Automation of the register of persons liable for military service in 2025: how changes in access to personal data will affect privacy and mobilization

One of the most hotly debated topics in Ukrainian society in autumn 2025 is the new powers of territorial recruitment centers (TRC; formerly military commissariats) regarding access to citizens’ personal data. Legislative changes envisage the creation and maintenance of the Unified State Register of Persons Liable for Military Service, which integrates personal data from key government databases. This step is presented as part of the digital reform of record-keeping to ensure transparency of mobilization procedures, yet it also raises many ethical, legal, and social concerns about privacy protection.

What Data Will Be Accessible to TRCs
From now on, TRCs receive technical access to integrated information about every man liable for military service aged 25 to 60. This includes:

• demographic data (full name, date of birth, personal identification code, photo);
• registered and actual place of residence;
• marital status and presence of children;
• information from the civil status registry;
• information from the Ministry of Interior, State Migration Service, and Pension Fund;
• tax data, border crossing records, and records of postponements.

Current legislation still restricts uncontrolled access to medical records, but if such data are related to military records — integration is possible. Full data collection will involve inter-agency cooperation and electronic document exchange.

Technical Integration and the “No Direct Citizen Involvement” Principle
As of 2025, the Unified Register operates as an interdepartmental platform. Data are integrated without the citizen’s direct involvement; military data are updated automatically per TRC requests. As a result, outdated or intentionally inaccurate information about place of residence, marital status, or border crossings will no longer hinder record updates or service of call-up notices.

Government Motivation and Official Reasoning
The rationale is to simplify and accelerate identification of persons liable for military service, enhance fairness and control of mobilization law compliance. Official statements claim automation ensures:

• rapid identification of those with postponement or exemption grounds;
• fair distribution of mobilization burden;
• combating fictitious border crossings or forged certificates.

Refusal to provide or update personal information may lead to administrative liability: fines for “concealment” or untimely updates are already provided by current regulations.

Potential Risks and Public Response
Digitalization provokes understandable concerns among rights activists and the general public:

• risks of privacy breaches and data leaks;
• unlimited database integration (multiple access, “extended checks”);
• absence of robust procedures protecting against technical failures or unauthorized data use.

There are additional concerns about TRC access to sensitive medical data, use of data for family profiling, precision tracking of citizens’ locations, and rapid service of call-up notices irrespective of actual circumstances.

Practical Effect for Persons Liable for Military Service
Now, each such citizen must promptly update their data using their electronic cabinet (“Reserve+”). Any changes in residence, marital status, education, or contact details are automatically forwarded to the TRC register. Automated services monitor data accuracy, and discrepancies may result in requests for updates or fines.

The Ministry of Defense stresses the registry launch does not mean automatic mass mobilization, but does allow for rapid identification of evaders, while citizens themselves can receive fines and appeal them directly via the app.

Balance Shifts and Future Prospects
Human rights, transparency of administration, and the right to appeal TRC actions remain crucial issues for the new legislative format. Officials promise open verification algorithms, data encryption, and gradual inclusion of civic oversight, though these measures are not yet comprehensive.

The newly adopted tools will be tested in real re-registration campaigns through the end of 2025. It is expected that practice will expose new “weak points” in balancing national security and citizens’ privacy.

Author: Ihor Yasko, Managing Partner of “WINNER” Law Firm, PhD in Law.

If you have any questions or concerns related to TRC actions, feel free to seek professional advice.