New Criticality Criteria from the Ministry of Economy

By Order No. 471 dated September 11, 2025, the Ministry of Economy approved updated requirements for determining “critical” employers, while the previous criteria have become invalid. Instead of criteria set by multiple ministries, a single set of new criteria will now apply, with some conditions—such as salary level and monopoly status—removed.

The updated criteria include:

• Receiving state support in the form of grants (CMU Resolution No. 739) – confirmed by data from the authorized bank regarding fulfillment of the contract terms.
• Execution of works/services for the Ministry of Economy under contracts with a duration of at least 6 months.
• Being under the management of the Ministry of Economy or 100% state ownership with fulfillment of state orders.
• Conducting independent expertise of draft normative legal acts in the areas of economics, foreign economic activity, and entrepreneurship.
• Operating in three or more regions of Ukraine – confirmed by property rights and extracts from the State Tax Service regarding tax calculations.
• Participation in an industrial park (included in the Register) – confirmed by a contract with the managing company.
• Possession of a special investment agreement for projects involving significant investments in processing, biogas/biomethane, processing of minerals (excluding coal, oil, and gas), and waste management (in accordance with the Law on State Support for Investment Projects).
• Inclusion in the list of domestically produced machinery/equipment partially compensated from the budget (CMU Resolution No. 952).
• Production/services necessary for the continuous operation of other enterprises in sectors under the responsibility of the Ministry of Economy.