Changes to Military Conscription Reservation Rules as of 30 May: Amendments to Resolution No. 76

By Resolution of the Cabinet of Ministers of Ukraine No. 692 dated 30 May 2026, the Government has significantly revised the provisions of Resolution No. 76, which governs the procedure for reserving persons liable for military service. The amendments aim to revise the approach to designating critically important enterprises and eliminate practices where such status was used formally without genuine economic significance.

The overall approach for businesses is shifting from a formalistic to a substantive one: the right to reserve employees must now be justified by economic importance, demonstrated through official salary levels and compliance with established quotas.

Essence of the changes

Resolution No. 692 introduces comprehensive amendments affecting both large corporate groups and medium-sized businesses.

1. Salary criterion

The requirements regarding the minimum remuneration level for reserved employees have been strengthened.

• General rule: the salary coefficient has been increased from 2.5 to 3. Based on the current minimum wage level, this equals approximately UAH 25,941.
• Frontline territories: for enterprises located in areas of possible or active hostilities (as defined by relevant ministerial lists), a coefficient of 2.5 applies.
• Exceptions: the new requirements do not apply to state and municipal institutions, Diia City residents, religious organisations, and energy sector enterprises with 100% state ownership.
2. Review of critical status and validity periods

A gradual “reset” of critically important enterprise statuses is introduced.

• all existing decisions will expire no later than 1 September 2026;
• by 10 June 2026, authorities must update sectoral and regional criteria;
• by 1 July 2026, statuses granted under outdated criteria are subject to cancellation.
3. New employee accounting rules

From 1 September 2026, the methodology for calculating employee headcount for quota purposes will change.

• persons liable for military service who have deferrals under Article 23 of the Law of Ukraine “On Military Duty and Military Service”;
• employees working part-time — will be counted only at one place of employment.
4. Updated criteria for Diia City residents

For residents of the special legal regime, compliance will be confirmed through tax reporting.

Income and Unified Social Contribution (USC) payments for the last six months must be confirmed based on submitted reports.

Comparative table of key changes

Implementation mechanism of the new rules

The amendments integrate financial indicators directly into the reservation system.

Salary levels will be confirmed by employer-issued certificates for the most recent month. By 1 August 2026, the Ministry of Defence of Ukraine, together with the Ministry of Digital Transformation and the Pension Fund of Ukraine, are expected to implement automated verification through state registries.

It is also established that exceeding the reservation limit (generally 50% of liable employees) constitutes an independent ground for loss of critical enterprise status. In such cases, the employer must submit an application to cancel excess reservations via the electronic services portal within 10 working days.

Practical implications

The new rules will directly affect business costs, primarily in relation to payroll expenses.

For HR and legal departments, this means:

• the need for a full personnel audit by 1 July 2026;
• continuous monitoring of compliance with updated salary criteria;
• tracking updates to sectoral and regional requirements.

Key transition dates

• by 10 June 2026 — update of sectoral and regional criteria;
• by 1 July 2026 — review and cancellation of certain critical status decisions;
• by 1 August 2026 — launch of automated interagency verification;
• 1 September 2026 — full renewal of the system of criteria and statuses.

Conclusion

Despite the phased implementation of certain provisions, businesses will face a revision of criticality criteria in the near term. This creates a risk of losing critical status even before certain requirements formally enter into force, which requires timely preparation and adaptation of HR policies.