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Published 03.06.2026 LEGAL ALERT
By Resolution No. 692 dated 30 May 2026 (“Resolution No. 692”), the Cabinet of Ministers of Ukraine updated the rules for reserving employees liable for military service and the procedure for confirming the status of critically important enterprises.
The amendments were introduced to CMU Resolution No. 76 dated 27 January 2023 (“Resolution No. 76”), which approved, among other things, the Procedure for Reserving Persons Liable for Military Service During Mobilisation and Wartime, as well as the Criteria and Procedure for Designating Enterprises, Institutions and Organisations as Critically Important for the Functioning of the Economy, Ensuring the Vital Needs of the Population, and Meeting the Needs of the Armed Forces of Ukraine and Other Military Formations.
Resolution No. 692 entered into force on 2 June 2026. At the same time, certain amendments provide for transitional deadlines, including those related to the review of criticality criteria, existing critically important enterprise statuses, and the application of updated salary requirements.
These changes affect both enterprises that already hold critically important status and companies that only plan to obtain such status for the purpose of reserving employees.
Businesses should pay attention to the following dates:
2 June 2026 - entry into force of CMU Resolution No. 692;
10 June 2026 - deadline for reviewing and approving updated sectoral and regional criticality criteria;
1 July 2026 - date by which the statuses of enterprises designated as critically important under criteria that have been amended or removed may be reviewed;
1 September 2026 - date by which previously adopted decisions designating enterprises, institutions and organisations as critically important must be reviewed, and with which the application of certain updated requirements is associated.
One of the most significant changes is the review of previously adopted decisions designating enterprises, institutions and organisations as critically important.
Having previously obtained such status does not guarantee its automatic retention, as the authorised authorities must review existing decisions in light of the updated criticality criteria.
In practice, this may be particularly relevant for enterprises that obtained critically important status on the basis of a sectoral or regional criterion. If the relevant criterion is amended, further detailed or removed, this may create a risk of losing critically important enterprise status and affect the ability to reserve employees.
Resolution No. 692 provides for a review of the criteria under which enterprises are recognised as critically important for the functioning of the economy, ensuring the vital needs of the population, or meeting the needs of the Armed Forces of Ukraine and other military formations.
The relevant ministries, central executive authorities and regional military administrations must update their own criticality criteria. In this regard, enterprises should verify whether the criterion on the basis of which they were granted critically important status remains in force.
If the relevant criterion is amended or removed, the enterprise may lose the ability to confirm its critically important status, which, in turn, may affect both existing and future employee reservations.
Resolution No. 692 increases the salary threshold taken into account for the purpose of designating an enterprise as critically important, as well as for maintaining employee reservations in cases where the relevant salary requirement applies.
The general salary threshold has been increased from 2.5 to 3 minimum wages. Taking into account the 2026 minimum wage of UAH 8,647, the new threshold amounts to UAH 25,941 per month.
At the same time, a special approach is envisaged for enterprises, institutions and organisations located and actually operating in areas of possible hostilities, active hostilities, or temporarily occupied territories. For such entities, the threshold of 2.5 minimum wages remains applicable, i.e. UAH 21,617.50 per month.
The reduced threshold may be applied only if the enterprise is not merely registered in the relevant territory, but also actually carries out its activities there.
Resolution No. 692 clarifies the conditions under which Diia.City residents may be designated as critically important enterprises for reservation purposes.
The updated criterion provides that an enterprise, institution or organisation must be a Diia.City resident and must comply with the requirements of paragraph 2 of part one of Article 5 of the Law of Ukraine “On Stimulating the Development of the Digital Economy in Ukraine”. This refers to the requirement regarding the average monthly remuneration of engaged employees and gig specialists, which must be not less than the equivalent of EUR 1,200 at the official exchange rate of the National Bank of Ukraine as of the first day of the relevant calendar month.
Compliance with this criterion must be confirmed by tax calculations of income accrued or paid to individual taxpayers, the amounts of tax withheld from such income, and the amounts of accrued unified social contribution for the last six calendar months.
This means that, for new Diia.City residents, obtaining critically important enterprise status effectively becomes possible no earlier than six months from the date of registration, provided that the salary criterion is met throughout that entire period.
Companies should verify not only the existence of Diia.City resident status, but also compliance with the remuneration-level requirement and ensure that the necessary reporting is available for the six preceding calendar months before any potential status review.
Enterprises must independently monitor whether the number of reserved employees complies with the established limits.
If the permissible number of persons liable for military service who may be reserved is exceeded, the employer must, within 10 business days from the date such excess arises, submit an application via the Diia Portal to cancel the reservation of the relevant employees.
Failure to comply with this obligation may constitute grounds for cancelling the enterprise’s critically important status, as exceeding the established limits on the number of persons liable for military service who may be reserved is expressly defined as a ground for cancellation of such status.
Resolution No. 692 clarifies the procedure for taking certain categories of employees into account when determining the total number of persons liable for military service.
Employees who have already been granted a deferment from conscription on other grounds provided for in Article 23 of the Law of Ukraine “On Mobilisation Preparation and Mobilisation”, as well as employees who work part-time at another enterprise, institution or organisation, are included in the total number of persons liable for military service only at one place of employment.
For businesses, this means that additional reconciliation of HR data will be required. The presence of part-time employees or employees with other grounds for deferment may affect the calculation of the available reservation quota.
In light of the new requirements, enterprises should conduct an internal review of their reservation system and the documents on the basis of which they have obtained, or plan to obtain, critically important status. In particular, enterprises should:
verify whether the enterprise meets the updated salary criterion;
for Diia.City residents, verify compliance with the requirement regarding the average monthly remuneration of employees and gig specialists, as well as the availability of tax calculations for the last six calendar months confirming this indicator;
analyse existing reservations and determine whether the permissible limit has been exceeded;
identify part-time employees and employees who already have a deferment on other grounds;
verify whether the criterion on the basis of which the enterprise obtained critically important status remains valid;
prepare documents for possible reconfirmation of status;
implement an internal procedure for regular monitoring of the number of persons liable for military service, reserved employees, part-time employees and employees with other deferments;
appoint responsible persons to monitor changes in employees’ status and ensure the timely submission of applications to cancel reservations if the established limits are exceeded.