The Verkhovna Rada allowed short-term reservation of men without military registration

On October 9, 2025, the Verkhovna Rada of Ukraine adopted an important law allowing enterprises of the defense-industrial complex (DIC) and critically important enterprises to temporarily reserve for 45 days men who are wanted by Territorial Recruitment Centers (TRCs), or who do not have a military ID or are not on military records.

Key Points of the Legislative Changes
The adopted Bill No. 13335 concerns the organization of labor relations under martial law and addresses one of the real problems of defense production: the shortage of employees with “clean” military records. Until 2025, reservation (protection from mobilization) applied only to those liable for military service who had properly completed documents, were officially employed, clarified their data in military registers, and were not wanted by TRCs. Now DIC enterprises can immediately process short-term reservation even for those who have issues with military records or are wanted, regardless of the reasons.

Who and How Can Be Reserved
Reservation is possible for:

• all employees liable for military service in critically important and defense-industrial enterprises;
• those without a military ID;
• those with improperly completed military registration documents;
• those not on military records or who have not clarified personal data;
• those already wanted by TRCs (except for specific crimes such as evasion of service under Articles 336–337 of the Criminal Code).

Important: This reservation can be used only ONCE per year for a specific person, for a period of up to 45 days from employment. A probationary period is set—up to 45 days, during which the employee should resolve all military record issues, otherwise the employer may terminate employment.

Practical Motivation and Reform Challenges
The purpose of the law is to prevent the “shock” withdrawal of key specialists from DIC production due to technical procedures of military registration. The loss of essential staff threatened the halt of production or fulfillment of defense orders. Therefore, reservation can now be issued even for “problematic” employees.

Employers are given a chance to resolve employee documentation issues while they perform urgent work for the defense sector. This is a real step to support HR capacity in a wartime economy.

Legal Guarantees and Limitations
Temporary reservation does not release a person from liability for violating military registration rules—it only provides a “window” to normalize their status without risk of immediate conscription.
If, within 45 days, an employee fails to correct the violation (obtain/restore documents, register), they may be dismissed.
Previously, reservation for “problem” individuals was entirely impossible—these changes open access to a wider pool of candidates for the defense sector.

Who This Does NOT Apply To
The new procedure does not extend to all citizens. It is expressly prohibited for those against whom criminal proceedings have begun under Articles 336, 337 of the Criminal Code (evasion of mobilization, unauthorized leaving of service).

Potential Risks and Forecasts
The law partially legalizes staff shortages by the “semi-legal” involvement of employees without a full set of military documents.
There may be demand for “workarounds” for reservation among questionable candidates if employers ignore subsequent registration procedures.
However, the system limits abuse: the period is clearly fixed, the employer is responsible for timely notification and dismissal of unlegitimized staff.
For transparency, all data on temporary reservation and record-status changes must be recorded in relevant electronic registers, and decisions must be officially justified.

Conclusions
The Rada’s decision on temporary reservation of men without a military card or who are wanted is essentially an “emergency valve” for preserving the defense industry’s workforce during emergencies. The law balances national security interests and the needs of the state economy, creating a temporary “amnesty” with strict conditions.
Compliance with procedure, strict control over record requirements, and understanding among employer, employee, and state are key to the effective implementation of updated labor and mobilization rules.

Author: Ihor Yas’ko, Managing Partner, Law Firm “WINNER”, PhD in Law
If you have questions or problems regarding reservation, consult a professional.