In 2026, updated rules for exemption from mobilization came into force in Ukraine. The Cabinet of Ministers reviewed the criteria for private companies wishing to keep their employees in the rear. The main change was the tightening of requirements for the level of wages and the confirmation of the status of a critically important enterprise. Now, the right to defer conscription depends directly on the employer's financial performance.

New criteria for the private sector

According to the Cabinet of Ministers' Resolution No. 692 dated May 30, 2026, private companies claiming employee exemptions must meet strict standards. If the status of a 'Diia.City' resident previously seemed like a sufficient basis, it is no longer enough. The company must not only comply with the law but also demonstrate financial viability.

To obtain and confirm the status of a critically important enterprise, the following conditions must now be met:

  • No tax debts.
  • Timely submission of reports.
  • Average salary of employees of at least 1200 euros in equivalent for the last months.
  • Compliance with criteria regarding income and staff size.

For startups, the requirements are even higher: it is necessary to additionally confirm the attraction of investments, receipt of grants, or a certain level of income. Experts note that these measures are aimed at ensuring that deferment is granted to structures that are truly significant for the economy, and not to companies using exemptions to evade taxes or optimize their staff.

Simplified procedure and deadlines

For most enterprises where industry or regional criteria have not changed, a simplified procedure for confirming status applies. However, there are strict deadlines here as well. By August 10, 2026, such companies must provide a certificate of the average salary of employees for the last month and a tax calculation. Enterprises where criteria have changed undergo the confirmation procedure in the general order.

Former Minister of Economy Alexey Sobolev explained that the review of criteria is a fair step, given the significant increase in the number of exempted persons and the need of the Armed Forces of Ukraine for human resources. According to him, this allows balancing the interests of the economy and defense.

Risks for employers and employees

Failure to meet the new requirements entails serious consequences. If a company cannot confirm the status of a critically important enterprise, the exemption for the entire personnel will be annulled. This means that employees will lose protection from conscription and may be mobilized at any time.

It is important to understand that the employer is exclusively responsible for arranging the deferment. The employee can only ensure that their data in the 'Oberyg' registry is up to date and that their military registration document is valid. If the term of the preliminary exemption has expired and a new one has not yet been arranged, the worker is considered unexempted. This creates a high risk of mobilization, especially during periods of administrative failures.

Statistics and forecasts

As of May 2026, the number of exempted persons in Ukraine amounted to 1.3 million people. This is about 12% of all workers, while critically important enterprises provide more than 60% of the state budget revenues. Lawyer of the law firm 'Prikhodko and Partners' Nikolai Sirenko predicts that in September-October 2026, a temporary gap of 10-20% may occur, mainly for administrative reasons. This is not a loss of rights, but an 'undocumented' right that will need to be restored.

By the end of 2026, a reduction in the number of exempted persons by 5-15% is expected, i.e., reaching a level of 1.1-1.25 million people. This is effectively a return to the lower limit of existing indicators. State and communal institutions do not fall under the new rules, but for the private sector, the requirements have become significantly stricter.

What should employees do?

For those who are wanted, arranging an exemption is possible only after resolving the issue with the TCC (Territorial Recruitment Center). Exemption is granted for 6 or 12 months, sometimes for the entire period of mobilization. After this period expires, the extension procedure must be undergone. Employees should carefully monitor the actions of their employer and ensure that all documents are submitted on time. Otherwise, the risk of mobilization becomes a reality.