On 30 May 2026, the Cabinet of Ministers of Ukraine adopted Resolution No. 692, which introduced amendments to CMU Resolution No. 76 dated 27 January 2023 regarding the procedure for reserving conscripts and determining enterprises, institutions and organizations as critically important. Resolution No. 692 launches a review of the current system for determining enterprises as critically important and also significantly changes certain provisions of the employee reservation procedure.
1. Loss of criticality due to non-compliance with the salary criterion
One of the key changes is the increase of the salary criterion for recognizing an enterprise as critically important. Previously, the average salary at the enterprise had to be at least 2.5 minimum wages. Following the amendments, for most enterprises this threshold has been increased to 3 minimum wages and must amount to at least UAH 25,941.
In practice, this means that if, in the tax reporting for May 2026, which must be submitted by 20 June 2026, the average salary at the enterprise is below UAH 25,941, such enterprise may be considered non-compliant with the established salary criterion, which may result in the loss of the relevant status.
At the same time, for enterprises, institutions and organizations that are located and actually carry out their activities in territories of possible hostilities, territories of active hostilities or temporarily occupied territories of Ukraine, where no date has been determined for the cessation of the possibility of hostilities, the end of hostilities or the end of temporary occupation, the previous threshold remains in place — at least 2.5 minimum wages, i.e. UAH 21,617.50.
2. Cancellation of criticality due to the loss of a sectoral or regional criterion
Central executive authorities, other state authorities and regional military administrations must, by 10 June 2026, review their own criteria under which they determine enterprises as critically important. Accordingly, some of these criteria may be amended or excluded.
For businesses, this means that the status of a critically important enterprise may be cancelled if the enterprise previously obtained such status on the basis of a sectoral or regional criterion that is excluded as a result of the review.
The relevant authorities must, by 1 July 2026, analyze enterprises, institutions and organizations that have already been determined as critically important on the basis of sectoral or regional criteria and cancel the status of those enterprises that no longer comply with the updated criteria or whose criterion has been excluded.
3. Criticality will be cancelled for all enterprises that do not obtain confirmation by 1 September 2026
Resolution No. 692 provides that decisions recognizing enterprises, institutions and organizations as critically important that are valid as of the date the Resolution enters into force remain valid for the period for which they were adopted, but no longer than until 1 September 2026. In addition, by 1 September 2026, the relevant authorities must review previously adopted decisions on determining enterprises as critically important, except for those enterprises that are already subject to a separate analysis by 1 July 2026.
Taking into account the deadlines and the practical speed of consideration of applications for obtaining or confirming the status of a critically important enterprise by commissions of central executive authorities, regional military administrations and the Kyiv City Military Administration, as well as the expected significant number of such applications, we recommend that enterprises do not postpone the preparation of documents.
After the relevant sectoral and regional criteria are updated, enterprises should prepare a full package of documents as soon as possible and submit it for consideration by the relevant commission, without waiting until the last month before the expiry of the current criticality status.
Accountor, as a reliable legal advisor, is ready to help businesses go through this process comprehensively: from the preliminary analysis of compliance with the updated criticality criteria to the preparation of documents, submission of the application to the relevant authority and further support of the employee reservation procedure.
