mothers, who have dependents:
	Three or more children under the age of 18; A child with a disability of sub-group A under the age of 18; A child with a disability, who has any type of severe functional impairments (III-IV degree) and life activity limitations of any category (II-III degree), or a child with a disability, who has functional impairments and life activity limitations (criteria for determining disability); Adult children with disability of Group I or II until they reach the age of 23; Orphaned children or children deprived of parental care under the age of 18.
4.	Mothers, who are single-handedly raising a child (or children) under the age of 18.
5.	Engaged in the continuous care of individuals, who require it according to Ukrainian legislation, in the absence of other individuals, who can provide such care.
6.	Women, who are wives, daughters, or daughters-in-law of individuals with disabilities of Group I or II, provided that such disabled individuals do not have other able-bodied individuals, who could support them.
7.	Female students pursuing professional undergraduate and higher education, assistant interns, graduate students, and doctoral candidates studying in full-time or dual forms of education. (However, there is a legislative proposal to eliminate deferments from mobilization for individuals over the age of 30, who are pursuing non-consecutive higher education degrees.)
8.	Female scientific and scientific-pedagogical employees of higher educational institutions (HEIs), research institutions, and organizations, who hold academic titles and/or scientific degrees, as well as pedagogical staff of general secondary education institutions, with a primary employment workload of no less than 0.75 rate.
9.	Women, whose close relatives have died or gone missing in action in the areas of Anti-Terrorist Operation (ATO) and were:
	Military personnel or employees of military formations established by the laws of Ukraine, who participated in the defense of the state in the ATO areas; Employees of enterprises, institutions, or organizations that provided support for the ATO and died or went missing in the ATO areas; Members of voluntary formations that self-organized or were formed to defend the state and participated in the ATO.
10.	Women, who are already serving in military formations or law enforcement agencies.
11.	Women, who volunteered to assist military formations or law enforcement agencies in the ATO. These are women, who were not officially enlisted in the army or police, but still carried out ATO tasks in collaboration with them.

 

In case of additional questions or for detailed consultation regarding the military registration of women in Ukraine, please contact the experts at BDO in Ukraine.