The Ukrainian Entrepreneurs Union (SUP) has appealed to the Cabinet of Ministers of Ukraine to extend until November 1, 2026 the validity of decisions designating enterprises as critical to the functioning of the economy and ensuring the vital needs of the population.
SUP regularly receives inquiries from companies regarding problems arising during the repeated confirmation of critical enterprise status. Businesses emphasize that under the current circumstances, there is a real risk that government authorities will not have enough time to process all submitted documents by September 1 — the deadline until which, pursuant to Cabinet of Ministers Resolution No. 692, existing decisions on critical status are to remain valid.
The extension is necessary to prevent a situation in which enterprises that actually meet the criticality criteria could lose their status due to circumstances beyond their control.
Why Businesses Are Calling for an Extension
1. Sectoral and regional criteria were updated with delays.
Resolution No. 692 required central executive authorities and regional military administrations to review the criteria for designating critical enterprises by June 10, 2026.
However, in most cases, the updated criteria were approved only at the end of June and throughout July. As a result, enterprises effectively did not have sufficient time to assess their compliance with the new requirements, prepare the necessary documents, and submit them to confirm their status.
2. Government authorities are facing a significant workload due to the large-scale confirmation process.
According to SUP members, merely registering documents with some authorities can take between five days and two weeks. Given the large number of applications, the actual review of documents may take longer than the established deadlines.
This creates a risk that after September 1, an enterprise could lose its critical status not because it fails to meet the criteria, but because its documents were not reviewed in time.
3. Wartime conditions objectively complicate the preparation of documents.
Regular missile attacks, air-raid alerts, damage to production and administrative facilities, and the forced relocation of offices significantly affect business operations.
Many companies operate remotely or in hybrid formats, which also increases the time required to collect and prepare documents. Established deadlines should take into account the actual conditions of doing business during wartime.
4. Changes in the Government and the reorganization of ministries have created additional uncertainty.
In July 2026, a new Cabinet of Ministers was formed and a large-scale reorganization of the central executive authorities was carried out.
These changes took place simultaneously with the launch of the new criticality confirmation process. Businesses are facing practical questions about which authorities they should submit their documents to and whether they need to wait for updated criteria from reorganized ministries.
5. The rules governing employee reservations and criticality confirmation have changed twice within a short period.
In recent months, significant changes to the relevant regulations were introduced by Cabinet of Ministers Resolutions No. 692 of May 30 and No. 862 of July 1, 2026.
The lack of a sufficient transition period is forcing enterprises to adapt internal processes, analyze new requirements, and collect documentation again within a very limited timeframe.
SUP’s Proposals
In view of these circumstances, the Ukrainian Entrepreneurs Union calls on the Government to extend until November 1, 2026 the validity of decisions designating enterprises as critical.
To achieve this, SUP proposes amending Resolution No. 692 to:
- extend until November 1, 2026 the validity of decisions designating enterprises as critical that were in force when the Resolution entered into effect;
- establish November 1, 2026 as the final deadline for the relevant authorities to review existing decisions designating enterprises as critical.
Businesses need sufficient time to adapt to the new rules, while government authorities need the opportunity to properly process the significant volume of submitted documents. Extending the deadline would reduce the risk of enterprises losing their critical status due to administrative delays and help ensure the continued operation of businesses that are supporting Ukraine’s economy during wartime.
SUP calls on the Government to consider this proposal promptly and introduce the necessary amendments to Resolution No. 692 to safeguard the economic resilience of Ukrainian businesses.