Increase in Fines on Employers for Failure to Perform Military Registration Duties

Dear clients,

We would like to inform you that the Russian State Duma is now considering amendments to the Russian Code of Administrative Offenses. The amendments provide for a significant increase in the fines for failure to perform the military registration duties. Below you will find the current fines and the new fines provided for in the draft law that is proposed for the second reading. The new fines are planned to take effect October 1, 2023.

No.	Offense	Current fines	New fines
1	Failure to provide, or untimely provision of, details necessary for keeping military registration records (Article 21.4 of the Russian Code of Administrative Offenses)	The general director may be subject to administrative liability in the form of a fine of RUB 1,000 to RUB 5,000	The general director may be subject to administrative liability in the form of a fine of RUB 40,000 to RUB 50,000
2	Failure to provide lists of persons who are subject to initial military registration (Article 21.1 of the Russian Code of Administrative Offenses)	The general director may be subject to administrative liability in the form of a fine of RUB 1,000 to RUB 3,000	The general director may be subject to administrative liability in the form of a fine of RUB 40,000 to RUB 50,000, and the company, in the form of a fine of RUB 350,000 to RUB 400,000
3	Failure to notify persons of their being called (a summons) by the military commissariat or another authority in charge of military registration upon receipt of such calls (summonses), including in electronic form, or failure to enable persons to timely appear on a call (a summons) by the military commissariat or another authority in charge of military registration (Article 21.2 of the Russian Code of Administrative Offenses);	The general director may be subject to administrative liability in the form of a fine of RUB 1,000 to RUB 3,000	The general director may be subject to administrative liability in the form of a fine of RUB 40,000 to RUB 50,000, and the company, in the form of a fine of RUB 350,000 to RUB 400,000
4	A new Article 19.38 has been added to the Russian Code of Administrative Offenses: Failure to perform the duty to ensure the timely notification and arrival of persons who are subject to call-up for military service on mobilization at rallying points or military units, or failure to provide assistance in arranging for such notification or arrival. This article is similar to Article 21.2 of the Russian Code of Administrative Offenses. We believe that this article is special and will apply where persons are called up on mobilization and are required to report to rally points or military units.	–	The general director may be subject to administrative liability in the form of a fine of RUB 60,000 to RUB 80,000, and the company, in the form of a fine of RUB 400,000 to RUB 500,000

This draft law is now nearing its second reading and has not been finalized yet. The draft law may have its second and third reading (final) this week. When the draft law passes through the Russian State Duma, it must be approved by the Russian Federation Council, signed by the Russian President, and then published.

If you have any questions or need any further assistance, please send an email to Alexandra Yudina.

Sincerely,

Forte Tax & Law Team