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In 2026, the rules regarding the exemption of liable-for-military-service employees from conscription underwent significant changes. Resolution No. 692 of the Cabinet of Ministers of Ukraine, dated May 30, 2026, altered the approaches to confirming "critical importance" status, salary requirements, quota calculations, and compliance monitoring. Subsequently, on July 1, 2026, the Cabinet of Ministers adopted Resolution No. 862, which adjusted some of the previously introduced rules—specifically regarding employees holding concurrent jobs and the transition period for critically important enterprises.

Therefore, it is crucial for employers to look beyond the initial version of Resolution No. 692 and focus on the regulations currently in force, taking into account all subsequent amendments.

 

One of the most practically significant issues concerns the accounting of employees who work for multiple employers.

Following the amendments introduced by Resolution No. 862, employees liable for military service who hold a secondary job at another critically important enterprise or institution are included in the total count of such employees at only one workplace—specifically, the one where the employment relationship has the longest duration.

This rule takes effect on July 3, 2026. Consequently, the statement that, as of September 1, all employees holding concurrent jobs are automatically counted with only one employer no longer reflects the current version of the rules.

If an employee’s other employer does not hold the status of a critically important enterprise, such concurrent employment does not, in itself, exclude the employee from the calculation of the critically important employer’s quota. In practice, this matter should be verified against up-to-date information regarding places of employment and the status of other employers.

 

Resolution No. 692 also raised the salary threshold for the majority of critically important enterprises. To confirm their status as critically important, the average accrued salary of employees must meet a set level—at least three times the minimum wage. Based on the figure applicable when the changes were introduced, this amounts to UAH 25,941.

Separate conditions apply to critically important enterprises and institutions located and actually operating in designated areas of potential or active hostilities or in temporarily occupied territories: the salary threshold in these cases is 2.5 times the minimum wage.

Certain categories of enterprises and institutions are subject to special rules or exceptions; therefore, the application of the salary criterion must be assessed taking into account the specific employer's status and type of activity.

 

Initially, Resolution No. 692 stipulated that existing decisions designating enterprises as critically important would remain in effect for the duration for which they were adopted, but no later than September 1, 2026.

Resolution No. 862 introduced an important exception. If a critically important enterprise submitted the documents regarding average wages and the corresponding tax return for the last calendar month by the established deadline—August 10, 2026—the September 1 deadline restriction does not apply to the decision regarding its status. In such a case, the decision on the enterprise's critical importance remains in effect for the duration for which it was issued, provided there are no other grounds for its revocation.

Deferrals for reserved employees remain valid for the period for which they were granted, but not beyond the validity period of the corresponding decision on the enterprise's critical importance.

 

Oversight regarding the number of reserved employees has become stricter. If an enterprise exceeds the established limit on the number of liable-for-military-service employees who can be reserved, the head of the enterprise is required—within 10 working days of the limit being exceeded—to submit an application via the Diia portal to cancel the reservation for the corresponding number of employees.

Furthermore, exceeding the established limits on the number of reserved employees is identified in legislation as a risk to the enterprise's status as a "critically important enterprise."

That is why calculating the quota should not be a one-time action performed solely at the moment the list for reservation is submitted.

 

• the current total number of employees liable for military service, used to calculate the quota;

• the presence of employees working simultaneously at multiple critically important enterprises or institutions, and the duration of employment at each workplace;

• the status of the other employers of employees holding concurrent jobs;

• whether the enterprise’s average salary and the salaries of the employees being reserved meet current requirements;

• the validity period of the decision on "critical importance" status and compliance with transitional period requirements;

• adherence to the limit on the number of reserved employees;

• the currency of employees' military registration data and internal military registration procedures.

 

Employee reservation is increasingly becoming a process of continuous monitoring rather than a one-time HR procedure. A change in an employee's workplace, the emergence of another critically important employer, or changes in the number of employees liable for military service, salary levels, or the validity period of the "critical importance" status can directly affect the available quota and existing reservations.

Therefore, it is advisable for enterprises to regularly reconcile HR and military registration data, verify quota calculations following personnel changes, and document the grounds for including or excluding specific employees in the quota determination.

 

ABEA Relocation specialists continue to monitor legislative changes and their practical application; they are ready to provide support regarding military registration, quota calculations, employee reservation, confirmation of "critically important enterprise" status, and compliance audits against current requirements.