2025 financial declaration campaign for military personnel: who must submit declarations

Commencing 1 January 2025, the annual submission period for 2024 declarations has been initiated. Pursuant to the Law of Ukraine ‘On Prevention of Corruption,’ individuals authorized to perform state or local government functions are required to file their declarations by 1 April 2025 via the official website of the National Agency on Corruption Prevention (NACP). 

It should be noted that during the period of martial law, specific categories of military personnel are exempt from the obligation to file declarations. In particular:

• military officials serving under contract, including personnel of rank-and-file, non-commissioned, and junior officer ranks;
• mobilized military personnel, reservists, and conscripted officers;
• personnel in social services, healthcare, education, science, culture, and sports sectors (excluding leadership positions).

Military personnel of the Armed Forces of Ukraine, including senior and higher-ranking officers, subject to declaration requirements, are obligated to submit their declarations within 90 days following the termination of martial law or upon discharge from military service.

However, specific categories of military personnel and civil servants within the Ministry of Defense's jurisdiction are required to submit declarations annually, even during the period of martial law.

Categories of military personnel required to submit annual declarations:

• ministers and their deputies;
• military personnel assigned to the apparatus of the Ministry of Defence (including those on temporary secondment);
• members of military medical commissions and flight medical commissions (including those on temporary secondment);
• military personnel of Territorial Recruitment and Social Support Centers (TRSSCs), except for enlisted personnel in guard units;
• individuals involved in procuring goods, works, and services for defense purposes or responsible for quality control of such procurements.

Colonel of Justice Serhii Stepanian, Acting Head of the Ministry of Defence’s Department for the Prevention and Detection of Corruption, emphasized that a deferral for submitting declarations is currently in effect for AFU personnel. However, the law clearly delineates specific categories of military personnel required to submit declarations annually, even during martial law (see infographic).