IMPACTA HR CLUB UPDATE
The text of Resolution of the Cabinet of Ministers of Ukraine No. 692 dated 30 May 2026, which provides for the review of decisions granting status of critical enterprise and other important changes, has appeared.
June 2026
The text of Resolution No. 692 of 30 May 2026 which provides for the review of decisions on decisions granting status of critical enterprise and other important changes, has finally appeared on the website of the Cabinet of Ministers of Ukraine.
The previously announced novelties have undergone additional changes, and the deadlines for reviewing critical status decisions have been shortened compared to the draft.
The Resolution was officially published on 2 June.
Main novelties
1. Review OF CRITERIA FOR CRITICAL ENTERPRISE STATUS AND CRITICAL-STATUS DECISIONS
Ministries, other central executive bodies and regional state administrations are obliged to:
- by 10 June 2026, revise their sectoral and regional criteria for critical enterprise status;
- by 1 July 2026, analyze previously issued critical-status decisions , taking into account the updated criteria, and revoke critical status if the relevant criterion was excluded;
- by 1 September 2026, review other critical-status decisions.
Previously issued decisions on critical status shall remain valid for the period for which they were granted, but not longer than until 1 September 2026 (except for the case of revocation due to the exclusion of the criterion).
The criteria by which the enterprise was designated as critically important will now be entered into the Diia Portal.
2. Raising the salary threshold
From the date of entry into force of the resolution, the coefficient of 3 applies for the purpose of calculating an average monthly wage across the company required for obtaining critical status (i.e. it must be at least UAH 25,941).
From 1 September 2026, the application of the coefficient of 3 will also become mandatory for determining the minimum required salary of reserved employees.
For enterprises in the frontline territories, the coefficient of 2.5 remains valid in both cases.
3. Additional requirements for Diia City residents
To obtain critical status, a resident of Diia City must now confirm the amount of the average monthly remuneration of employees and gig specialists - at the level of at least EUR 1,200 for the previous six months . Confirmation is carried out by submitting combined reports on personal income tax, military levy, and unified social tax for the relevant months.
4. Employees with deferrals and part-time employees
From 1 September 2026, employees liable for military service who have been granted a deferral from conscription into military service for other reasons determined by Article 23 of the Law of Ukraine "On Mobilization Training and Mobilization", as well as employees working for several companies, are counted in the total number of persons liable for military service (i.e. participate in the calculation of the reservation quota) at one place of work only. Based on the text of the resolution, such a place of work does not have to be the main one.
By 1 July 2026, the Ministry of Defence, together with the Ministry of Digital Transformation and the Pension Fund of Ukraine, must finalize the relevant functionality for the implementation of this rule.
5. Compliance with the reservation quota
If a company exceeds the reservation quota, a manager is obliged to cancel the reservation of the excess number of reserved employees within 10 working days.
Exceeding the reservation quota becomes the basis for the cancellation of critical status.
Most of the resolution’s provisions come into force from the date of its publication, except for the provisions on increasing the minimum monthly wage for reserved employees and counting of part-time employees and employees with a deferral.
For many companies, the revision of criteria for critical enterprise status and other novelties of the Government will be a real challenge. IMPACTA LAW lawyers will be happy to help you with the analysis of compliance with the updated requirements and the confirmation of critical status.
UPDATE WAS PREPARED BY LABOUR LAW TEAM
Inna Kostrytska
Counsel