Higher Salaries, Tighter Limits, Status Reviews: What Is Changing in the Reservation of Employees

The Cabinet of Ministers of Ukraine has adopted Resolution No. 692 of 30 May 2026, amending Resolution No. 76 on the reservation of those liable for military service during mobilisation and wartime.

In essence, these changes are another stage in the overhaul of the reservation system. The state is not merely updating individual procedural rules but is also tightening the requirements on business: it will verify the validity of the critical-enterprise statuses already granted, raise the salary threshold, monitor reservation limits more closely, and introduce consequences for exceeding them.

Let us examine what exactly is changing, what legal consequences this will have for business, and what should be done now.

An Increase in the Salary Criterion

The key — and perhaps most painful for business — change is the increase in the salary criterion for enterprises wishing to obtain or retain critical-enterprise status.

Previously, Resolution No. 76 provided that the amount of wages accrued to employees for the last calendar month had to be no less than the national minimum wage multiplied by a coefficient of 2.5 (i.e. UAH 21,618).

Now this figure has been raised: instead of a coefficient of 2.5, a coefficient of 3 applies. In other words, the requirement for the average salary at an enterprise increases by UAH 4,323 — from UAH 21,618 to UAH 25,941.

There are, however, those who will not be affected by this change. The new threshold of 3 minimum wages does not apply to enterprises, institutions, and organisations that are located and actually operating in territories of possible hostilities, active hostilities, or temporarily occupied territories of Ukraine included in the relevant list approved by the Ministry for Development. This concerns territories for which no date has been set for the cessation of the possibility of hostilities, the end of hostilities, or the end of temporary occupation. For them, the previous threshold of 2.5 minimum wages is retained.

In simpler terms: for most businesses the salary bar is rising; for enterprises in front-line territories it remains lower.

Greater Control Over the Number of Reserved Employees

The next change concerns the reservation limit.

As a general rule, the number of reserved employees must not exceed 50% of the total number of an enterprise's employees liable for military service.

Previously, Resolution No. 76 did not directly establish liability for exceeding this limit. Now the rules are becoming stricter.

Now, if an enterprise has exceeded this limit, it must, within 10 working days, submit through the Diia Portal an application to cancel the reservation of the relevant employee. It is very important for businesses to pay attention to this aspect, because exceeding the limit may itself be a ground for revoking critical-enterprise status.

New Rules for Accounting for Part-Time Workers and Employees with Other Grounds for Deferral

Paragraph 12 of the Reservation Procedure has been supplemented with a new rule: employees who have a deferral on other grounds under Article 23 of the Law of Ukraine 'On Mobilisation Preparation and Mobilisation,' as well as part-time employees, are counted in the total number of those liable for military service at only one place of work.

This means that such employees will no longer be able to simultaneously increase the reservation limit for several employers. For example, if an employee liable for military service has a primary place of work at one enterprise and also works part-time at another, he must be counted in the total number of those liable for military service at only one employer.

The good news is that there is still time to prepare for this change, as it will not apply immediately. Resolution No. 692 provides that this rule takes effect on 1 September 2026.

A New Criterion for Diia City Residents

The changes have also affected Diia City residents. Previously, the mere fact of acquiring Diia City resident status was sufficient to meet this criterion. After the changes, this is no longer enough.

Now, additionally, the average monthly remuneration of engaged employees and gig specialists must be no less than the equivalent of EUR 1,200. The calculation is made at the official exchange rate of the National Bank of Ukraine as of the first day of the relevant calendar month.

What Else Is Changing:

In addition to the principal changes listed above, Resolution No. 692 introduces several other important innovations.

• First, the validity period of decisions on criticality already taken is now limited. Decisions recognising enterprises, institutions, and organisations as critical that are in force on the date Resolution No. 692 takes effect remain valid for the period for which they were taken, but no later than 1 September 2026.
• Second, the bodies that define criticality criteria for their sector must review those criteria. They must comply with the new wording of Resolution No. 76, be objective and well-founded, and apply only to enterprises, institutions, and organisations whose activities are of critical importance for the functioning of the economy, the livelihood of the population, or the defence needs of the state.
• Third, a review of decisions on criticality already taken is introduced. If the criterion on the basis of which an enterprise obtained critical status is removed, that status will be subject to revocation. This review must be carried out by 1 July 2026.
• Fourth, the information entered into the Unified Reservation List is clarified. Following the changes, it must indicate not only identifying information about the enterprise, institution, or organisation, but also the criteria it meets to be recognised as critical.
• Fifth, the functionality of the Diia Portal and the electronic information exchange between state bodies are to be enhanced. This is necessary to implement the new rules technically, in particular regarding the accounting of employees.

The amendments to Resolution No. 76 make the reservation system considerably stricter.

The state is narrowing the circle of enterprises that can use the reservation mechanism and tightening control over how justified that status is.

The main consequences for business are: a higher salary threshold, a review of previously granted critical-enterprise statuses, and tighter control over reservation limits.

Therefore, enterprises that already hold critical-enterprise status or plan to obtain it should carry out an internal review of their compliance with the updated requirements in advance. This will help minimise the risk of losing critical-enterprise status and having employee reservations cancelled.

Danylo Makarenko, Junior Associate at LCF Law Group, exclusively for Biz.Censor.