Material prepared by Natalia Slipchenko,
Senior HR Records Management Specialist/
Military Records Specialist
Department for the Provision of HR Records Management
and Payroll Accounting Services
On 22 May 2026, the Ministry of Economy announced that the Government had approved amendments to the system for reserving conscription-liable employees working at critically important enterprises.
The official text of the resolution amending Resolution of the Cabinet of Ministers of Ukraine No. 76 dated 27 January 2023 is still subject to final review following its publication. However, it is already clear that employers should prepare not only for updated salary criteria, but also for more stringent control over military records data, reservation quotas, and the confirmation of critically important enterprise status.
For large companies, this is not solely an HR or legal matter. Employee reservation depends on the quality of military records management, accuracy of HR data, payroll calculations, the relevance of employee information, and timely coordination among internal company functions.
Key expected changes
1. Tightening of salary level requirementsTo obtain or confirm the status of a critically important enterprise, as well as to reserve employees, the average salary level must be at least three minimum wages, i.e., UAH 25,941. For reference, the current threshold is 2.5 minimum wages.
An exception applies to businesses located in frontline areas: for these companies, the current threshold of UAH 21,617.50 will remain in effect.
It is also expected that, within three months — likely by the end of the summer — businesses will need to reconfirm their critically important status, including under the salary-level criterion. This requirement will not apply to all enterprises, including Diia City residents, state- and municipally owned enterprises, electricity producers, and other entities listed in the draft resolution.
Preliminarily, the new salary requirements are expected to take effect from June. However, final conclusions can only be drawn once the resolution is officially published. To minimise risks, employers may wish to ensure as early as May that the salaries of reserved employees exceed UAH 25,941.
It should also be considered that, if Draft Law No. 15224-5 is adopted, the minimum wage may increase to UAH 11,183 from 1 July 2026. In that case, given the requirement of three minimum wages, the average salary required for employee reservation and confirmation of critically important status would rise to at least UAH 33,549 (UAH 11,183 × 3).
2. Updated rules for including employees with secondary employment in the reservation quota
Employees with secondary employment will be counted towards the overall reservation quota only once and only at their primary place of employment.
Currently, the total number of conscription-liable employees does not include individuals who are already reserved by another employer, as well as women and employees registered with the Security Service of Ukraine or intelligence authorities. However, if an employee with secondary employment is not reserved at their primary place of employment and is registered with a Territorial Centre of Recruitment and Social Support, they may be counted towards the quota.
The new rules are expected to introduce an additional condition: if an employee with secondary employment has a deferment and has already been counted by another employer at their primary place of employment in the total number of conscription-liable employees, that employee cannot be counted again at their secondary place of employment.
Accordingly, employees with secondary employment who have a deferment (for example, due to a disability or because they have three or more children) will be included in the reservation quota only once — at their primary place of employment.
3. Updates to the criteria for critically important enterprises
The resolution also requires ministries, central executive authorities, and regional military administrations to review and reapprove, within one month, the criteria used to designate enterprises as critically important.
The updated criteria must be agreed with the Ministry of Defence and the Ministry of Economy in order to ensure the uninterrupted operation of enterprises and institutions that are essential to the functioning of the state under martial law.
In addition, within three months after the amendments enter into force, the status of all enterprises that already hold critically important status is expected to be reviewed.
In practice, this means that most enterprises will need to reconfirm their critically important status under the new criteria, likely by the end of the summer. This applies only to enterprises recognised as critically important for the economy and territorial communities and does not apply to enterprises recognised as critically important for meeting the needs of the Armed Forces of Ukraine.
Importantly, throughout the transitional period until the new changes are adopted, the existing critically important status of enterprises and current reservations of employees will remain valid.
If, as of the date the resolution enters into force, an enterprise holds valid critically important status that is due to expire before 15 July, that status will be automatically extended until 15 October.
If, as of the date the resolution enters into force, an enterprise holds valid critically important status that is due to expire between 16 July and 15 October, it will expire on its originally scheduled expiry date.
4. Deadlines for action if reservation limits are exceeded
Another change introduces specific deadlines for cases where reservation limits are exceeded.
Specifically, heads of critically important enterprises will be required, within ten business days from the date such limits are exceeded, to submit via the Diia Portal an electronic application to cancel the reservation of conscription-liable employees. Alternatively, instead of cancelling reservations, an enterprise may, within the same period, hire new employees who will be counted towards the quota. Previously, no such deadlines applied.
Accordingly, businesses will have a transition period to adapt to the new requirements and complete the process of reconfirming their critically important status.
What this means for employers
The expected changes shift military records management and employee reservation from a matter of one-off administrative actions to an ongoing compliance process.For large companies, this means the need for close coordination between HR, payroll, legal, accounting, and those responsible for military records management. An error in any one data set may affect the entire process — from calculating the quota to preserving the reservation of key employees.
Employers should already consider conducting a preliminary readiness assessment for the new rules. As a first step, businesses should review whether they meet the salary criteria, whether the total number of conscription-liable employees has been calculated correctly, and whether employees with secondary employment, employees with deferments, reserved employees, and individuals who should not be included in the quota have been properly accounted for.
It is also important to verify that military records data is up to date, that the necessary internal documentation is in place, that HR data is consistent with information in state registers, and that the business is prepared to reconfirm its critically important status.
For large businesses, military records management is no longer simply an administrative function. It is now a component of business continuity, workforce stability, and mobilisation risk management.
How BDO in Ukraine can support your business
The BDO in Ukraine team provides comprehensive support in military records management for large companies, including:
- auditing the current state of military records management
- verifying military records documents and HR data
- supporting employee reservation and reservation cancellation processes
- preparing the company for confirmation of critically important enterprise status
- monitoring changes in employee statuses, quotas, and documentation
- outsourcing the military records management function for companies with a large workforce or a complex organisational structure.
Given the expected changes, employers should take proactive steps now. High-quality military records management is no longer only a matter of legal compliance; it is also a tool for retaining key employees and maintaining stable business operations.
To obtain a preliminary assessment of your company’s readiness for the new reservation rules, contact the BDO in Ukraine team.
