How to appeal against a fine imposed by the TCC for failing to update data in a timely manner
Contents
- What offences are punishable and what are the fines
- How to appeal against TCC fines
- What are the most common grounds for overturning decisions
- Is the so-called ‘search’ subject to appeal
Updated rules on mobilisation procedures and military registration are now in force in Ukraine. The new regulatory framework has also shaped new case law in disputes concerning fines imposed by territorial recruitment and social support centres.
Which offences are subject to penalties and what are the amounts of the fines
The main legislative acts in this area are the Law of Ukraine ‘On Mobilisation Preparation and Mobilisation’, the Law of Ukraine ‘On Military Duty and Military Service’, and Resolution No. 560 of the Cabinet of Ministers of Ukraine dated 16 May 2024.
For violations of military registration rules by conscripts, persons liable for military service and reservists, Article 210 of the Code of Administrative Offences provides for a fine of between 3,400 UAH and 5,100 UAH. For a repeat offence within a year, the fine ranges from 5,100 UAH to 8,500 UAH. During a special period, a fine of between 17,000 UAH and 25,500 UAH applies.
For violations of legislation on defence, mobilisation preparation and mobilisation, Article 210-1 of the Code of Administrative Offences provides for a fine for citizens ranging from 5,100 UAH to 8,500 UAH. For a repeat offence within a year, the amount increases to 8,500–11,900 UAH. During a special period, the fine also ranges from 17,000 UAH to 25,500 UAH.
The special period in Ukraine began on 17 March 2014 in accordance with the Decree of the President of Ukraine ‘On Partial Mobilisation’. Therefore, fines for violations of Articles 210 and 210-1 of the Code of Administrative Offences can currently range from 17,000 UAH to 25,500 UAH.
The most common grounds for such fines are
- failure to verify details,
- failure to report for duty at the Territorial Recruitment Centre and the Military Registration and Enlistment Office,
- failure to complete military registration documents
- failure to undergo a medical examination.
How to appeal against TCC fines
The decision to impose a fine comes into force after 10 days if it has not been appealed in court. If the fine is not paid voluntarily within 30 days of the decision coming into force, the TCC and SP may refer the matter to the State Enforcement Service. In such a case, the fine will have to be paid at double the amount.
A decision by the head of the TCC and SP may be appealed to the district, city district, city or municipal court at the person’s registered place of residence or at the location of the TCC and SP, in accordance with the Code of Ukraine on Administrative Offences.
The time limit for appeal is 10 days from the date the decision was issued. If a person received the decision significantly later, they may ask the court to extend this time limit. A court fee of 0.2 times the minimum subsistence level for an able-bodied person is payable for filing a claim to overturn the decision. In 2026, this amounts to 665.60 UAH.
What are the most common grounds for overturning decisions
One of the common grounds for overturning a fine is the hearing of the case without properly notifying the person of the date, time and place of the hearing. In Case No. 363/2523/25, the TCC and SP argued that the person had been sent a summons to clarify their details. As they failed to appear, the fine was imposed in their absence.
The court of first instance upheld the decision of the TCC and SP. However, the Sixth Administrative Court of Appeal, in its ruling of 20 August 2025, stated that failure to receive a summons and failure to be notified of the place and time of the hearing are distinct legal mechanisms. As there was no evidence of proper notification regarding the hearing, the decision was overturned and the proceedings were closed.
Another ground for annulment relates to the possibility of obtaining personal data from state registers. In Case No. 725/4651/25, a conscript challenged a fine of 17,000 UAH for failing to appear at the TCC and SP in response to a summons.
The court noted that the content of the report and the decision differed. The report referred to the failure to update data in a timely manner, whilst the decision referred to failure to appear in response to a summons. The main ground for the annulment was that the decision did not contain evidence of the impossibility of obtaining personal data through electronic interaction with other state registers and databases.
The Code of Administrative Offences provides that Articles 210 and 210-1 do not apply if personal data can be obtained through electronic interaction with other information systems, registers or databases of state bodies.
Courts also overturn decisions if they do not specify the period for which personal data has not been updated or exactly which data has not been updated. In case No. 759/16450/25, the court found that the report contained only a general reference to the failure to update registration details. It did not specify which particular data had not been updated, in particular the residential address, contact numbers, email address or other personal data. The decision was overturned.
Is the so-called ‘search’ subject to appeal?
A distinction must be made between appealing a decision by the TCC and SP and a situation where a message appears in ‘Reserve+’ stating: ‘The TCC and SP have requested the National Police to bring you in to draw up a report’. In such cases, there is no decision or fine yet, so there is effectively nothing to appeal against.
This procedure is carried out on the basis of Article 259 of the Code of Administrative Offences. It allows the offender to be taken to the territorial recruitment and social support centre to draw up a report on the administrative offence.
In such a situation, you may apply to the TCC and SP to have the administrative offence case closed if the time limits for bringing proceedings have expired. This refers to three months from the date the offence was detected and one year from the date it was committed.
The grounds for the TCS&SS to have fines overturned in court usually relate either to a procedural irregularity or to the substance of the decision itself. In some cases, the decision can only be overturned after an appeal to the court of appeal.
