The Cabinet of Ministers of Ukraine, by Resolution No. 692 of May 30, 2026, “On Certain Issues of Reserving Military-Obligated Persons During Mobilization and Wartime” (hereinafter – Resolution No. 692), introduced significant changes affecting the review of sectoral and regional criteria for critical enterprises, an increase in salary requirements, and new rules for accounting part-time employees within reservation quotas.
Below is an analysis of the key changes and what they mean for businesses.
Reassessment of “Critical Infrastructure” Status
One of the most important changes is the revision of existing sectoral and regional criteria used to grant “critical enterprise” status.
- By June 10, 2026, ministries, government bodies, and military administrations must update the criteria so they apply only to companies essential for the economy, defense, or public services.
- By July 1, authorities will assess companies’ compliance with the new requirements. If a company obtained its status based on criteria that are later revoked or changed, its status may be reviewed or canceled.
- By September 1, 2026, all previously issued decisions must be reassessed by state authorities.
Existing decisions remain valid only until September 1, 2026.
This means companies must re-confirm their critical status under the new rules before this deadline.
At the same time, businesses highlight risks related to tight timelines. Due to the expected workload of government bodies, application processing may exceed official deadlines, potentially leading to temporary loss of critical status and related reservation rights.
Increased Salary Threshold
Significant changes are introduced regarding remuneration requirements.
Starting June 2, 2026, the average monthly salary required to obtain critical enterprise status must be at least three minimum wages, which equals UAH 25,941 in 2026.
For companies operating in areas of active or potential hostilities, as well as temporarily occupied territories, a lower threshold applies — 2.5 minimum wages (UAH 21,617.50).
Additionally, from September 1, 2026, employees included in reservation lists must also receive a salary of at least three minimum wages, with exceptions for frontline regions.
New Rules for Accounting Part-Time Employees
From September 1, 2026, the procedure for counting military-liable employees working at multiple companies will change.
A part-time employee will be counted in the total number of military-liable personnel only by one employer, regardless of whether it is their primary place of work.
The government aims to eliminate double counting when calculating reservation quotas.
However, the verification mechanism has not yet been fully defined. By August 1, the Ministry of Defense, Ministry of Digital Transformation, and the Pension Fund must update state electronic systems to implement this rule.
Strengthened Control Over Reservation Quotas
Resolution No. 692 introduces a new basis for revoking “critical enterprise” status.
If a company exceeds the permitted number of reservable military-liable employees, this may lead to cancellation of its critical status.
In addition, company managers are required, within 10 working days after detecting a quota violation, to submit a request via the Diia portal to cancel relevant reservations.
This places ongoing responsibility on employers to monitor reservation limits and promptly respond to workforce changes.
Additional Requirements for Diia.City Residents
Previously, residency status alone was sufficient for certain benefits. Now companies must additionally confirm salary levels for employees and gig specialists.
The average monthly remuneration over the last six months must be at least the equivalent of €1,200.
What Businesses Should Do
- Review average salary levels and ensure compliance for both the company and employees planned for reservation.
- Monitor updated criteria issued by relevant authorities granting critical status.
- Submit updated documentation and re-confirm critical status by September 1, 2026.
- Continuously monitor reserved employee quotas and promptly cancel reservations if limits are exceeded.
- From September 1, 2026, apply new rules for part-time workers, as only one employer may include such employees in reservation calculations.
Overall, the new resolution makes the reservation system more centralized and controlled, while also increasing requirements for businesses. The coming months will therefore be a period of adaptation for many companies to new rules and procedures.