Thousands of mobilization exemptions under review: What police are looking for at companies and TCRs
Law enforcement officers carried out several large-scale special operations to identify facts of abuse within Territorial Centres of Recruitment and Social Support (TRC and SS), including in the processing of mobilization exemptions and the adoption of decisions by military medical commissions (MMCs), as well as cases of possible illicit enrichment and false asset declarations by those who decided to profit from mobilisation evasion during the war.
To learn more about how illegal schemes are set up, who is involved in them, how already issued findings of MMCs are reviewed, and which companies are most often used to obtain fraudulent mobilization exemptions, Censor.NET contacted the National Police. Acting Head of the National Police Maksym Tsutskiridze agreed to answer Censor.NET’s questions, while noting that investigative actions are still ongoing and not everything can yet be disclosed.
— Maksym Serhiiovych, you recently stated that 76 heads of TCR and SS at various levels had been served notices of suspicion and that this work would continue. You also added that investigators were separately examining fraudulent mobilization exemption schemes and were currently looking into the circumstances surrounding the potentially unlawful mobilization exemption of nearly 2,500 persons liable for military service. In which regions have the most offences related to evasion of military service been identified to date?
— The largest numbers of such proceedings are in major industrial and border regions. There are more than 1,900 in the Dnipropetrovsk region, around 1,500 in Zakarpattia, and more than 1,000 each in the Volyn, Mykolaiv and Odesa regions. Significant numbers have also been recorded in the Lviv, Vinnytsia, Kharkiv and Sumy regions.
Overall, however, since martial law was imposed, National Police investigators have investigated more than 20,000 criminal proceedings involving evasion of conscription during mobilisation. In other words, this is not a problem confined to several regions: such proceedings exist in virtually every part of the country.
— Heads of TCR and SS at which particular level most often become the subjects of investigations, and under which articles of the Criminal Code?
— Around 80% of the TCR heads who come under our investigation are district-level officials. Overall, as I noted earlier, 76 heads of regional, district and municipal TCR have been served notices of suspicion.
The schemes they use vary. In some cases, they receive an undue advantage in exchange for a desired decision; in others, for influencing other officials. Some cases involve the unlawful issuance of military registration documents, changes to the Oberih database, fraudulent findings of unfitness for military service or subsequent departure abroad. We most often classify such acts as receipt of an undue advantage or abuse of influence under Articles 368 and 369-2. Some proceedings also involve Article 332, concerning the illegal transportation of persons across the state border. Depending on the specific legal classification, the maximum sentence may be up to 12 years’ imprisonment, in some cases accompanied by confiscation of property and disqualification from holding certain positions.
In cases related to mobilisation, everyone involved must be held accountable under the law. Responsibility cannot be placed solely on the person liable for military service who used the scheme. If officials or intermediaries facilitated an unlawful decision, their actions must likewise receive a legal assessment.
Incidentally, we recently discussed these issues — mobilisation, fraudulent military exemptions, AWOL and cooperation between the military and the police — at a meeting with Commander-in-Chief of the Armed Forces of Ukraine Mykhailo Drapatyi. This year alone, the police have received more than 1.5 million requests from TCR and SS to locate citizens evading conscription during mobilisation. This is an extensive joint effort that requires the continuous exchange of information and clear coordination among all those responsible for it. We likewise work together when we identify potential abuses by officials of TCR, MMCs or other bodies involved in mobilisation processes.
— Did you discuss how approaches to mobilisation should change?
— We primarily discussed matters where the work of the Armed Forces and the National Police directly intersects. These include locating persons liable for military service, exchanging information, responding to possible abuses during mobilisation activities and issues relating to AWOL.
— Have there been documented cases in which TCR officials acted as part of organised criminal groups together with civilian intermediaries?
— Yes, and such cases are not isolated. A scheme may involve several participants: those who negotiate, prepare documents, have access to registers or influence the decisions of other officials. They may include not only TCR employees but also members of MMCs, military personnel and civilian intermediaries.
For example, in the Rivne region, an official from a district TCR organised a criminal group that also included civilians. In exchange for money, they were to influence TCR officials to issue a military registration document stating that an individual was unfit for service and had been removed from the military register.
In the Kherson region, we documented another scheme: for $7,000 per person liable for military service, false information was entered into military registration documents and subsequently into the Oberih register. The scheme involved a TCR official, a senior officer, a TCR operator and an employee of an Administrative Services Centre.
When officials profit from unlawful decisions, we must look more broadly at where their assets came from, whether they correspond to their lawful income and whether any property was registered in the names of relatives or other individuals.
Just last Friday, as part of Operation Declarant, police officers in the regions, together with the State Bureau of Investigation (SBI) and the Specialised Defence Prosecutor’s Office, conducted more than 100 searches in cases involving possible illicit enrichment and false asset declarations. The subjects of the investigations include officials from higher education institutions, TCR and SS, MMCs, expert teams assessing individuals’ daily functioning, and other persons subject to asset declaration requirements.
We are examining the origins of their assets. For example, the head of a district TCR and SS in Bukovyna declared no cash savings at all in 2023, but reported holding $115,000 and $120,000 in cash in 2024 and 2025, respectively. More than $100,000 was seized from him during a search.
We are transferring the seized documents and materials to the National Agency on Corruption Prevention (NACP) for the relevant findings. After that, if sufficient grounds exist, decisions will be made on serving notices of suspicion and determining the subsequent fate of the unexplained assets. The police will publish detailed results of this work separately.
— Which sectors do the companies most frequently mentioned in case files concerning potentially unlawful mobilisation exemptions belong to?
— Most often, these are municipal enterprises of strategic importance to the economy and national security, as well as critical infrastructure companies, including those in the fuel and energy sector. Their status may provide lawful grounds for exempting employees from mobilisation.
As part of criminal proceedings, we are currently examining the circumstances surrounding the potentially unlawful mobilization exemption of nearly 2,500 persons liable for military service. One common scheme involves fictitious employment: a person is formally hired by a company authorised to secure mobilisation exemptions for its employees, even though the person does not actually work there. In some cases, intermediaries arrange this in exchange for money, or false information is entered into information systems and registers.
Such schemes undermine trust in the mobilization exemption mechanism itself. When someone buys themselves a position at a company solely to obtain a deferment, those who genuinely work there and are lawfully entitled to a mobilization exemption inevitably come under suspicion as well. It is therefore important for us not only to expose abuses but also to distinguish them clearly from the lawful mobilization exemption of people whose work the state genuinely needs.
— What will happen to persons liable for military service whose mobilization exemptions are found to be unlawful? Will they be mobilised immediately? And will they be held liable?
— If it is established that there were no lawful grounds for the exemption, the deferment is revoked. However, this does not mean that the person will automatically be mobilised the following day. They lose that particular ground for deferment and may subsequently be called up under the procedure prescribed by law.
Nor can liability be imposed automatically. We establish precisely how the person obtained the mobilization exemption, which documents they submitted, whether they participated in the illegal scheme, and who organised it. The issue of administrative or criminal liability is then determined based on the specific actions involved.
It is important to me that there be no oversimplified approach here: an unlawful mobilization exemption has been identified; therefore, the person liable for military service is automatically at fault. The investigation must establish the role of everyone involved: both the person who used the scheme and those who facilitated it in exchange for money.
— What percentage of the seized decisions issued by MMCs have investigators already reviewed in full?
— The Central MMC provides the final assessment of whether decisions by local MMCs are substantiated. Investigators seize medical records, examine the circumstances in which they were prepared and, where the evidence provides sufficient grounds, refer the decisions for review.
Overall, since the beginning of the full-scale invasion, 6,500 unlawful decisions by MMCs have been overturned. At the same time, the Central MMC upheld more than 25,600 decisions by local MMCs and ordered repeat medical examinations in more than 1,600 other cases without overturning the original decisions.
These figures clearly illustrate the fundamental principle: reviewing a decision does not necessarily mean overturning it. We must identify specific abuses, but we must also avoid affecting the lawful findings of people who genuinely have medical grounds for them.
— To verify this, do you engage experts to review the medical records, or does the person undergo another examination by an MMC?
— Investigators first seize the medical records: examination results, treatment records, the decision of the MMC itself, and everything on which that decision was based.
We then verify this information against other sources. For example, under a court order, we may obtain information from mobile network operators and establish where the person was actually located during the period when, according to the documents, they were supposed to be undergoing examination or treatment. We also cross-check the information against the electronic healthcare system to determine whether the person consulted doctors or underwent examinations, and which diagnoses and medical findings were recorded there.
If sufficient grounds exist, the decision of the MMC is referred for review. Following that review, the previous finding may be upheld or overturned, or a new one may be issued. If the investigation requires an additional assessment of the person’s health and the relevant procedural grounds exist, a panel forensic medical examination is ordered.
— How does the investigation ensure an individualised approach so that the lawful findings of people with genuine serious illnesses or injuries are not inadvertently overturned?
— Every decision by an MMC is reviewed individually, together with the medical records on which it was based. The mere fact that MMC’s finding has come to the attention of investigators does not mean that it is unlawful or must be overturned.
If a person genuinely has a serious illness or lasting effects from an injury, this is confirmed by their medical records. If the MMC’s decision was made in accordance with the prescribed procedure, there are no grounds for overturning it.
Liability must always be individual and evidence-based. This is a matter of principle for us: we must simultaneously protect the state from fraudulent diagnoses and protect people from the unjustified cancellation of lawful findings. Exposing specific abuses must not turn into a campaign against all MMCs or create a presumption that every finding of unfitness for military service was bought.
— You said that 6,500 decisions by MMCs have already been overturned. Which medical diagnoses were most frequently falsified in these overturned findings? How did these schemes operate?
— Most often, the manipulation involved musculoskeletal, cardiovascular and neurological conditions. There were also cases involving mental disorders and conditions affecting vision, hearing and internal organs. We examine not merely the diagnosis recorded on paper, but whether it is supported by actual examinations, treatment and medical data.
The schemes varied. In some cases, knowingly false information about a diagnosis was entered into medical records, on the basis of which a person was declared unfit for service. In others, medical documents containing fictitious diagnoses were produced in exchange for money. Members of MMCs, TCR employees and, in some cases, civilian intermediaries were involved in such schemes.
— Have people challenged the overturning of MMC findings or the actions of investigators in court?
— Yes, such cases do occur. People who disagree with decisions by the Central MMC apply to administrative courts and challenge them. This is their right and, ultimately, another mechanism for reviewing how well-founded the decision was.
At present, we have no information about final court rulings in these cases. According to the information available to us, however, there have been no cases in which the investigators’ actions themselves were challenged in such proceedings.
— Have you identified cases in which people with illnesses were unlawfully declared fit for service to effectively "replace" those for whom findings by MMCs had been fabricated?
— I would not link such cases to "replacement" unless that connection has been established by evidence. However, if we obtain information in a particular proceeding indicating that a person with a genuine illness or medical contraindications was groundlessly declared fit for service, we examine that as well: which documents formed the basis of the decision, who made it, and whether there were lawful grounds for doing so.
The principle applied by the investigation does not change depending on the direction in which a potentially unlawful decision was made. We must establish the facts and provide a legal assessment of the actions of those involved.
— Ombudsman Dmytro Lubinets has repeatedly spoken about violations of citizens’ rights during mobilisation activities. Has he referred such cases to the National Police? Which actions by TCR employees most frequently become the subject of investigations?
— We consider all submissions from the Ukrainian Parliament Commissioner for Human Rights and his representatives and maintain constant cooperation with them. If a report contains information indicating a possible criminal offence, the police respond in accordance with the procedure established by law.
For example, last Thursday, following a report from Dmytro Lubinets, police investigators in the Zakarpattia region opened two criminal proceedings concerning officials of the Berehove District TCR and SS. The cases involve possible unauthorised interference with information and communications systems and abuse of office under Part 5 of Article 361 and Part 1 of Article 364 of the Criminal Code of Ukraine.
Generally speaking, among the most common proceedings involving TCR employees are those concerning possible unlawful deprivation of liberty or abduction. There are also proceedings concerning bodily injuries inflicted on citizens during mobilisation activities.
In every such case, we establish exactly what happened: the circumstances in which the conflict arose, the actions taken by those involved, whether force was used, whether there were lawful grounds for its use and what injuries the person sustained.
My position here is simple: holding a particular position does not confer immunity from liability. At the same time, guilt cannot be determined solely from a video posted on social media or from the mere fact that a conflict occurred. The investigation must establish the circumstances and collect evidence.
Tetiana Bodnia, "Censor.NET"
