New Rules for Employee Reservation: What Changes Businesses Should Expect in Summer 2026
By Resolution No. 692 dated 30 May 2026, the Cabinet of Ministers of Ukraine introduced another set of amendments to the Resolution of the Cabinet of Ministers of Ukraine No. 76 dated 27 January 2023 regarding the reservation of persons liable for military service during mobilisation and wartime” (“CMU Resolution No. 76”).
What businesses should expect:
Higher salary threshold. The Government has increased the main monthly salary criterion for criticality-status purposes, as well as the salary level required for reserved employees, to UAH 25,941, i.e. not less than three minimum monthly salaries. Companies must ensure this level of average salary for insured employees over the last calendar month, as part of meeting the main criterion, as from the effective date of the amendments to the Resolution. At the same time, the salary of each reserved employee must meet this threshold starting from 1 September 2026.
A separate, more lenient regime is provided for critically important enterprises/institutions whose registered location is determined as, and which actually operate in, territories of possible or active hostilities. For such entities, the salary threshold remains at 2.5 minimum monthly salaries, i.e. UAH 21,617.50.
Clear boundaries for quota-control obligations and consequences for non-compliance. The Cabinet of Ministers has introduced the next stage of monitoring reservation limits. In particular, an enterprise must bring its quota limits into compliance with the requirements established by CMU Resolution No. 76 within 10 business days. Failure to comply with this obligation entails a clear consequence: cancellation of criticality status.
In addition, from 1 September 2026, the total number of persons liable for military service who may be included in the basis for calculating the reservation quota will also be reduced. From then on, employees working concurrently and employees who already have another type of deferment other than reservation will be counted toward the reservation quota only at one place of employment.
Revision of the so-called additional criticality criteria. Ministries, central executive authorities and regional military administrations must, by 10 June 2026, re-approve their own criticality criteria in coordination with the Ministry of Defence of Ukraine and the Ministry of Economy, Environment and Agriculture of Ukraine.
Following the revision of the additional criticality criteria, companies that obtained critically important enterprise status on the basis of criteria that are excluded by 10 June 2026 will lose that status by 1 July 2026.
Reconfirmation of criticality status. By 1 September 2026, the relevant authorities and regional military administrations must review the status of all enterprises that have already been designated as critically important.
Limitation of the validity period of the criticality status. Taking into account the published amendments, the validity of decisions granting critically important enterprise status is now limited. Accordingly, such decisions will remain valid only until 1 September 2026.
