In the second half of 2025, the business community is actively discussing “joint inspections” — as of July, Ukraine has expanded the authority of commissions to check the status of military registration at enterprises. New legislative changes have given rise to rumors and myths about whether tax inspectors, labor inspectors, and representatives of the Territorial Recruitment Centers (TRC) now come to offices together and operate as a “single front.” Our legal analysis provides a detailed answer, based on the law and honest business practice.

Legislative background: regulations and changes
From July 23, 2025, the new provisions of the Cabinet of Ministers Resolution No. 1487 (as amended by No. 892 dated 16.07.2025) entered into force, regulating the inspections of military registration. The commissions responsible for such inspections officially include representatives of:

• Territorial Recruitment Centers (TRC),
• interregional bodies of the State Labor Service,
• territorial bodies of the State Tax Service.

Key point: What does a joint inspection actually mean?
Although from now on the State Labor Service and the State Tax Service are officially part of the military registration inspection commissions, this does NOT require their physical presence together with the TRC during an on-site inspection. In practice, inspections are carried out as follows:

• The TRC is the main inspecting authority that initiates and conducts the onsite inspection;
• The State Labor Service and the Tax Service may participate in the commission (providing materials, consultations, remote monitoring, sending requests, initiating their separate inspections), but are not necessarily present together with the TRC representatives at the company.

What do the different agencies cover?

• The TRC checks compliance with military registration obligations: maintaining records and journals, appointing responsible persons, having schedules, lists of conscripts, timely notification of changes in personnel, etc.
• The State Labor Service is concerned with the proper formalization of labor relations, correct payment of wages, use of civil contracts instead of employment contracts, etc. Special attention is paid to hidden labor relations (e.g., people operating as sole proprietors or those who actually perform work under formal contracts).
• The Tax Service can check tax compliance concerning payments to employees, the grounds for people’s presence at a company, compare information with databases on sole proprietors, contractors, etc.

Why did the commission form arise?
The TRC does not have direct authority to inspect business relations or documents related to sole proprietorship/civil contracts. Therefore, the tax and labor authorities were included in the commission for effective detection of hidden workers or formal circumvention of military registration.

What does this mean for business?
The presence of a “commission” does not always mean mass “raids.” In most cases, the involvement of the authorities is formal, and interaction occurs via information exchange or sending inquiries.
The grounds for on-site inspections are strictly regulated: there must be an official notice and inclusion in the plan (for scheduled inspections, a 10-day notice is required). Unscheduled inspections happen in case of booking, mobilization orders, complaints, etc.
During an on-site visit, the TRC may demand documents related to military registration. Materials related to labor or business relations (for example, civil contracts, acts of completed work) may be requested separately by the State Labor Service or the Tax Service, not necessarily on the day of the main inspection.

Practice in 2025: inspection realities
According to accounting and HR portals, the number of “simultaneous” site visits by all three authorities is an exception, not the rule. The prevailing scheme: the company receives a letter about the military registration inspection, the TRC conducts the visit or document inspection, and the State Labor and Tax authorities may join separately, based on information from the TRC or their own analysis.

Moratorium and inspections: exceptions and risks
The 2025 moratorium on “unsubstantiated” inspections does not apply to measures related to:

• military registration,
• mobilization issues,
• areas of high risk.

The State Labor Service and Tax Service may join the process if they find signs of violations (such as unregistered workers or the evasion of military registration).

Legal advice for business

• Streamline your internal military registration documentation in advance.
• Don’t assume that contracting with individuals (civil contracts or sole proprietors) automatically exempts you from scrutiny — these relationships are under close attention.
• During inspections, record all inspector actions and consult a lawyer in case of questionable or disputable requests.
• Do not sign any acts without a careful analysis of the consequences; avoid “compromises” that may lead to double fines.

Conclusions
The State Labor Service and the Tax Service are indeed included in the commissions for checking military registration status along with the TRC. However, the actual physical presence of all representatives at the company is not mandatory — cooperation is often conducted through information exchange, requests, or remote participation.
The main focus of all agencies is on compliance with military registration requirements and preventing abuses involving unofficial labor relations/civil contracts.
Every employer must be prepared for inspection and act within the law, following the recommendations of qualified lawyers.

This material is based on an overview of Ukrainian legislative and practical matters as of July 2025.

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