The Cabinet of Ministers of Ukraine has drafted an act providing for the automatic extension of the criticality status of enterprises whose validity expires in November–December 2026 until February 1, 2027. This is reported by RBC-Ukraine with reference to the Government Portal. The measure was introduced to ensure the uninterrupted operation of critically important enterprises during the transition to the updated reservation system, so that employees of such companies do not lose their reservations amidst changing rules.
Transition Period and Updated Rules
On October 27, the government updated the rules for obtaining and confirming the status of critically important enterprises. The new algorithm defines the stages of transition to the updated criteria, responsible executors, and the timeline for their introduction. According to the Ministry of Economy, sector-specific criteria have already been reviewed by about 90% of state bodies and agreed upon in the newly created Coordination Center. It is precisely so that critically important enterprises can operate without interruption while changes continue in the system that the draft act on the transition period has been prepared.
New Conditions for Confirming Criticality
To obtain or renew criticality, it is now necessary to fulfill two additional conditions. In particular, the list of critical spheres can be expanded upon the submission of a specialized central executive authority or regional state administration, agreed upon with the Coordination Center. This means that the circle of enterprises falling under reservation will be determined more flexibly — with the participation of sectoral and regional bodies, rather than solely through a single federal list.
What This Means for Employees
Criticality status is directly linked to the right to deferment from mobilization. Employees of critically important enterprises and certain state bodies are among the categories entitled to deferment alongside other grounds — family circumstances, health status, education, and scientific activity. The automatic extension of status until February 1, 2027, helps avoid gaps in the reservation of employees of those enterprises whose terms expire at the end of 2026.
Practical Problems
At the same time, lawyers note that in practice the procedure for confirming criticality remains complex. According to Nikita Murenko, managing partner of the law firm Murenko, Kuryavy and Partners, the number of mandatory criteria has exceeded 200, and enterprises regularly face situations where submitted document packages are not registered, stretching a process that used to take one to two working days into months. He also pointed out that the rules are established by resolutions rather than law, allowing them to be changed quickly and in a manual mode.
Context of the Decision
The decision to extend the transition period has become part of a broader restructuring of the conscript reservation system, which the Cabinet of Ministers began updating in May 2026 with the aim of making it more transparent and protected from abuses. Thus, the automatic extension of status until February 1, 2027, is a temporary measure designed to smooth out the consequences of the transition to new criteria and ensure the continuity of operations for critically important enterprises.
