Legal updates (05.12.2025)

Below, you will learn about:

• Receiving deferrals from mobilization for employees with military registration issues;
• Submission of information about companies’ transport vehicles to the military authorities;
• Updated criteria of the Ministry of Defense regarding critically important companies;
• Changes to the procedure for granting and extending deferrals from mobilization;
• New law and opportunities for public-private partnerships;
• Government provides options for restricting access to information about companies in the defense industry;
• Renewal of the period of statute of limitations.

Receiving deferrals from mobilization for employees with military registration issues

On 4 December 2025, the Law came into force, which provides special conditions for critically important companies for the Armed Forces of Ukraine, other military formations, and the defense-industrial complex regarding the employment and reservation of conscripts who:

• absent or improperly executed military registration documents, and/or
• not registered with the military, and/or
• not clarified their personal data, and/or
• are wanted for violating military registration rules, defense, mobilization preparation, and mobilization laws.

Key aspects:

• the period of reservation for such conscripts may not exceed 45 calendar days from the date of conclusion of the employment contract and is granted no more than once per calendar year;
• when employing such conscripts, it is allowed to establish a probationary period of up to 45 calendar days regardless of the employee’s category;
• if, during the period of reservation, such a violation is eliminated, the conscript is subject to reservation on general grounds, and if not, his dismissal at the initiative of the employer is permitted;
• at the same time, the fact of reservation does not exempt a conscript from liability for violating the law on defense, mobilization preparation, and mobilization laws.

^{Source: Law of Ukraine No. 4630-IX dated 9 October 2025 “On Amendments to Certain Laws of Ukraine Regarding the Organization of Labor Relations under Martial Law”.}

Submission of information about companies’ transport vehicles to the military authorities

By 20 December 2025, companies should submit to the military authorities “Information on the availability and technical condition of vehicles and equipment, as well as on the personnel working on such vehicles and equipment”.  

Key aspects:

• managers of companies shall submit information to the military authorities by 20 June and 20 December each year in accordance with Appendix 1 to the Regulations on:
  • availability of vehicles and equipment;
  • technical condition of transport;
  • the personnel working on such vehicles and equipment.

^{Source: Government Resolution No. 1921 dated 28 December 2000 “On Approval of the Regulations on Military Transport Duty”.}

Updated criteria of the Ministry of Defense regarding critically important companies

On 3 November 2025, Order No. 722 of the Ministry of Defense, dated 28 October 2025, came into force, approving new criteria for determining companies in the defense-industrial complex (DIC), aircraft manufacturing industry, and space activities that are important to the national economy.

Key aspects:

• companies are involved in the development, production, repair, modernization, or disposal of weapons and equipment for the Armed Forces of Ukraine, as well as the subjects that manage them, are recognized as important to the national economy if they meet at least one of the following criteria:
  • performance of a state contract in the field of defense or participation in its performance on the basis of agreements, in particular foreign economic agreements. The volume of defense-related production must exceed 50% of the total volume of the enterprise for the last reporting period;
  • receiving state financial support in the form of grants, in accordance with Government Resolution № 262 of 8 March 2024;
  • performing the functions of an authorized subject for the management of state-owned property, which regulates, controls, and coordinates the activities of such companies;
• companies in the aviation and space industries, as well as DIC enterprises that do not meet the above criteria, should meet at least three of the following requirements:
  • performance of state contracts in the field of defense;
  • involvement in the performance of defense orders under contracts, including foreign economic ones;
  • inclusion in the electronic register of participants in the selection and performers of state contracts;
  • participation in the implementation of state target programs in the fields of aircraft construction or space activities;
  • participation in the implementation of state programs for the development of the DIC, development, mastering, and implementation of new technologies, expansion of production capacities for the manufacture of defense products;
  • production of goods, works, and services used by DIC companies for the manufacture of defense goods.

^{Source: Order of the Ministry of Defense No. 722 dated 28 October 2025 “On Approval of Criteria for the Ministry of Defense of Ukraine to Identify Enterprises, Institutions, and Organizations in the Defense-Industrial Complex, Aircraft Manufacturing Industry, and Space Activities as Being of Significant Importance to the National Economy”.}

Changes to the procedure for granting and extending deferrals from mobilization

On 1 November 2025, new rules for applying for and extending deferrals from mobilization came into force. The changes are aimed at simplifying the procedure, increasing transparency, and digitizing the process.

From now on, applications for deferral can only be submitted via the Reserv+ app or at the Administrative Services Center. In turn, the military authorities will no longer accept such applications.

Key aspects:

• automatic extension of deferrals, the grounds for which can be confirmed in state registers or which cannot change over time. Such deferrals will be extended automatically;
• registration via Reserv+ is available for most categories;
• offline registration is possible at any Administrative Service Center for those who are not yet digitized, do not use a smartphone, or have paper documents and insufficient data in state registries. In this case, the Administrative Service Center receives and scans the documents and transfers them in electronic form to the relevant military authority for decision-making;
• modernization of certificates: from 1 November 2025, a paper certificate of deferral with a wet seal will no longer be required. Confirmation of deferral will be provided by an electronic military registration document in Reserv+.

^{Source: Government Resolution No. 1364 dated 24 October 2025 “On Amendments to Government Resolutions No. 57 dated 27 January 1995 and No. 560 dated 16 May 2024”.}

New law and opportunities for public-private partnerships

On 31 October 2025, the Law “On Public-Private Partnership” (PPP) came into force, aimed at improving legislation in the field of public-private partnerships (PPP) in order to attract private investment for the post-war reconstruction of Ukraine, developing critical infrastructure, the economy, and the social sphere, and establishing qualitatively new standards for the provision of socially significant services.

Key aspects:

• improvement of procedures for preparing and implementing PPP projects;
• more flexible mechanisms for cooperation between the state and business;
• the possibility of concluding agreements on facilities that will be built or restored after the war;
• updating terminology related to PPPs, investors, and private partners;
• simplifying procedures for selecting partners and approving projects;
• harmonizing national legislation in the field of PPPs with European Union law and Ukraine's international obligations.

^{Source: Law of Ukraine No. 4510-IX dated 19 June 2025 “On Public-Private Partnership”.}

Government provides options for restricting access to information about companies in the defense industry

On 4 October 2025, Government Resolution No. 1257 dated 3 October 2024, came into force, approving the Procedure for temporarily restricting access to information on enterprises, institutions, and organizations in the defense-industrial complex (DIC) for the duration of the martial law.

Key aspects:

• during martial law, companies that are critical to the defense industry or to the needs of the Armed Forces of Ukraine and other military formations may submit a written request to the Ministry of Defense for temporary restriction of access to information about them in public registers and electronic resources;
• the request is submitted to the Ministry of Defense in electronic form, signed with an electronic digital signature, and should contain information in accordance with the Procedure. Within three business days, the Ministry of Defense sends an email to the supplier regarding access restrictions or notifies the enterprise of the non-compliance of the request;
• companies notify the Ministry of Defense of the loss of critical importance status within 5 working days after the decision is made (except in cases where the order was issued by the Ministry of Defense), and if the restriction is no longer necessary, – sends an email with a digital signature. The Ministry of Defense informs the supplier about the resumption of data disclosure within 3 working days;
• access restoration is carried out:
  • for all companies that have independently restricted access to information – no later than 1 month after the termination or cancellation of martial law;
  • for a specific companies that have been deprived of its critical importance status – within 10 working days from the date of receipt by the service provider of a letter from the Ministry of Defense;
  • for a specific companies, upon receipt of a letter from the Ministry of Defense at its request, within 10 working days from the date of receipt of the letter from the Ministry of Defense.

^{Source: Government Resolution No. 1257 dated 3 October 2024, “On Approval of the Procedure for Temporary Restriction of Access to Information on Enterprises, Institutions, and Organizations in the Defense-Industrial Complex”.}

Renewal of the period of statute of limitations

On 4 September 2025, a law came into force that renews the statute of limitations, namely, paragraph 19 of the section “Final and Transitional Provisions” was excluded from the Civil Code of Ukraine, which suspended the statute of limitations defined by the Civil Code for the period of martial law.

Key aspects:

• renewal of the statute of limitations means that from 4 September 2025, the statute of limitations will continue to apply, taking into account the time that has elapsed before its suspension;
• the time limits for bringing disputes to court are counted again;
• from this point on, you should review the deadlines for filing claims to avoid missing them;
• courts will again apply the provisions on the statute of limitations in the general order when considering cases.

We remind you that the statute of limitations is the period within which a person can apply to the court with a claim for the protection of their civil rights or interests.

^{Source: Law of Ukraine No. 4434-IX dated 14 May 2025 “On Amendments to the Section ‘Final and Transitional Provisions’ of the Civil Code of Ukraine Regarding the Renewal of the Statute of Limitations”.}