Violation of Military Registration Rules: Does the “Reserv+” System Work for Paying Fines?

In April 2025 the President of Ukraine signed Law No. 12093, which introduced a new Article 279-9 to the Code of Ukraine on Administrative Offenses. This article allows for consideration of cases regarding military registration violations without the individual’s presence, if they agree to it. The law came into force on April 17. However, despite appearing to be a progressive mechanism, its practical implementation remains problematic.

What Does the New Procedure Entail?

Article 279-9 of the Code of Administrative Offenses allows individuals who have violated military registration rules or mobilization legislation (Articles 210 or 210-1) to submit a request and agree to a fine without personal attendance. This is possible if the individual:

• acknowledges the offense;
• agrees to the imposition of a fine without personal presence;
• submits a written or electronic application to the TCR (Territorial Center of Recruitment and Social Support), the Security Service of Ukraine or the Foreign Intelligence Service (depending on where they are registered).

This application may be submitted:

• in person in writing, or
• via the electronic portal, i.e., through the “Reserv+” system.

After receiving the application, an authorized official must issue a resolution and impose the minimum fine within three days. If the application was submitted through the electronic portal, the resolution may also be sent electronically.

Why the Mechanism Does Not Work Properly?

Despite the presence of this mechanism, its full implementation is currently not possible.

• The Electronic Portal Does Not Allow Submissions for All Violations

Although the law explicitly allows submission of the application via “Reserv+”, this feature currently works only for certain violations. Currently, users can pay fines for failure to update their information before July 16, 2024.

When it comes to submitting applications or agreeing to fines for other violations, such as failure to appear upon summons, this option is still being tested.

• TCRs Do Not Accept Mailed Applications

Another method of submitting the application is in written form by mail. However, in practice, TCRs refuse to process such mailed applications and demand in-person attendance. Yet the law clearly states that the procedure should work without the individual’s physical presence.

As a result, a mechanism that was supposed to simplify case review and ease the administrative burden is currently not fully operational. It depends entirely on when the required technical capabilities become available and whether the authorities are truly prepared to implement it.

Case Law: Can Remote Applications Be Rejected?

In this context, the legal position of the Seventh Administrative Court of Appeal is noteworthy. In its ruling dated July 4, 2024, in case No. 120/476/24, the court clearly stated: “the obligation to ‘personally inform’ is not the same as the obligation to ‘personally appear’”.

This is an important stance, as it means TCRs cannot force conscripts to appear in person when the law permits remote submission in written or electronic form.

Additional Requirements for Fine Resolutions

Particular attention should be paid to Part 5 of Article 283 of the Code of Administrative Offenses, which adds further requirements to the resolution on fine imposition. In addition to the mandatory data, the resolution must include:

• the date and method of application submission;
• its content;
• payment details;
• information on how the resolution is to be executed: at least 50% of the amount must be paid within 10 days after the resolution enters into force.

Conclusion

Despite the progressive idea of simplifying minor case reviews, the mechanism is not yet fully functional. To make it work effectively, the following are necessary:

• an update of “Reserv+” to enable submission of applications for any violation of military registration or mobilization laws;
• clarification from the Ministry of Defense and other responsible bodies regarding the acceptability of applications sent by mail or electronically;
• a change in the enforcement practices of TCRs to align with the court’s position on the right to submit applications and pay fines remotely.

Only under these conditions can the new mechanism become an effective and functional tool.