Fines for failing to undergo a medical examination after 6 June may be challenged in court

This is reported by the “Judicial and Legal Gazette”. Law No. 3621-IX requires citizens aged between 25 and 60 who were previously classified as ‘partially fit for service’ to undergo a repeat medical examination by 5 June 2025, with the exception of those with disabilities.

In Ukraine, after 6 June 2026, the practice of imposing fines for failure to undergo a repeat military medical examination for those previously classified as “partially fit” may change.

This applies to citizens aged between 25 and 60 who, prior to the legislative changes, had the status of “limitedly fit for military service” and were required to undergo a repeat medical examination.

This obligation arose following the entry into force of Law No. 3621-IX, which effectively removed the “limitedly fit” status from the military medical examination system. The law provided for a re-examination of such individuals to determine their fitness for service under the new criteria.

Initially, the Ministry of Defence explained that the repeat medical examination must be completed by 4 February 2025. The deadline was subsequently extended to 5 June 2025.

Who is affected

The specific requirement applied to those citizens who had previously been deemed partially fit for military service.

The exception is people who have officially recognised disability status.

For this category, the obligation to undergo a repeat medical examination arose not only following a summons or referral from the Military Registration and Enlistment Office, but directly on the basis of the law.

This is precisely why lawyers distinguish between two separate situations: failure to undergo the medical examination on one’s own initiative by the set deadline, and failure to undergo the medical examination after receiving a lawful referral from the Military Registration and Enlistment Office.

Why 6 June 2026 is an important date

The deadline for undergoing a repeat medical examination expired on 5 June 2025.

If the violation is deemed to have ended on 6 June 2025, the limitation period for bringing administrative proceedings begins to run.

Under Article 38 of the Code of Administrative Offences, during a special period, an administrative penalty for breaching military registration rules may be imposed no later than one year from the date of the offence.

In other words, by this logic, the deadline for imposing a fine expired on 6 June 2026.

That is why, after this date, fines imposed on a former ‘partially fit’ person for failing to initiate a repeat medical examination by 5 June 2025 may be subject to appeal.

Important: not all fines are automatically unlawful

This does not mean that any fine for failing to undergo a medical examination after 6 June 2026 is automatically unlawful.

Lawyers point out the difference between two scenarios.

The first situation is where a person did not initiate a repeat medical examination as a former “partially fit” individual by 5 June 2025. It is in this specific case that the one-year limitation period for bringing proceedings may have expired.

The second scenario is where the Military Registration and Enlistment Office issues a person with a valid referral for a medical examination now, but they fail to attend. In this case, the obligation to undergo the medical examination arises from the new referral, and the risk of liability may remain.

Lawyers also emphasise: the TCC cannot impose a fine specifically for a lack of independent initiative after the limitation period has expired, but a referral to the VLC under the general procedure remains a valid mechanism.

What case law may decide

The final interpretation of this situation will depend on the practice of the TCC, the bodies hearing administrative cases, and the courts.

The key issue will be how the courts determine the nature of the violation: whether it was completed on 6 June 2025 or is ongoing.

If the court concludes that the violation was completed after the deadline expired, fines imposed after 6 June 2026 may be quashed due to the expiry of the limitation period for bringing proceedings.

If, however, certain authorities interpret failure to undergo the medical examination as an ongoing violation, this could become the subject of new disputes between conscripts and the Military Registration and Enlistment Offices.

What conscripts need to know

After 6 June 2026, those previously classified as ‘limitedly fit’ may challenge fines for failing to undergo a repeat medical examination on their own initiative by 5 June 2025.

However, this does not exempt them from the obligation to undergo the medical examination if there is a lawful referral from the Military Registration and Enlistment Office and the Military Commissariat.

Furthermore, this does not automatically apply to other breaches of military registration rules if they occurred later or have other legal grounds.

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