The new government has repealed the controversial decision on reservations: what this means for businesses
23 July 11:45
The Cabinet of Ministers has revoked the decision to establish a Coordination Center for the Mobilization of Conscripts. The new body was supposed to coordinate the reservation process during mobilization and provide recommendations on identifying enterprises as critical. This was reported by People’s Deputy Olga Vasilevska-Smaglyuk, according to "Komersant Ukrainian"
According to her, the center was intended to coordinate the reservation process and provide recommendations on identifying enterprises as critical.
However, this initiative caused a stir among business representatives and industry experts. They feared that the creation of an additional body could complicate the existing procedure, increase the number of approvals required, and make decision-making regarding criticality less transparent.
“We had to backtrack,” Olga Vasilevska-Smaglyuk commented on the decision’s reversal.
Thus, the Coordination Center did not actually have time to begin full-scale operations. The identification of critically important enterprises and the reservation of their employees will continue to be carried out according to existing procedures without the involvement of the new coordinating body.
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Deadline—September 1: Who Must Re-confirm Their Status
The cancellation of the Coordination Center does not mean that other changes to the reservation rules are automatically canceled.
Separately, the government has updated the criteria under which enterprises can obtain or confirm their status as critical to the economy and the provision of essential services to the population. An employer’s ability to reserve employees subject to military service depends on this status.
Companies that already have this status must check the validity period of their decision and ensure compliance with the new requirements. Previously approved decisions remain in effect for their specified duration, but for some companies, the cutoff date will be September 1, 2026.
This does not mean that the exemption for all employees will be terminated simultaneously on September 1. The consequences will depend on the validity period of a specific company’s status and whether the employer confirms compliance with the updated criteria.
What happens if a company fails to confirm its critical status
If a company loses or fails to confirm its critical status, it will no longer be able to use that status as a basis for retaining employees.
Losing critical status may result in the cancellation or termination of deferrals arranged through that company. Therefore, employers must prepare the necessary documents in advance, review their financial metrics, and submit the information to the authorized agency.
Decisions regarding each company will be made on a case-by-case basis. The new rules do not provide for the automatic, mass cancellation of all deferrals on a single day.
Financial Threshold: How Much Must Be Paid to Reserved Employees
One of the main changes is the increase in the salary threshold.
Starting September 1, 2026, for most employees subject to military service at critically important enterprises, the salary must be at least three times the minimum wage. In 2026, this amounts to 25,941 hryvnia per month before taxes.
Until September 1, the previous threshold—2.5 times the minimum wage, or 21,617.50 hryvnia—applies to most of these employees. Specialized accounting publications note that the increased requirement will take effect in September, not upon the adoption of the amendments.
For certain companies operating in areas of potential or active hostilities, the reduced threshold of 2.5 times the minimum wage may remain in effect.
How to Account for Employees with Multiple Jobs
The updated rules also clarify the procedure for calculating the reservation quota.
Employees who hold multiple jobs should generally be counted toward the reservation quota based on their primary place of employment. A similar approach applies to individuals subject to military service who have already been granted a deferment on another legal basis.
The purpose of these changes is to avoid double-counting the same person within the quotas of different employers and to more accurately determine the actual number of employees a company can reserve.
What Employers Need to Do
Companies that use the reservation mechanism should:
- check the expiration date of their current status as a critical enterprise;
- determine which government agency is authorized to confirm their critical status;
- bring the average salary and compensation for reserved employees into compliance with the new requirements;
- verify the accuracy of the data in registries and employment records;
- not delay the re-confirmation of their status until the last days of August.
Up-to-date information on the economic criteria is published on the website of the Ministry of Economy of Ukraine, and the electronic reservation of employees is carried out through the “Diya” portal .
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