We have already written earlier about the Government’s decision to introduce new changes in the reservation of employees at enterprises under the Resolution of the Cabinet of Ministers of Ukraine dated May 22, 2026, and the introduction of a mandatory review of the criticality status of all private enterprises through mandatory new confirmation of the criticality status of the enterprise in 2026.
Now, information has appeared about a clear deadline for confirming criticality, namely, by September 1, 2026, all Ukrainian enterprises that have the status of critical for the economy are required to undergo a re-confirmation procedure, this was stated by the Minister of Economy, Environment and Agriculture Oleksiy Sobolev during a speech in the Verkhovna Rada. Noting that exactly three months have been allocated for collecting documents and submitting business applications . According to him, this decision is designed to update the reservation lists in view of changes in the economy during martial law. How an enterprise can confirm the criticality of an enterprise by September 1, we will talk further in this article.
Why does the government require re-verification of businesses?
Reviewing the status of enterprises every one and a half years is an economically and strategically justified step, last year the real salary of Ukrainians increased by 7% above the inflation rate, so the requirements for remuneration at critical enterprises remain in force. As separately noted by the Minister of Economy, Environment and Agriculture Oleksiy Sobolev , the situation in the country is constantly changing due to inflation, changes in the budget due to military needs and new challenges of the state of war in general. The previous large-scale verification of this format, according to him, was carried out in December 2024.
Despite fears of stagnation, official data indicate a recovery in GDP. The Minister of Economy has refuted rumors of a GDP decline, noting that the economy grew by almost 2% last year. The government also forecasts growth for 2026, which will directly depend on the smooth operation of key booking companies important to the economy.
Main criteria and how criticality confirmation takes place
In 2026, the algorithm of actions for company managers to maintain the right to reserve company employees, the mechanism remains unchanged compared to 2024, because the old procedure that was in effect in 2024 has already been clearly worked out and understood, the document packages remain standard, similar to 2024. In general, in 2026, the procedure for confirming the criticality of an enterprise will be much simpler, since this time the re-confirmation of the criticality status of an enterprise will take place according to the procedure already familiar to everyone.
The most debated issue in business traditionally concerns the question of whether “ does my company fall under the new criteria for obtaining criticality status?” Here, the lawyer’s answer is simple, the only new significant criterion for confirming the “criticality” status, which has undergone changes in 2026, is an increase in the salary level to 25,941 UAH per month for employees at an enterprise that does not border a combat zone, and 21,618 UAH for businesses in a combat zone and in nearby territories .
However, the government emphasizes that in order to obtain the right to make reservations, businesses will have to obtain approval from local authorities about the reality of their activities in order to avoid abuses with fictitious reservations.
4 steps to confirm the criticality of an enterprise by September 1
- Conduct an internal audit of compliance with the correctness of military record keeping: since only 50% of employees are entitled to receive reservations on a 1-to-1 basis (where one employee has a reservation and one does not), it is worth checking the relevance of the lists of military-liable employees and the number of those subject to reservation under the quota. If the enterprise has an authorized person for compliance with the rules and military record keeping, this person should conduct an additional check of each employee for violations of the “search” due to which it will be impossible to receive a rebooking.
- Analyze the personnel composition of the enterprise: the personnel department must check whether all employees of the enterprise are employed as their “main place of work” at the enterprise that will undergo the criticality confirmation procedure . This is a new mandatory requirement to maintain the right to the 50% quota . If some employees of your enterprise are not registered as their “main place of work”, then your reservation quota is significantly reduced, or the right to a reservation is “taken off” altogether .
- Analyze the payroll : the company’s accounting department must check that the average level of wages at the enterprise is at least 3 minimum wages – 25,941 UAH for regions that do not border on places where hostilities are taking place and at least 2.5 minimum wages – 21,618 UAH for frontline enterprises.
- Create a package of documents now: do not wait until the last days to submit before the deadline of September 1. It is worth starting the procedure of preparing and collecting documents for submission to the relevant ministries or regional military administrations in the coming weeks in order to have additional time if necessary to correct errors, resubmit in case of refusal, or due to delays due to technical failures or bureaucratic problems.
Key dates and indicators of the enterprise rebooking procedure
| Characteristics of the procedure | Details and clarifications from the Cabinet of Ministers |
| Average salary requirement for frontline enterprises and businesses in the combat zone | 2.5 times the minimum wage — 21,618 UAH / month |
| Average salary requirement for all other enterprises not bordering the DB locations | at least 3 minimum salaries — 25,941 UAH / month |
| Final deadline for all businesses | September 1, 2026 |
| Preparation period for all businesses | 3 months from the start |
| Quota to update critical status | 50% of all employees |
| Quota after updating to “critical” status | 50% of the number of employees, by primary place of work at a “critical” enterprise |
| Documents to submit | Similar to the end of 2024 procedure |
| Feed algorithm | Similar to the end of 2024 procedure |
Is it possible to reconfirm the status of a critical enterprise in 2026 through “Diya”?
Reconfirmation of the status of a critical enterprise in 2026 is not carried out directly through the “Diya” portal. This state service “Diya Booking” is used for the very process of booking employees only if your enterprise is already included in the Unified List of Critical Companies . The procedure for confirming criticality requires submitting the appropriate package of documents to the relevant ministry or regional military administration (OVA), depending on who granted you this status initially.
After the authority that granted the status checks your data (including tax reporting and average salary criteria) and updates the information in the Unified List, the data in “Diya” will be updated automatically. That is, you first undergo documentary verification outside the portal, and after a positive decision, you get the opportunity to continue booking your employees without any obstacles using the “Diya” online service.
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