Employee Reservation Under the New Rules: What Cabinet of Ministers Resolution No. 692 Actually Changed

On 30 May 2026, the Cabinet of Ministers adopted Resolution No. 692, and it was published as early as 1 June. The document noticeably rewrites the conditions under which enterprises obtain and retain critically important status — and, with it, the right to reserve their employees from mobilization. At Dextra Law, we have gone through the resolution point by point, and below we explain what is already in force, what switches on from September, and why delaying in this situation is genuinely risky.

In short: the state has simultaneously raised the salary bar, shortened the deadlines for re-confirming status, and turned exceeding reservation limits into a direct ground for revoking that status. Each of these factors is manageable on its own. Together — and within such tight deadlines — they require businesses to get organized this very month.

Changes that have already taken effect

Current decisions on critical importance now have a “shelf life”

The orders that previously recognized enterprises as critically important will now remain valid no longer than until 1 September 2026. This is not an automatic extension — it is the boundary beyond which the status will have to be obtained anew under the updated criteria.

A tight schedule for state bodies and business

The resolution sets out a clear sequence of dates, and they follow one another very closely:

• by 10 June 2026, ministries and regional and city state administrations review their own critical-importance criteria;
• by 1 July 2026, the new criteria take effect;
• by 1 September 2026, a full review of previously adopted decisions takes place, and enterprises must effectively re-obtain their status.

There is a separate consequence worth understanding: if the sectoral criterion under which an enterprise was once recognized as critical is removed from the list, the status may be revoked for the company as a whole. That is why the review of criteria at ministry level is not purely “their internal business” but an event that companies should keep an eye on.

Criteria will become visible in Diia

The grounds on which an enterprise is recognized as critical will now be displayed on the Diia portal. The transparency is convenient, but it has a flip side: non-compliance will become visible just as quickly as compliance.

The salary threshold has risen

The coefficient applied to the minimum wage has risen from 2.5 to 3, and the threshold for the average salary at an enterprise now stands at UAH 25,941. An exception was made for enterprises in areas of possible or active hostilities and in temporarily occupied territories — for them the bar was kept at UAH 21,617.5 (coefficient 2.5). For business, this is above all a matter of the payroll fund: budgets will have to be recalculated so as not to “fall out” of the status over a formal mismatch.

For Diia City residents, the status alone is no longer enough

Previously, residency granted by the Ministry of Digital Transformation was sufficient. Now, in order to obtain or confirm critical importance, a Diia City resident must demonstrate that the average monthly remuneration of its employees and gig specialists over the last six calendar months was no less than EUR 1,200 at the NBU exchange rate. This is confirmed by tax calculations of income amounts and the Unified Social Contribution (USC) for that period — meaning it concerns real reporting data, not declarative intentions.

Reservation limits under tighter control

This is perhaps the most sensitive change. Exceeding the established reservation limit is now a direct ground for revoking the status of a critically important enterprise. Moreover, in the event of an excess, the company is obliged to file an application itself to cancel the “surplus” reservations via the Diia portal within ten business days. Previously the wording was softer — the employer “could take measures.” Now it is an obligation with a specific deadline, and any delay works against the enterprise.

As for confirming salary in order to obtain or re-confirm status: for most enterprises this is a certificate for the last calendar month, and for Diia City residents — the aforementioned tax calculations for six months.

Changes that will take effect from 1 September 2026

The salary of each reserved employee

The threshold will apply not only to the “enterprise average.” The monthly accrued salary of each reserved employee must be no less than UAH 25,941 (for enterprises in areas of hostilities and in temporarily occupied territories — UAH 21,617.5). Moreover, the increased salary must be accrued to an employee liable for military service throughout the entire period for which the deferment is granted. Payments must be brought into line by 1 September.

Part-time workers and other deferments count under one place of work only

Persons liable for military service who hold a deferment on other grounds (in particular, under Article 23 of the Law “On Mobilization Preparation and Mobilization”), as well as part-time workers, are now counted toward the reservation quota under one place of work only. The point of the change is clear: to avoid “double” counting of one and the same person and an accidental breach of the limit due to a technicality. The deadline for bringing HR data into line is likewise 1 September 2026.

Old vs. new wording: a brief comparison

To make the changes easier to compare, we have brought the key parameters together in a single table.

Parameter of change	Old wording / Previous conditions	New wording (per Resolution No. 692)	Implications for business
Salary level	Coefficient 2.5 (in certain cases).	Coefficient raised to 3 for certain categories. For enterprises in areas of hostilities, a threshold of no less than 2.5 minimum wages is set.	Higher payroll costs. The need to revise budgets to retain “critical” status. The same salary-level conditions apply to reserved employees — to be brought into line by 01.09.2026.
Reporting on limits	The employer “may take measures” to prevent limits from being exceeded.	Mandatory filing of an application via the Diia Portal to cancel reservations within 10 business days if limits are exceeded.	Stricter liability. Any delay in reporting the number of reserved employees becomes critical.
Loss of enterprise status	Was not clearly defined as grounds for stripping status.	Exceeding the established reservation limits is a direct ground for revoking critically important enterprise status.	High risk. Loss of status means automatic cancellation of reservation for all of the enterprise’s employees. Deadline for reporting an excess: if an enterprise has exceeded the established limits on the number of reserved employees, it must file an application to cancel the reservation via the Diia Portal within ten business days of such an excess.
Accounting for part-time workers and other deferments	Was not detailed.	Employees with a deferment under Art. 23 of the Law on Mobilization and part-time workers are counted in the total number of reserved employees under one place of work only.	The need for an HR audit to avoid “double” counting and an accidental breach of limits. Deadline for bringing into line — 01.09.2026.
Re-approval of criteria	—	By 10 June 2026, ministries and regional and city state administrations must re-approve the review of the criteria referred to in subparagraph 4 of paragraph 2 of the Criteria and Procedure governing the determination of enterprises, institutions and organizations that are critically important (this does not affect the enterprise for now); then, by 1 July 2026 there will be new critical-importance criteria, and by 1 September 2026 enterprises will need to re-obtain critical importance.	Review and possible revocation of critical importance for the enterprise as a whole if the current sectoral criteria under which the enterprise previously obtained critical importance are excluded. Tight deadlines.

What businesses should do right now

Since ministries and state administrations are reviewing their criteria as early as 10 June, we advise not putting off preparation. In practice, the priority steps look like this.

First, check your company’s current salary indicators and compare them with the new threshold of UAH 25,941 — both for the average salary and for each reserved employee individually, if you plan to maintain reservations after September. Second, conduct an internal audit of HR data and of the procedure for submitting lists: this is where double counting of part-time workers and the risk of a quiet quota breach most often hide. Third, if you are planning new reservations, build in the updated threshold straight away so as not to receive a refusal. And keep a separate eye on the limits — exceeding them now costs the entire enterprise its status, not just a specific position.

Diia City residents should pull up their tax reporting for the last six months in advance and make sure the average remuneration meets the EUR 1,200 bar. This is the kind of thing where it is better to see the figures before an inspection rather than during one.

Frequently asked questions

Need help preparing?

Issues of critical importance and reservation are now decided not only by figures in reporting but also by deadlines. If you need to check your company’s compliance with the new criteria, put HR data in order, or support the re-confirmation of status, the Dextra Law team is ready to help.

Your legal adviser — Dextra Law.