Reservation of individuals who may be drafted for military service: new rules from 1 September 2026

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Reservation of individuals who may be drafted for military service: new rules from 1 September 2026

The Cabinet of Ministers of Ukraine has passed Resolutions No. 692 of 30 May 2026 and No. 862 of 1 July 2026, which introduce amendments to the Procedure for the Reservation of Individuals who may be Drafted for Military Service and to the Criteria for Determining Enterprises, Institutions, and Organisations as Critically Important (Cabinet of Ministers Resolution No. 76 of 27 January 2023). Some of the changes have already taken effect since June and July 2026, while the remaining changes take effect as of 1 September 2026.

Key changes

  • the Resolutions raise the salary criterion from 2.5 to 3 minimum wages (UAH 25,941). For enterprises actually carrying out activities in frontline territories, the Resolutions set a separate threshold of 2.5 minimum wages (UAH 21,618);
  • the Resolutions expand the list of exceptions to the salary criterion. They add distribution system operators, coal-mining and coal-processing enterprises, and subsidiaries of state-owned energy companies (with a state shareholding of 90% or more) to that list;
  • if an enterprise exceeds the reservation limit, its head must file, within 10 business days, an application for cancellation of the reservation through “Diia”; exceeding the limit also constitutes an independent, direct ground for revocation of the enterprise’s status as critically important (in effect from 2 June 2026);
  • for Diia City residents, resident status alone is no longer sufficient — residents must also meet the requirements as to average remuneration, confirmed by tax calculations for the last six calendar months (in effect from 2 June 2026);
  • employees who hold secondary employment (part-time positions) at several critically important enterprises, and individuals who have a deferral on one of the grounds set out in Article 23 of the Law “On Mobilisation Preparation and Mobilisation”, count towards the reservation quota at only one place of work — the one where the employment relationship has lasted longest (in effect from 3 July 2026); and
  • from 1 September 2026, the state authorities that granted critically important status will be able to access, through “Diia”, employers’ information on the number of individuals who may be drafted for military service, reserved employees, the reservation limit, and the number of individuals reserved in excess of the established limit.

Decisions granting critical importance status that were in force as at 2 June 2026 will cease to be valid from 1 September 2026. Enterprises may restore them only by filing a new application under the updated sectoral or regional criteria. An exception applies to enterprises that, by 10 August 2026, submitted a certificate on the amount of the accrued average salary and a tax calculation for the last calendar month: their decisions will remain valid for the full term the authorities originally set, and the deferrals granted to employees will remain valid within the term of validity of the respective decision.

Additional notes

For further information on the topic please contact managing partner Mykola Stetsenko or counsel Bogdana Parkhomchuk, or by telephone +380 44 591-3355 or via e-mail.

Authors

MYKOLA STETSENKO

Managing Partner

[email protected]

BOGDANA PARKHOMCHUK

Counsel

[email protected]

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