Seventy-six Suspicions Against Military Commissars and One and a Half Million Search Requests in a Major National Police Report on Mobilization Schemes

Law enforcement carried out several large-scale special operations in succession to uncover abuses in the activities of regional and district enlistment and mobilization centers (TCKs and SPs), in particular during the issuance of reservations and the decisions of military-medical commissions (VLCs), as well as to detect possible illegal enrichment and false asset declarations by those who, during the war, sought to profit from evading mobilization.

To learn in more detail how illegal schemes are structured, who is involved, how already completed VLC conclusions are checked, and which enterprises are most often used for fictitious reservations, we contacted the National Police. Acting Head of the National Police Maksym Tsutskiridze agreed to answer questions from the publication “Censor.NET,” but noted that investigative actions are still underway and not everything can be discussed.

— Maksym Serhiyovych, you recently said that suspicions have been notified 76 to TCK and SP leaders of various levels and that this work will continue. You also added that separately investigators are working on fictitious reservation schemes and are currently checking the circumstances of possible illegal reservation of almost 2,5 thousand conscripts. In which regions have the most offenses related to draft evasion been identified so far?

— We have the most such proceedings in large industrial and border regions. In Dnipropetrovsk region there are more than 1,9 thousand, in Zakarpattia — about 1,5 thousand, and more than a thousand in Volyn, Mykolaiv region and Odesa region. There are also significant numbers in Lviv, Vinnytsia, Kharkiv and Sumy regions.

But overall, during martial law the National Police investigators have investigated more than 20 thousand criminal proceedings related to draft evasion. So this is not a problem of just a few regions — such proceedings exist virtually across the whole country.

— Leaders of TCKs and SPs of which specific levels most often become subjects of investigations and under which articles of the Criminal Code?

— About 80% of the TCK leaders who fall into the scope of our investigations are at the district level. Overall, as I noted earlier, suspicions have been notified to 76 leaders of TCKs at the regional, district and city levels.

The schemes they use vary: in some cases they take unlawful payments for a desired decision, in others — for influence on other officials, in others it involves illegal issuance of military registration documents, changes in the “Oberih” database, fictitious unfitness, or facilitating subsequent travel abroad. Most often we qualify such actions as receiving unlawful benefit or abuse of influence — articles 368 and 369-2. In certain proceedings there is also article 332 — illegal crossing of the state border. Depending on the specific qualification, the maximum punishment can reach 12 years imprisonment, in some cases with confiscation of property and a ban on holding certain positions.

In cases related to mobilization, everyone involved must be held legally accountable. You cannot shift all responsibility onto the conscript who used the scheme. If illegal decisions were provided by officials or intermediaries, their actions must also receive legal assessment.

By the way, we recently discussed these issues — mobilization, fictitious reservation, SZZ [special registration questions] and interaction between the military and the police — at a meeting with Commander-in-Chief of the Armed Forces Mykhailo Drapatyi. Just during this year, TCKs and SPs sent the police more than one and a half million requests to locate citizens evading the draft. This is a large joint effort, where constant information exchange and clear interaction among all responsible parties are important. We also work together when we detect possible abuses by TCK officials, VLC members or other structures involved in mobilization processes.

— Did you discuss how approaches to mobilization should change?

— We talked primarily about issues where the work of the Armed Forces and the National Police directly intersect. That includes locating conscripts, exchanging information, responding to possible abuses during mobilization activities, and questions of SZZ.

— Have there been recorded cases where TCK officials acted as part of organized criminal groups together with civilian intermediaries?

— Yes, such cases are not isolated. Several participants can be involved in a scheme — those who arrange the deals, prepare documents, have access to registries or influence the decisions of other officials. Among them may be not only TCK employees, but VLC members, servicemen and civilian intermediaries.

For example, in Rivne region an official of a district TCK was the organizer of a criminal group that included civilians. For money they were supposed to influence TCK officials to issue a military registration document with a mark of unfitness for service and to remove the person from military records.

In Kherson region we documented another scheme: for 7 thousand dollars from each conscript false information was entered into military registration documents and then into the “Oberih” registry. The scheme involved a TCK official, a senior officer, a TCK operator and a CNAP employee.

If illegal decisions generate profit, we need to look more broadly — where the official's assets came from, whether they correspond to his lawful income, and whether property was registered to relatives or other persons.

Just on Friday, within the operation “Declarant,” police in the regions together with the State Bureau of Investigation (DBR) and the Specialized Prosecutor's Office for Defense conducted more than a hundred searches on suspicion of possible illegal enrichment and false declarations. Among the suspects were officials of higher education institutions, TCKs and SPs, VLCs, assessment expert teams for everyday functioning of a person and other declarants.

We are checking the origin of their assets. For example, the head of a district TCK and SP in Bukovyna did not declare cash savings at all in 2023, but in 2024 and 2025 he listed 115 and 120 thousand dollars in cash, respectively. During a search more than 100 thousand dollars were seized from him.

Seized documents and materials are being transferred to NAPC for appropriate conclusions. After that, if there are grounds, the issue of notifying suspicions and the further fate of the unjustified assets will be decided. The police will publish detailed results of this work separately.

— Which sectors do the enterprises that most often appear in materials on possible illegal reservations belong to?

— Most often these are communal enterprises that have strategic importance for the economy and the state's security, as well as enterprises of critical infrastructure, in particular the fuel and energy complex. Their status can be a lawful basis for reserving employees.

Currently, within criminal proceedings we are checking the circumstances of possible illegal reservation of nearly 2,5 thousand conscripts. One common scheme is fictitious employment: a person is officially registered at an enterprise that has the right to reserve employees, although in reality they do not work there. There are cases where intermediaries organize this for money or false data is entered into information systems and registries.

These schemes undermine trust in the reservation mechanism itself. When someone buys themselves a position at an enterprise solely for a deferment, those who truly work there and legitimately have the right to reservation fall under suspicion as well. Therefore, for us it is important not only to uncover abuses but also to clearly separate them from lawful reservations of people whose work is genuinely needed by the state.

— What awaits conscripts whose reservations are declared illegal? Are they immediately mobilized? And do they bear responsibility?

— If it is established that there were no legal grounds for the reservation, the deferment is annulled. But that does not mean the person is automatically mobilized the next day. They lose that basis for deferment and may then be drafted according to the procedure defined by law.

There is also no automatic application of liability. We establish exactly how the person obtained the reservation, which documents they submitted, whether they participated in an illegal scheme and who organized it. Depending on the specific actions, the issue of administrative or criminal liability is decided.

For me it is important that there not be an oversimplified approach: finding an illegal reservation does not automatically make the conscript guilty. The investigation must establish the role of each person: both the one who used the scheme and those who provided it for money.

— What percentage of seized VLC rulings have investigators already fully checked?

— The Central VLC provides the definitive assessment of the validity of local VLC decisions. Investigators seize medical records, verify the circumstances of their preparation and, if the materials give grounds, refer the decisions for review.

Overall, during the period of the full-scale invasion 6,5 thousand unlawful VLC decisions have been overturned. At the same time, more than 25,6 thousand decisions of local VLCs were left in force by the Central VLC, and for more than 1,6 thousand it made decisions to review without canceling the rulings.

These figures illustrate the principle well: review does not equal cancellation. We must find concrete abuses, but we must also avoid touching lawful conclusions of people who truly have medical grounds for them.

— To verify this, do you involve experts who check medical documentation, or does the person undergo the VLC again?

— First investigators seize the medical documentation — examination results, treatment records, the VLC ruling itself and everything that served as grounds for its adoption.

We then verify these data using other sources. For example, by court order we can obtain mobile operator information to establish where the person was actually located during the period when, according to documents, they were supposed to undergo examinations or treatment. Separately we cross-check information with the electronic health care system — whether there were visits to doctors, examinations, which diagnoses and medical conclusions are recorded there.

If there are grounds, the VLC decision is referred for review. As a result it may be left in force, canceled or a new conclusion formed. And if additional assessment of health status is needed for the investigation and there are appropriate procedural grounds, a panel forensic-medical examination is appointed.

— How does the investigation ensure an individual approach so as not to accidentally cancel lawful conclusions for people with real serious illnesses or injuries?

— Each VLC decision is checked individually — together with the medical documents on the basis of which it was adopted. The mere fact that a VLC conclusion came under investigation does not mean it is unlawful or must be canceled.

If a person truly has a serious illness or consequences of injury, that is confirmed by medical documentation, and the VLC decision was made in accordance with the established procedure, there are no grounds to cancel it.

Responsibility must always be individual and based on evidence. For us this is a fundamental issue, so we must simultaneously protect the state from fictitious diagnoses and people from unjustified cancellation of lawful conclusions. Exposing specific abuses should not turn into a campaign against all VLCs or a presumption that every unfitness was bought.

— You said that 6,5 thousand VLC decisions have already been canceled. Which medical diagnoses were most often falsified in these canceled conclusions? How were these schemes built?

— Most often manipulations concerned musculoskeletal diseases, cardiovascular system disorders and neurological diseases. There were also cases involving mental disorders, diseases of the eyes, hearing and internal organs. We check not the diagnosis on paper itself, but whether it is supported by real examinations, treatment and medical data.

The schemes varied: in some cases knowingly false information about a diagnosis was entered into medical documents on the basis of which a person was declared unfit for service. In others, medical documents with fictitious diagnoses were produced for money. Such schemes involved VLC members, TCK employees, and in some cases — civilian intermediaries.

— Do people appeal the cancellation of VLC conclusions or the actions of investigators in court?

— Yes, such cases occur. People who disagree with the decisions of the Central VLC appeal them to administrative courts. That is their right and, ultimately, another mechanism for checking how well-founded the decision was.

To date we do not have information about final court decisions in these cases. As for cases where investigators' actions were challenged in such proceedings, according to our information, there have been none.

— Have you found cases where seriously ill people were unlawfully recognized as fit, effectively “replacing” those for whom a VLC conclusion was fabricated?

— I would not link such cases to “replacement” unless that connection is established by evidence. But if, within a specific proceeding, we obtain data that a person with a real illness or medical contraindications was groundlessly declared fit for service, we check that too: on what documents the decision was based, who made it and whether there were legal grounds for it.

For the investigation the principle does not change depending on which way a possible illegal decision was made. We must establish the facts and give the actions of those involved a legal assessment.

— Ombudsperson Dmytro Lubinets has repeatedly spoken about violations of citizens’ rights during mobilization activities. Has he brought such facts to the National Police? What actions of TCK staff most often become the subject of investigations?

— We consider all appeals from the Verkhovna Rada Commissioner for Human Rights and his representatives and constantly interact with them. If a report contains data about a possible criminal offense, the police respond in accordance with the law.

For example, last Thursday the Zakarpattia police investigators, following a report from Dmytro Lubinets, opened two criminal proceedings regarding officials of the Berehove district TCK and SP. These concern possible unauthorized interference with information and communication systems and abuse of office — under part five of article 361 and part one of article 364 of the Criminal Code of Ukraine.

Generally, among the proceedings involving TCK employees the most common are possible unlawful deprivation of liberty or kidnapping of a person. There are also proceedings regarding causing bodily harm to citizens during mobilization activities.

In each such case we establish what exactly happened: under what circumstances the conflict arose, what actions the participants took, whether force was used, whether there were legal grounds for that and what injuries the person suffered.

My position is simple: a position does not give immunity from responsibility. But guilt is not determined solely from a social media video or the existence of a conflict — the investigation must establish the circumstances and collect evidence.