In accordance with the provisions of the Law of Ukraine No. 3621-IX , which introduced significant changes to the issues of social protection of military personnel, and separately introduced mandatory rules for all those who were recognized as “limitedly fit” before the adoption of this law on mandatory re-passing of the VLK by June 5, 2025 .
Previously, this deadline was different, June 5, 20205 is an extended deadline and at the same time defined as the final deadline for undergoing a repeated medical examination by “limitedly fit” categories of citizens.
Who was this duty directed to?
According to the Final and Transitional Provisions of the Law, citizens of Ukraine aged 25 to 60 who, before the entry into force of this document, were recognized as “limitedly fit for military service, namely, not fit in peacetime and partially fit in wartime” for military service, were obliged to independently apply to the territorial recruitment and social support centers (TCK and SP) to receive a referral to undergo a military medical commission.
The purpose of such changes was to solve the acute problem of the distribution of “limitedly fit” for service due to the inaccuracy of the legislation, because limitedly fit “in the old way” could serve on the front line, simply not being in a position in the highly mobile troops of the Ukrainian Armed Forces, the Marine Corps, and others. Therefore, after receiving a referral to a military medical commission (VLK) to determine actual fitness for service, the person had up to 14 days (including referrals for additional examinations) to meet all medical specialists of the military medical commission. The deadline for fulfilling this obligation was set at June 5, 2025 .
Why is June 5, 2026 a critical date?
Although the obligation to pass the medical commission for “limited fitness” and fully complete the procedure for re-examination was established by June 5, 2025, the liability of those who ignored this requirement or failed to comply for any other reason expires only on June 5, 2026. After all, under current legislation, the duration of the term for imposing an administrative penalty, in accordance with the norms of Article 38 of the Code of Administrative Offenses , cannot exceed 1 year from the date of committing the offense, even if it was discovered only now or will be discovered in the future.
That is, since the obligation to undergo a VLK was to be fulfilled by June 5, 2025 inclusive, from June 6, 2025, persons who did not appear for the inspection actually became violators, for whom the CCC and SP had 3 months from the moment of detection but no later than 1 year from the moment of commission. Thus:
- The one-year period during which the state had the right to hold such individuals administratively liable (impose a fine) expires on June 5, 2026 .
- After this date, prosecution for this specific violation (untimely passing a repeated VLK under Law No. 3621-IX) becomes legally impossible due to the expiration of administrative deadlines. All cases where no person was prosecuted for this offense are subject to compulsory closure upon expiration of the deadline.
Important clarifications
It is worth remembering that you did not have to wait for a summons to be sent to you or for a referral to be issued in person, because Law No. 3621-IX clearly defined the algorithm of actions for those liable for military service and reservists: they had to independently contact the CCC at their place of registration or create an electronic referral to the VLK independently through the electronic account in the Rezerv+ application .
It should be noted that the expiration of the term for prosecution for “untimely” passing the military service does not exempt a citizen from the general obligation to comply with the rules of military registration and requirements for passing the military service according to Order No. 402 in the future.
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