During a special period, employees of the Territorial Recruitment and Social Support Centers (hereinafter – TRSSC) are authorized, for violations of military registration as well as violations of legislation on defense, mobilization training, and evasion of mobilization, to draw up reports and bring both individuals and legal entities to administrative liability under Articles 210, 210-1 of the Code of Ukraine on Administrative Offenses (hereinafter – CUAO).
According to Article 235 of the CUAO, cases of administrative offenses under Articles 210, 210-1, 211 of the CUAO are subject to review directly by TRSSC — based on the review, they issue a Resolution on the imposition of an administrative penalty.
Failure to appear at TRSSC upon summons is subject to a fine ranging from 17,000 to 25,000 UAH for the first offense. For individuals who failed to update their data on time, the TRSSC also has the authority to issue such resolutions and impose fines. However, citizens may still have grounds to appeal them.
Such fines may be appealed in court by filing a claim with reasoning regarding the illegality of the actions/decisions of TRSSC personnel. The subject of appeal is not the report, but the resolution on administrative liability in the form of a fine, issued based on the review of the report.
To determine all the circumstances of appealing TRSSC fines and the appropriateness of doing so in a particular case – please contact the lawyers in Kyiv of our Ukrainian law firm “First Legal.”
A person may learn about an already imposed fine and thus an opened enforcement proceeding when the enforcement service blocks bank accounts or collects the fine amount from the debtor’s accounts.
How to find out that a fine has been imposed on you?
You can find out about a TRSSC fine from three sources:
- Directly at the TRSSC during a visit;
- From the Unified State Register of Enforcement Proceedings;
- In the “Diia” app: in the “Services” section, “Enforcement Proceedings” tab.
To prevent collection of the fine from you, a claim to cancel the fine must be filed in court within 10 days from the date the resolution was issued.
If you learned about the resolution too late and cannot meet the ten-day appeal deadline, then along with the claim, you must submit a motion to the court to restore the appeal period, stating when you became aware of the resolution.
Can fines for violating military registration rules (failure to update data, etc.) be appealed?
Yes. To do this, a claim must be submitted to the court to recognize the resolution on the imposition of an administrative penalty (fine) as unlawful and to cancel it, indicating the reasons why the resolution being appealed is unlawful.
The time limit is 10 days from the date the resolution is issued.
A resolution on bringing a person to administrative liability is an official document — a decision of an authority based on the results of the review of an administrative offense case, which must clearly state the established facts and cite the legal provision that sets liability for the offense.
Compliance with these requirements is critical for establishing the objective truth when appealing such a resolution in court.
One of the grounds for successful appeal is non-compliance with procedural requirements (e.g., “in absentia” review, errors in the text, expiration of the time limit for imposing a fine, etc.).
A consultation with lawyers from “First Legal” will help you timely appeal TRSSC fines and protect your rights.
Grounds for cancellation of fines include:
- TRSSC’s non-compliance with the fine imposition procedure and/or improper notification — the person was not served a summons to appear at the TRSSC or it was served in violation of the established timeframes;
- Lack of convincing evidence of the offense committed by the citizen — the reason for the fine is not specified, the procedure for appeal is not explained, errors in personal data, etc.;
- Fines are imposed for a period when the new norms had not yet entered into force — this is grounds for cancellation.
A fine is imposed unlawfully if:
- The person is not subject to military registration: the citizen has legal grounds for exemption from registration (age, health, family circumstances, etc.), but TRSSC did not consider them.
- There were valid reasons for failure to appear at TRSSC: the person was undergoing medical treatment, on a business trip, fulfilling other important obligations — and can provide documentary proof.
- TRSSC employees made an error: incorrect information in the military ID or other documents became the reason for the fine.
- Improper actions by TRSSC: blackmail or threats — TRSSC personnel applied physical pressure, made threats, or demanded bribes.
- Discriminatory cases — the fine was imposed based on race, religion, political beliefs, or principles.
- Illegal seizure of documents — TRSSC staff seized documents without legal grounds.
General principle of TRSSC fine proceedings
The TRSSC must notify the person about the time and place of the administrative case review. According to Article 268 of the CUAO, the case must be reviewed in the presence of the person being held administratively liable and may be reviewed in their absence only if there is evidence that the person was duly notified and if no request for postponement was received.
Important! A summons to TRSSC, for example, for data clarification, does not qualify as notice within the administrative case proceeding.
In practice, TRSSC often forgets to notify the person or notifies them in such a way that the person does not actually receive the notice. Failure to notify the person about the date, time, and place of the hearing leads to violations of human rights, which, in turn, affects the legality of the decision.
As a result, we have a fine resolution that has every reason to be appealed.
As mentioned earlier, such a resolution must be appealed within 10 days from its issuance.
Courts react quite critically to violations of the notification procedure and cancel resolutions even in cases where the person is factually guilty.
That is, when TRSSC forgets to notify the person of the hearing, courts almost always side with the complainant and annul the unlawful resolutions.
For example, the Resolution of the Sixth Administrative Court of Appeal in case No. 754/9026/24 dated September 24, 2024, annulled the fines. A similar position was taken in the ruling of the Sokyriany District Court of Chernivtsi Region in case No. 722/161/25, where the court cancelled a fine of 17,000 UAH for a reservist who failed to appear at TRSSC after receiving a summons. The court ruled in favor of the claimant, and the decision entered into legal force.
Currently, there are many lawsuits for cancellation of TRSSC fines, with a very high rate of positive outcomes.
Risks of not appealing TRSSC fine resolutions
A TRSSC resolution on administrative liability may go unchallenged if the fine is paid. However, there is one very important aspect — criminal liability.
The Criminal Code of Ukraine contains articles also related to mobilization and conscription.
- Article 336 of the Criminal Code provides punishment for evading military service during mobilization, in a special period, or conscription from the reserve during a special period.
- Article 337 provides punishment for evading military registration by a conscript, reservist, or liable person after being warned by the relevant head of TRSSC, the Security Service of Ukraine, or the Foreign Intelligence Service of Ukraine. This article specifically refers to criminal liability after a warning issued by the TRSSC head.
Please note that on March 13, 2025, the Verkhovna Rada adopted draft law No. 12093 in its entirety, which proposes a 50% discount on fines for reservists who voluntarily pay penalties for violating military registration. This is stated in the bill’s card on the Parliament’s website; the bill has now been sent to the President of Ukraine for signature.
According to the adopted law, a reservist who is held administratively liable will have the opportunity to contact the authorized body and pay 50% of the imposed fine within 10 days. Instead of 17,000 UAH, they would pay only 8,500 UAH. This opportunity is available if the offender does not contest their guilt and agrees to administrative liability.
For more detailed legal advice on cancellation of TRSSC fines, we recommend contacting the professionals at “Persha Yuridychna”! Fill out the application form on the website right now or call one of the following numbers: +38 (044) 35-35-164; +38 (067) 306-89-89 +38; (063) 45-85-448; +38 (099) 367-89-89.