Reservation-2026: Government Changed Criteria for Critical Enterprises, Who Is at Risk

The state has tightened requirements for enterprises seeking the status of critically important for the economy, along with the right to reserve employees. This is evidenced by the Order of the Ministry of Economy, Environment, and Agriculture of Ukraine dated June 24, 2026, No. 6954.

The document establishes updated requirements for business entities in various economic sectors, including agriculture, forestry, industrial parks, ecology, and foreign representative offices.

From State Grants to Industrial Parks

The general criteria cover a wide range of enterprises whose activities are related to the responsibilities of the Ministry of Economy, Environment, and Agriculture. Enterprises that have received state grants for the development of processing industries, perform work or provide services for the Ministry of Economy under long-term contracts, are under the ministry's management, or provide independent expertise of draft regulatory legal acts in the economic sphere may be recognized as important for national economic sectors.

Separate criteria are defined for enterprises operating simultaneously in at least three regions of Ukraine, having employees in different regions, and paying taxes to local budgets in the respective territories. The list also includes participants of industrial parks and companies implementing projects with significant investments according to the Law "On State Support for Investment Projects with Significant Investments in Ukraine."

Thus, the state effectively confirms its course to support production localization, develop industrial sites, and attract capital to the Ukrainian economy.

Special Emphasis on the "Made in Ukraine" Program

One of the most interesting innovations of the order is the inclusion of enterprises whose products participate in state compensation programs. This concerns manufacturers of machinery and equipment included in the relevant lists of the Ministry of Economy and eligible for state support under the "Made in Ukraine" policy.

Effectively, the government recognizes that supporting Ukrainian production is not only an economic policy issue but also a component of national economic security. This especially applies to machine-building enterprises, equipment manufacturers for the agricultural sector, and companies providing Ukrainian producers with technological solutions of their own production.

Even Component Suppliers May Become Important

A separate criterion concerns enterprises producing products or providing services whose absence could lead to a complete halt of other enterprises. This refers to producers of raw materials, materials, components, and other resources necessary for the functioning of production chains.

This approach indicates a gradual transition by the state from evaluating individual enterprises to assessing their role in the overall economic ecosystem. Strategically important may be not only a large plant but also a manufacturer of highly specialized products without which an entire industry’s operation stops.

Agricultural Sector: Increased Land and Financial Indicators

For agricultural enterprises, the basic criteria for determining economic significance have been changed. The minimum area of cultivated agricultural land has been increased from 500 to 1000 hectares. The annual revenue of the enterprise (net income from the sale of products, goods, or services) is set at no less than 40 million UAH instead of the previous threshold of 20 million UAH. Compliance with the criteria is determined by meeting at least two of the established conditions.

There is also a requirement to submit a certified copy of the tax calculation of income amounts and the single contribution with confirmation from the controlling authority of its acceptance.

Forestry: Increased Minimum Land Area

For forestry enterprises, the minimum area of forest land in permanent use has been increased from 500 to 2500 hectares. An alternative criterion regarding the number of insured employees is set at no less than 10 persons. A minimum annual revenue of no less than 10 million UAH is also provided.

A separate list of economic activities (NACE codes) is defined to confirm compliance with forestry criteria.

Criteria Regarding Wage Levels

The order introduces criteria for the minimum average wage level for certain categories of enterprises:

• For enterprises with an average number of insured persons of at least 50 employees, the average wage must not be lower than the national average for the previous reporting year multiplied by a coefficient;
• For enterprises with at least 20 employees, a coefficient is established;
• A similar approach applies to permanent representative offices of non-residents.

Activity in Multiple Regions

For enterprises operating in three or more regions of Ukraine, additional conditions are set. Such business entities must have an average number of insured persons of at least 10 employees and confirm payment of taxes, fees, and the single contribution of at least 24 thousand UAH per region over the last three months.

The document also provides for the possibility of classifying enterprises as important for the national economy if they:

• conduct expertise of draft regulatory legal acts in the economic sphere;
• implement investment projects in defined sectors;
  are included in the lists of machinery and equipment whose cost is partially compensated from budget funds.

Employee Reservation

It should be noted that Order No. 6954 does not directly regulate the procedure for reserving employees liable for military service. However, the criteria it defines are applied to establish the economic significance of enterprises, which is one of the elements in determining enterprises that may have the status of critically important for the economy. Practically, this means that compliance with the updated criteria may be considered during:

• confirmation or granting of the status of a critically important enterprise;
• formation of lists of enterprises participating in reservation procedures;
• further checks of the enterprise’s compliance with established requirements.

Thus, the changes affect the circle of business entities that may potentially be involved in employee reservation mechanisms within the current legislation.

The updated criteria establish a more detailed approach to defining enterprises important for national economic sectors, strengthening requirements for the scale of activities, financial indicators, and wage levels.

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