Changes to the Status of Critically Important Enterprises and Employee Reservation

On 30 May 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 692, amending the procedure for determining criticality and the procedure for reserving persons liable for military service. The resolution came into force on 2 June 2026.

Key changes that have come into force

The average salary of an enterprise's full-time employees for the previous calendar month must be no less than UAH 25,941.00 (except for enterprises operating in areas of possible/active hostilities or temporarily occupied territories — for them the salary requirement remains at UAH 21,617.50). Diia City resident status alone is no longer sufficient — it is necessary to confirm that the average monthly remuneration of engaged employees and gig specialists over the last 6 calendar months is no less than the equivalent of EUR 1,200 at the NBU exchange rate as of the 1st day of each month. Exceeding the limits on the number of reserved persons may be grounds for revoking the status of a critically important enterprise. If the reservation limit is exceeded, the head is obliged to cancel employee reservations within 10 working days. By 10 June 2026, state bodies must review the criteria by which enterprises are recognised as critical for a particular sector or territorial community. By 1 July 2026, state bodies must analyse all enterprises with critical status for compliance with the updated criteria (if the criterion on the basis of which the status was granted is removed, the enterprise loses its criticality). By 1 September 2026, state bodies must review the decisions made on determining critical status. Decisions recognising critical status (granted before 2 June 2026) remain valid for the period for which they were adopted, but no longer than until 1 September 2026 (except for enterprises that may lose criticality due to changed criteria).

Changes that will take effect from 1 September 2026

Employees who have a deferment, as well as employees working part-time, are counted towards the reservation quota at only one place of work. The minimum salary of reserved employees must be no less than UAH 25,941.00 (except for enterprises operating in areas of possible/active hostilities or temporarily occupied territories — for them the requirement remains at UAH 21,617.50).

The changes effectively reset the criticality criteria, trigger a review of existing statuses, and tighten control over compliance with reservation requirements. In this regard, we recommend that businesses check their compliance with the updated requirements now.

Kucherenko & Partners advises and supports companies on obtaining and confirming the status of a critically important enterprise, as well as on specific employee reservation matters.