The Ministry of Economy has updated the criteria for determining critically important enterprises: what the new requirements provide

Order of the Ministry of Economy, Environment and Agriculture of Ukraine No. 3650 dated 22 December 2025 has entered into force, approving the Amendments to the Criteria for determining enterprises, institutions, and organizations that are of importance to sectors of the national economy.

The document updates the approaches to determining enterprises that are critically important for the economy and for meeting the needs of the Armed Forces of Ukraine, in particular:

1. Enterprise criteria
   • A minimum number of employees has been established at not less than 10 persons.
   • New sub-criteria regarding financial indicators have been added:

   -Enterprises receiving partial compensation for agricultural machinery.

   -Enterprises with at least 50 employees and an average salary not lower than the national average for the last reported tax year multiplied by a coefficient of 2.

   -Enterprises with at least 20 employees and an average salary not lower than the national average for the last reported tax year multiplied by a coefficient of 3.

2. Land and financial criteria
   • Enterprises that have the right of permanent use of forestry lands with an area of at least 2,500 hectares, or that have at least 10 employees and annual revenue of at least UAH 10 million.
   • Confirmation is provided by financial statements, including the balance sheet and the statement of financial results.
3. Clarification of sectors and types of activities
   • The employee threshold for determining important enterprises has been increased from 500 to 1,000.
   • Clarifications have been introduced regarding wholesale trade in agricultural machinery and bioethanol production.
   • A technical correction to the numbering of paragraphs (74–88) has been made.
4. Restrictions regarding owners
   • A prohibition is established on classifying enterprises as critically important if their founders or beneficial owners are the Russian Federation, the Republic of Belarus, or countries on the FATF blacklist (except for those permanently and lawfully residing in Ukraine).

It is expected that these changes will enhance the state’s economic security and ensure the effective functioning of strategic sectors.