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On 2 June 2026, the Resolution of the Cabinet of Ministers of Ukraine (CMU) No. 692 dated 30 May 2026 “Certain Issues on Reservation of Conscripts during the Mobilization Period and Wartime” (“Resolution No. 692”) was published.

Resolution No. 692 amends CMU Resolution No. 76 dated 27 January 2023 (“Resolution No. 76”).

The key changes concern:

• The revision of sectoral and regional criteria for determining companies as critically important (hereinafter “critical” or the “critical status”, depending on the context)
• The confirmation or review of existing decisions on granting companies the critical status
• The update of salary requirements for the purposes of confirming the critical status and reserving employees
• The strengthening of control over compliance with reservation limits and the consequences of their exceeding
• The clarification of the procedure for accounting for employees working under secondary employment arrangements and those who have other grounds for deferral from military service
• The update of requirements applicable to Diia City residents for their critical status.

Resolution No. 692 provides for a number of changes to the criteria for determining companies as critical and the reservation procedure, as well as a transitional period for the implementation of these changes, in particular:

1. Revision of sectoral and regional criteria for the critical status and confirmation of the critical status of companies

Resolution No. 692 provides that central executive authorities, other state bodies, as well as region, Kyiv and Sevastopol city state administrations / military administrations:

• By 10 June 2026, should have reviewed the relevant sectoral or regional criteria.

As of the date of this news alert, certain ministries and authorities report that the criteria are being reviewed; however, the updated criteria have not yet been officially published.

• By 1 July 2026, must conduct an analysis of companies’ compliance with the updated criteria, where such companies were determined as critical based on sectoral or regional criteria. Importantly, if the
  • criterion on the basis of which a company obtained the critical status is cancelled, the company's critical status will be revoked.

To retain such status, companies must comply with the updated criteria and submit a complete set of supporting documents within the prescribed deadline. The submitted documents must be reviewed within 10 business days.

• By 1 September 2026, must review the decisions on the critical status, which were valid as of the date of entry into force of Resolution No. 692. Such decisions remain valid for the period for which they were adopted, but no later than until 1 September (except for decisions revoked on the grounds that the criterion under which the company obtained critical status has been abolished — as noted above).

This applies both to companies relying on sectoral or regional criteria and to those that obtained critical status under the general criteria of Resolution No. 76. In this regard, such companies should consider submitting documents in advance to confirm their status, in order to ensure that the documents can be reviewed and the decision adopted by the relevant authority within the specified timeframe.

In particular, the Ministry of Digital Transformation has emphasized this, given the large number of companies that will undergo the criticality confirmation procedure. The Ministry notes that if critical status is not confirmed by 1 September, the respective status will cease to be valid.

According to the position of the Ministry, even companies meeting the new criteria are required to submit supporting documents to confirm their critical status. An exception applies to companies that have been granted critical status pursuant to an order issued under the updated rules after Resolution No. 692 entered into force.

2. Increase of salary requirements

Resolution No. 692 increases the salary requirements applicable both: (1) for determining a company as critical, and (2) for reserving individual employees-conscripts.

As of 2 June 2026, as a general rule, the average salary of the company’s employees must be at least three times the minimum salary. As of 2026, this amounts to UAH 25,941. This requirement already applies to the companies submitting documents to obtain or confirm their critical status.

Also, as of 1 September 2026, the monthly salary of the reserved employees must be at least three times the minimum salary throughout the reservation period.

At the same time, for certain companies that are located and operate in the territories of possible or active hostilities or temporarily occupied territories, a lower threshold of 2.5 minimum salary has been maintained. As of 2026, this amounts to UAH 21,617.50.

3. Strengthening control over reservation limits

Resolution No. 692 strengthens control over compliance with reservation limits.

As of 2 June 2026, if the established limits on the number of the employees-conscripts who may be reserved are exceeded, the employer is required, within 10 business days from the date of such exceeding, to submit via the Diia portal an application for cancellation of the employees’ reservation.

In addition, exceeding reservation limits is expressly defined as a ground for revocation of the company's critical status. Resolution No. 692 does not specify when the critical status is revoked; however, it appears likely that such revocation would occur upon the expiry of the 10 business days allotted for submitting the above application.

4.   New approach to accounting for employees working under secondary employment arrangements and those with other grounds for deferral from military service

As of 1 September 2026, employees who have a deferral on grounds other than reservation, as well as those who work under secondary employment arrangements at another company shall be considered in the total number of employees-conscripts only at one place of employment (we note that there is no indication that it should necessarily be the primary employment).

Accordingly, for companies having employees working under secondary employment arrangements, this rule may affect the calculation of the total number of conscripts and the reservation quota.

It is expected that amendments to Resolution No. 692 will be introduced in the near future to regulate the procedure for accounting for employees working under secondary employment. The relevant mechanism is anticipated to become operational within the next 3-4 weeks.

By 1 August 2026, the Ministry of Defense, the Ministry of Digital Transformation and the Pension Fund of Ukraine must ensure the update of the relevant state electronic resources and data exchange between them for the technical implementation of these changes.

5. Updated requirements for Diia City residents

Resolution No. 692 also clarifies the criteria for critical status of Diia City residents. As before, to obtain or confirm the critical status, a Diia City resident must confirm compliance with the requirements regarding the average monthly remuneration of employees and gig-specialists (in the amount of at least the equivalent of EUR 1,200).

At the same time, starting from 2 June 2026, compliance with these requirements must be confirmed by the tax reports for the last six calendar months.

The Ministry of Digital Transformation has confirmed that, when assessing compliance with this requirement, months prior to obtaining Diia City resident status are also taken into account, provided that during such period the average monthly remuneration amounted to no less than EUR 1,200. Such months are included in the six-month period considered for the purposes of confirming critical status.

This requirement also applies to startups.

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In light of the changes introduced, businesses should consider the following practical steps:

• Check compliance with the updated criteria for the critical status
• Monitor updates and publications of sectoral and regional criteria applicable to the company
• Review the list of employees who are already reserved or planned to be reserved, in particular employees working under secondary employment arrangements
• Calculate the average salary at the company and the monthly salaries of reserved employees
• Prepare and submit the documents in advance for confirming or obtaining critical status.

EY Ukraine team can assist with analyzing your company's compliance with the criteria for the critical status, reviewing salary indicators, verifying employee lists for reservation and preparing supporting documents.