CMU Resolution No. 1608: New Rules for Employee Reservation
On December 8, 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 1608, which introduced changes to the procedure for reserving conscripted employees of critically important enterprises. Dextra Law legal company has prepared an overview of the innovations for your business.
Transitional Provisions Until February 1, 2026
Until February 1, 2026, a special regime is established:
- The employee reservation procedure is carried out within 24 hours
- Cancellation of reservation for employees of critically important enterprises occurs without considering the standard period once every 5 days
Changes to the Reservation Procedure
Temporary Reservation for Violations
The possibility to reserve conscripted employees who have violations for 45 calendar days has been established. Enterprises can retain employees while resolving issues with violations.
Limitation on the Number of Employees for Reservation
Limits have been set for enterprises of various categories:
- Enterprises of the Defense Industrial Complex
- Enterprises of the Fuel and Energy Complex
- Other critically important enterprises
The number of conscripts subject to reservation must not exceed the indicator specified in the criticality decision.
Digitalization Through Diia Portal
For enterprises operating in territories of possible or active combat operations, the possibility of submitting notifications about changes in reservation limits through the Diia Portal has been introduced. Administrative procedures under martial law have become simpler.
Procedure for Increasing Reservation Limit
The resolution details the procedure for increasing the reservation limit for conscripted employees. Enterprises can promptly respond to changes in production needs.
Re-reservation Without Waiting
“Re-reservation of conscripted employees for a new term based on confirmation of critically important enterprise status is carried out without considering the 72-hour period”
Expansion of Grounds for Deferment Cancellation
New grounds for cancellation of mobilization deferment have been added:
- Submission by a state authority
- Submission by a local government body
- Initiative of the critically important enterprise itself in case of exceeding reservation limits
Changes to Criteria for Determining Critically Important Enterprises
Expansion of Document List
The application for determining an enterprise as critically important now includes information about the total number of conscripted employees and detailed personnel structure of the enterprise.
Clarifications in Orders
The order determining an enterprise as critically important must specify the number of conscripts subject to reservation. This establishes transparency of the procedure and clarity of limits for each enterprise.
Regulatory Framework
Changes have been made to the following regulatory acts:
- CMU Resolution of January 27, 2023 No. 76 “On Approval of the Procedure for Reservation of Conscripts for Enterprises, Institutions and Organizations for the Period of Mobilization and Wartime”
- CMU Resolution of October 28, 2022 No. 1215 “On Approval of Criteria for Assessing the Degree of Risk from Economic Activity and Determining the Frequency of Planned State Supervision (Control) Measures”
Practical Implications for Business
CMU Resolution No. 1608 introduces changes to reservation procedures:
- Acceleration of administrative reservation procedures
- Strengthening control over compliance with limits
- Digitalization of processes through Diia Portal
- Increased system flexibility under martial law
Timely received and analyzed information will help your business adapt to new legislative requirements.
Professional Assistance with Employee Reservation
Legal company Dextra Law provides services for reservation of conscripted employees:
- Analysis of reservation opportunities for your enterprise
- Document preparation for obtaining critically important enterprise status
- Support of the reservation procedure through Diia Portal
- Consultations on compliance with limits and legislative requirements
- Legal support during inspections
Ensure stable operation of your business with professionals in military law.
Order Military Conscript Reservation Service
Dextra Law — your reliable partner in wartime legal matters
