On 2 June 2026, Resolution of the Cabinet of Ministers of Ukraine No. 692 dated 30 May 2026, “Certain Issues on Reservation of Conscripts during the Mobilization Period and Wartime” (hereinafter, Resolution No. 692), entered into force. The Resolution introduces yet another round of changes to the rules governing the confirmation and acquisition of critical enterprise status.
The document updates the criteria for critical enterprises, strengthens control over reservation quotas, changes salary requirements, and establishes a transitional period until 1 September 2026 for companies to confirm compliance with the updated criteria.
Our team has prepared an overview of the key changes.
What happens to existing critical enterprise status?
All critical enterprise statuses that were valid as of 2 June 2026 remain effective until their original expiry date, but no later than 1 September 2026.
If a company's critical status expires before 1 September 2026, it must be renewed before the expiry date. There is no automatic extension.
All enterprises must confirm compliance with the updated criteria by 1 September 2026.
What has changed in the criteria?
State authorities were required to update the criteria by 10 June 2026. However, as of that deadline, the updated criteria had not yet been issued, and businesses are therefore awaiting their formal publication.
By 1 July 2026, authorities were expected to review enterprises that had previously been granted or had confirmed critical enterprise status to assess compliance with the new requirements.
🔴 Important: If the updated criteria do not include the criterion under which an enterprise originally obtained critical status, the relevant state authority will be required to revoke that status before 1 September 2026.
📌 Recommendation: Regularly monitor your critical enterprise status through the Diia portal and closely follow updates to the applicable criteria.
New salary requirements
The average accrued monthly salary of employees for the most recent calendar month must be:
- Not less than UAH 25,941 (three minimum wages multiplied by a coefficient of 3). This requirement does not apply to state-owned or municipal enterprises.
- Not less than UAH 21,617.5 (three minimum wages multiplied by a coefficient of 2.5) for enterprises operating in areas of active hostilities or possible hostilities. The coefficient for such enterprises remains unchanged.
- The requirement that reserved employees receive a salary of at least UAH 25,941 (three minimum wages multiplied by a coefficient of 3) will take effect on 1 September 2026.
Changes for Diia.City residents
In addition to maintaining Diia.City resident status, companies must now confirm that:
- The average monthly remuneration paid to employees and gig specialists in each calendar month is at least the equivalent of EUR 1,200, calculated using the official UAH/EUR exchange rate established by the National Bank of Ukraine on the first day of the relevant month (Part 2, Article 5 of the Law of Ukraine “On Stimulating the Development of the Digital Economy in Ukraine”).
- Compliance is evidenced by income tax reports, together with all relevant appendices and filing confirmations submitted to the State Tax Service, covering the last six calendar months, filed in accordance with applicable legislation.
🔴 The amendment to criterion 7 of the Criteria and Procedure approved by Cabinet of Ministers Resolution No. 76 (hereinafter, Resolution No. 76) substantially affects Diia.City startup residents. Previously, startups benefited from an exemption from the EUR 1,200 remuneration requirement. Under the new rules, however, they must demonstrate compliance with this criterion for the preceding six months. As a result, some startups may be unable to confirm compliance with criterion 7 of Resolution No. 76.
📌 Recommendations:
- Diia.City residents that meet the updated requirements should begin preparing the necessary documentation package and submit it to the Ministry of Digital Transformation.
- Startups should assess their compliance with the updated criterion. If they do not meet the requirement, they should monitor forthcoming sector-specific criteria from the Ministry of Digital Transformation. Order No. 182 remains in force for now, although amendments are expected.
Changes to reservation quotas
Will part-time employees with other types of deferment be included in the quota?
- Until 1 September 2026: The provisions of Resolution No. 692 regarding the calculation of part-time employees within the reservation quota will only enter into force on 1 September 2026. Therefore, until that date, part-time employees must be included when calculating the quota.
- After 1 September 2026: Employees who hold a deferment other than a reservation under Article 23 of the Law of Ukraine “On Mobilisation Preparation and Mobilisation” will be counted toward the quota at only one place of employment. The implementation mechanism is yet to be developed by the Ministry of Economy.
Stricter control of the reservation quota (≤50%)
If the number of reserved employees exceeds the permitted quota relative to the total number of employees liable for military service included in the quota calculation, the head of the enterprise must submit an application to cancel reservations within 10 working days.
🔴 Exceeding the quota will constitute grounds for revoking critical enterprise status.
Other changes:
- By 1 August 2026, the Ministry of Digital Transformation and the Pension Fund of Ukraine must update state information systems to implement the rule that employees with deferments other than reservations are counted at only one workplace. In practice, this means introducing a technical mechanism for accounting for part-time employees with deferments.
- Within 14 days, the Ministry of Digital Transformation must ensure that the Unified Register of Enterprises Eligible for Employee Reservation reflects the updated validity period of critical enterprise status until 1 September 2026, provided the existing status does not expire earlier.
- By 1 August 2026, the Ministry of Digital Transformation must also ensure the technical capability to display, within the Unified Register, information on the specific criteria met by each critical enterprise.
What should businesses do now?
- Ensure that the enterprise-wide average salary for June 2026 meets the new threshold of three minimum wages (UAH 25,941).
- Conduct an audit of their workforce structure, including employees holding deferments and part-time employees.
- Continuously monitor compliance with reservation quotas.
- Closely track updates to the criteria and promptly submit documentation confirming compliance once the updated criteria are published.
"The new rules create both additional obligations and areas of uncertainty for businesses, particularly given the absence of updated criteria from state authorities by the 10 June 2026 deadline, as well as the unresolved practical implementation of the rule concerning part-time employees who hold deferments other than reservations. In these circumstances, and given the limited time remaining before 1 September 2026, businesses should take a proactive approach by closely monitoring developments, assessing the likely application of the new rules, and planning their next steps in advance"
Tetiana Levkivska
Head of Legal Practice
We are ready to support your company at every stage, from assessing your current position to providing comprehensive assistance throughout the critical status confirmation and employee reservation process.
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