The Cabinet of Ministers of Ukraine has initiated a major update to the regulatory framework governing the status of critical enterprises. Starting in June 2026, new macroeconomic filters will come into force, designed to verify the real contribution of businesses to the budget and minimize opaque schemes for obtaining reserve status. According to the government resolution, previously issued decisions on criticality will remain valid only until their expiration date, but no later than September 1, 2026.

People's Deputy Bohdan Kytsak confirmed that tightening the limits will change the legal status of tens of thousands of citizens. Employers that do not meet the new requirements will automatically lose the right to provide deferment from mobilization to their employees.

New economic thresholds for industries

The reform is aimed at redistributing mobilization resources and supporting the localization of production. The new rules are differentiated by key economic sectors and significantly raise the entry threshold for small and medium-sized businesses.

In the agro-industrial complex, land use requirements have been doubled: the minimum threshold for the area of arable land has increased from 500 to 1,000 hectares. At the same time, the minimum annual income of the enterprise has risen from 20 to 40 million hryvnias. Payment of personal income tax (PIT) in the amount of 324,000 hryvnias per quarter has been removed from the list of grounds for reserve status. This means that small-scale farms risk losing their right to quotas.

The forestry sector has faced even stricter conditions. Requirements for the area of land in permanent use by forestry enterprises have increased fivefold — from 500 to 2,500 hectares. A mandatory minimum annual income of 10 million hryvnias has been introduced. Small regional forestry enterprises that do not meet these indicators will be restricted in reserving personnel.

Salary coefficients and regional reporting

One of the most significant innovations has been the strict coefficients regarding the level of wages, tied to the national average (approximately 26,900 hryvnias according to the State Statistics Service).

  • For legal entities with a staff of more than 50 employees, the average salary must exceed the national average by two times.
  • For companies with a headcount of 20 employees and permanent representative offices of non-residents, this coefficient is three times.
  • For frontline territories, a lenient threshold has been maintained at the level of 2.5 minimum wages (21,618 hryvnias).

Enterprises operating in three or more regions must have a staff of at least 10 insured employees in each region. In addition, they must confirm the payment of taxes and the Unified Social Contribution (USC) in the amount of at least 24,000 hryvnias to the local budget for the last reporting quarter.

Digitalization and transition period

In accordance with the Law of Ukraine "On Mobilization Preparation and Mobilization", the definition of criticality parameters is within the exclusive competence of the Cabinet of Ministers. The Ministry of Economy stated that a transition period is provided for business adaptation: all previously issued deferments retain their legal force until their expiration.

However, starting in July, all new applications and status confirmation procedures will be accepted exclusively through departmental digital interfaces, including the "Diia" portal, strictly according to the new criteria. The new rules also completely exclude the duplication of quotas: a conscript can be counted in reserve limits only once for a specific place of work.

Leaders of business associations express concern that the sharp increase in fiscal requirements will complicate the retention of human resources for a significant part of enterprises. Nevertheless, relevant ministries and regional military administrations are obliged to re-approve their internal lists within the shortest possible time, coordinating them with the Ministry of Defense.