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Reservation Reform: New Deadlines and Strict Financial Criteria for Business

The Cabinet of Ministers of Ukraine has adopted Resolution No. 692, which radically changes the rules for determining the criticality of enterprises and the procedure for reserving military-liable employees. The government has established clear deadlines for a total review of current statuses and significantly raised financial requirements for business.

The period of uncertainty is over. The Resolution entered into force on June 02, 2026.

📅 Schedule of Changes and Key Deadlines

The government has fixed a clear timeline during which the entire reservation system will be reformatted. The changes are being implemented in stages throughout the summer so that businesses and state bodies have time to adapt:

  • From June 2, 2026: The Resolution officially entered into force. The countdown of the transition period has begun.
  • By June 10, 2026: Ministries, specialized agencies, and Regional Military Administrations (OVAs) are obliged to completely review and re-approve their sectoral and regional criticality criteria, coordinating them with the Ministry of Defence and the Ministry of Economy.
  • By July 1, 2026: Authorities are instructed to analyze already issued decisions. If the basis (criterion) by which the enterprise previously received the status is removed from the new rules, such status will be canceled immediately.
  • By September 1, 2026 — Main Deadline: All current decisions on the criticality of enterprises continue to be valid only until the end of their term, but up to a maximum of September 1, 2026. By this date, businesses must re-confirm their criticality status under the new rules, otherwise existing employee reservations will be canceled. IMPORTANT: employee reservations remain valid throughout the entire period of the granted criticality, but no later than September 01, 2026.

🔍 Main Changes “in Numbers and Details”

1. Financial and Salary Criterion
To confirm the criticality status and subsequent reservation of employees, a new threshold for the average salary across the enterprise (before taxes) has been introduced:

  • Basic level: Must be at least 3 minimum wages — 25,941 UAH (previously the requirement was 2.5 minimum wages or 21,618 UAH). Enterprises need to review budgets and reach this figure already in June. This norm regarding employees will be fully controlled from September 1, 2026.
  • Preferential rate: For businesses actually operating in front-line territories or in zones of possible/active hostilities, the threshold was left at the level of 2.5 minimum wages — 21,618 UAH.
  • Exception: These changes do not apply to state and municipal institutions.

2. A New Approach to Part-Timers and Quotas
Employees who are registered as part-timers or already have the right to a deferment for other reasons (for example, due to health conditions or family circumstances) are now counted in the overall reservation limit (quota) of the enterprise only once and at one place of work. The procedure for including part-time employees in the total number of persons liable for military service to calculate the quota of a particular employer has not yet been clarified.

3. Automation and Strict Sanctions for Exceeding Limits
All criteria for the criticality of enterprises are now integrated into the “Diia” portal. Strict liability for exceeding the limit of reserved persons has been introduced:

  • If the limit is exceeded, the employer is obliged to independently submit an application via “Diia” within 10 working days to cancel the “extra” reservations.
  • Ignoring this requirement or the detection of an exceeded limit by controlling bodies is a direct basis for completely depriving the enterprise of its critical status.

4. New Grounds for Immediate CANCELLATION of Reservation
Resolution No. 692 closes the possibility of keeping an “exceeded limit” of reserved employees.

Situation Consequence and employer’s duty
Dismissal of other employees (due to which the percentage of reserved persons became greater than the allowed 50%). The employer is obliged within 10 working days to submit an application via “Diia” to cancel the deferment of the “extra” people.
Ignoring the exceeded limit (did not un-reserve staff on time). The enterprise completely loses the status of critically important, and the deferments of absolutely all employees are subject to cancellation.
Non-compliance with the new criteria during inspections until September 1. Cancellation of the criticality status by the body that issued it.

5. Speed of Consideration
State bodies are allocated no more than 10 working days from the moment of submission to analyze documents and make a decision on confirming the criticality of the business.

6. Implementation of Changes in Reservation at the Enterprise.

  1. Internal audit of the staffing table and quotas: Do by June 15, 2026. Recalculate the exact number of persons liable for military service. Exclude part-timers and persons who have other deferments (for care, disability, etc.) from the quota calculation (50%) if your enterprise is not their main place of work. Check if you have a current “exceeded limit”.
  2. Financial monitoring and salary adjustment: June – July 2026. Together with the accounting department, check the level of the average salary across the enterprise and the incomes of candidates for reservation. If the amount is less than 25,941 UAH (or 21,618 UAH for officially confirmed facilities in the combat zone), it is necessary to make changes to the staffing table and raise salaries/bonuses to reach this figure for at least the last 6 months.
  3. Monitoring of updated sectoral criteria: After June 10, 2026. Monitor the official websites of your specialized Ministry or OVA. By June 10, they are obliged to publish new, narrowed criteria for “criticality”. Ensure that your company passes under the new requirements (production volumes, amount of taxes paid, etc.).
  4. Submission of documents for status re-confirmation: July – August 2026. Collect an updated package of documents, including fresh tax calculations for the last 6 months (Personal Income Tax, ESV, profit), and submit an application for confirming criticality through “Diia” or the specialized body. This needs to be done in advance, without waiting for September 1, when the old decisions are canceled.

📑 New Daily Duties of the Person Responsible for Military Registration

With the entry into force of Resolution No. 692, the HR specialist or the person maintaining military registration has two critically important operational tasks:

1. Control of the “10-day rule” for dismissals
If unreserved military-liable employees quit the company, or obtain the status of non-military-liable (by age, health condition, etc.), the overall staff decreases, and therefore — the allowed limit of 50% automatically decreases as well.

  • Action: If you detect an exceeded limit of reserved persons, you are obliged within 10 working days to independently submit an application via “Diia” to cancel the reservation of “extra” people. Otherwise, the company will completely lose its criticality status.

2. Strict filtering of part-timers
When hiring new part-time employees, immediately record in internal databases that they cannot claim your company’s reservation quota if their labor book (main place of work) is located in another company.

🎯 Key Highlights for Executives

  1. Act immediately: You should not wait until the end of August. Since OVAs and ministries will update their criteria by mid-June, documents under the new rules should be submitted as early as possible to avoid queues and the “resetting” of reservations on September 1.
  2. Ensure financial compliance: Check the accrued salaries for May and June. The company must meet the marker of 25,941 UAH.
  3. Full control of military registration: Since “Diia” automatically reconciles data with the “Oberih” register, any error in the employee’s HR documents will block the process.

📌 Brief Conclusions

Summary: The government has drawn a line between the real economy and attempts to use reservation for evasion. The new model requires a greater financial burden from businesses (salaries from 25,941 UAH) and absolute HR transparency.

The transition period is valid until September 1, and this time is given to businesses not to wait, but to bring finances and accounting into full compliance with the new conditions. There can be no question of delay — the price of a mistake equals the loss of key specialists.

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