The Ministry of Defense acknowledged the need to replace the rules of the Military Medical Commission, which were created in peacetime conditions

The Ministry of Defense of Ukraine is creating an interagency working group tasked with developing a new procedure for conducting military medical examinations. The new rules should regulate the issuance of documents based on the examination results, referral for a repeat Military Medical Commission (MMC), verification of the medical component of commission decisions, and the responsibility of MMC members.

According to the Ministry of Defense representative Kristina Saponenko, the current Regulation on Military Medical Examination in the Armed Forces of Ukraine, approved by the Ministry of Defense order No. 402 dated August 14, 2008, will be replaced in the future. At the same time, a rapid change of the document may create risks for the stable operation of the system, so the Ministry is currently developing a concept for the new procedure, which will be put up for public discussion.

The Ministry of Defense notes that the current rules were developed under peacetime conditions, and the disease schedule was calculated for regular conscription for compulsory service.

They will check not only the procedure but also the medical validity of decisions

Kristina Saponenko pointed out that courts, when considering disputes, mostly check compliance with the procedure of conducting the MMC. However, this may be insufficient since the disputed decision is often related to medical indicators and the specifics of disease development. Therefore, a mechanism for medical expertise of such decisions needs to be defined.

Additionally, the Central MMC currently operates at the level of regional commissions, performs the same functions, and simultaneously exercises control. Therefore, the Central MMC needs to be relieved and its coordination and control functions separated. This could allow it to additionally conduct medical expertise of disputed decisions.

They want to guarantee the issuance of documents after the MMC

One of the problems in the MMC’s work, according to lawyers, is the failure to issue documents with the results of the medical examination to those liable for military service.

The National Association of Advocates of Ukraine (NAAU) noted that without an MMC certificate, a person cannot fully appeal the decision regarding fitness for military service. Therefore, mandatory issuance of such documents is to be established, and it should be determined that an unissued decision should not be enforced.

Lawyers also drew attention to the problem of the period between the issuance of a disease certificate and its approval. Servicemen may find themselves in situations where a new commission does not take into account previous medical conclusions.

A separate issue remains establishing a causal link between diseases or injuries and military service or participation in combat operations.

Problems also arise due to the results of the initial examination during mobilization.

If a person is recognized as fit, later the lawyer has to prove that as of the mobilization date, the person did not have the corresponding disease to establish a causal link. At the same time, complaints regarding establishing the causal link can be considered by regional MMCs for about a year.

The majority of complaints concern referrals to the MMC

In the first six months of operation, the Office of the Military Ombudsman received about 12,000 appeals. 23% of them concerned the medical field.

Among medical complaints, the largest share—43%—is related to obtaining a referral for undergoing the MMC. Military personnel also appeal regarding referrals for treatment, the work of commission officials, medical support, and the examination procedure itself.

The Secretariat of the Verkhovna Rada Commissioner for Human Rights noted that during 2025, 6,127 appeals were received, and in 2026 as of July, about 3,500. Almost every second appeal this year concerned undergoing the MMC.

Responsibility for MMC members may be introduced

During the discussion, the issue of responsibility for members of military medical commissions was also raised.

One option proposed is to create a separate disciplinary responsibility mechanism for MMC members. Possible measures include dismissal, prohibition to work in commissions, or temporary deprivation of the right to engage in the relevant practice.

At the same time, the Ministry of Defense emphasized that each level of the MMC must understand the consequences of its decisions. One possible mechanism considered is linking payment to the quality of the examination: if the medical service was provided improperly, it should not be paid in full. For this, the Ministry of Health and the National Health Service of Ukraine (NHSU) need to be involved.

At the same time, the Ministry of Defense stressed that medicine should not be criminalized, as doctors might then refuse to work in the MMC.

Rules for military personnel abroad will be updated

Separate changes are planned for servicemen undergoing treatment abroad.

The Ministry of Defense reported that the draft amendments to the Regulation are planned to be sent for external approval in the coming days. It should define the procedure for conducting the MMC to establish the fitness of servicemen abroad and involve garrison MMCs in this work.

The ministry also plans to replace the current experimental remote MMC mechanism, which operates according to Cabinet of Ministers Resolution No. 1125. According to the Ministry of Defense, this model has not yielded the expected results in practice.

Changes are expected to be made to the Procedure for referring persons from the defense and security forces affected by the Russian Federation’s military aggression against Ukraine for treatment abroad, approved by Cabinet Resolution No. 411 dated April 5, 2022. Before sending a serviceman abroad for rehabilitation, it is proposed to conduct the MMC in Ukraine to avoid future problems with documents.

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