On July 1, 2026, the Cabinet of Ministers of Ukraine adopted Resolution #862, which entered into force on July 3, 2026. This Resolution introduces amendments to Resolution #76 and clarifies the transitional provisions of Resolution #692.
Key changes include:
- enterprises with critical importance status can retain it after the September 1, 2026 deadline (set by Resolution #692) if they submit two documents by August 10, 2026: a salary certificate and a tax report for the most recent month. This does not apply to enterprises with revoked critical importance status due to a change or loss of the eligibility criteria for granting such a status
- only payroll documents instead of a full document package are required for the review of critical status decisions before September 1, 2026
- employee military reservations remain valid only for as long as the enterprise holds critical status
- starting from July 3, 2026, part-time employees and employees who already have a deferment for other reasons are counted for the reservation quota only once, and only at the workplace where they have worked the longest
- authorized bodies that granted critical status will gain access to data on the number of military-eligible employees, reserved employees, the reservation limit, and its excess via Diia
- the five-calendar-day waiting period between reservation cancellations has been removed, allowing employers to reduce excess reservations more quickly
- the list of enterprises eligible for special reservation and salary rules has been expanded to include distribution system operators, coal mining and processing enterprises, gas distribution system operators included in the sectoral list of critical infrastructure, and energy companies with a state ownership share of at least 90%
- IT companies that develop, administer, or support the Ministry of Defense information systems under contracts and without public funding are now recognized as a separate category eligible for critical status
Experts of AmCham member companies have consistently advocated for clear and workable rules governing critical enterprise status and military reservation procedures, including simplified confirmation mechanisms of critical enterprise and transparent quota management. Therefore, the AmCham welcomes these amendments and clarifications and looks forward to continued cooperation with responsible stakeholders to further enhance the relevant procedures.
