Criticality Criteria for Online Media: How to Overcome the Digital Barrier and Obtain Status

Can an online resource be considered critically important for the economy during the war? Formally, yes. But in practice, for most internet publications, the path to such status remains difficult, as merely having a website is not enough. The new edition of Order No. 67 provides a clear answer: yes, but only if professional and territorial criteria are met.

The process of reserving media employees liable for military service in 2026 is based on the enterprise obtaining the status of critically important for the national economy. The key regulatory act in this area is Order of the Ministry of Culture of Ukraine No. 711 dated June 30, 2026, which set out the criticality criteria in the information and cultural spheres in a new edition. For online media, this document became both a roadmap and a source of serious restrictions, as the state shifted the focus to physical presence, project scale, and direct support of the Defense Forces.

The Online Format Trap

The most important legal nuance for internet resources is the reservation written in the updated criteria of the cultural sphere, which is often applied to creative industries, including media.

Online projects alone are not enough. The updated criteria stipulate that cultural and artistic projects implemented exclusively in a remote format are not taken into account during evaluation. Thus, merely having an internet platform or conducting digital events is not sufficient grounds to confirm compliance with the relevant criterion.

Restrictions for commercial projects. Also not considered are events that have exclusively private, corporate, or commercial nature, do not provide free access or ticket sales, and are aimed only at entertaining a limited circle of people.

Online media can claim the status of a critically important enterprise only when it meets one of the clearly defined criteria of the information sphere. The mere fact of having a website or regularly producing news does not automatically grant such status.

If an enterprise uses criteria related to the implementation of cultural-artistic or creative projects, it is advisable to also confirm the holding of offline events, public discussions, exhibitions, conferences, printed publications, or other forms of activity that have a public character and are carried out beyond the exclusively digital environment. This increases the chances of meeting the established criteria and minimizes the risk of refusal due to formal application of the updated requirements.

Information Sphere Criteria: Where Can Online Media Fit?

Order No. 711 defines 11 specific criteria for the information sphere. Online media may comply with the following:

• Support of foreign media: Organizations that ensure the activities of foreign mass media, have cooperation agreements, and whose employees have valid accreditation from the Armed Forces.

• Strategic communications and information security: Enterprises aimed at disseminating socially important information, implementing measures on strategic communications and information security under Ministry of Culture programs.
• Artistic competitions and state product: Winners of artistic competitions for project selection aimed at creating Ukrainian cultural products under the President's initiative, provided contracts worth at least 100,000 hryvnias are in place.

Scale of activity, support for the Defense Forces, and work experience: additional criteria for creative industries

In addition to special categories of enterprises, the Ministry of Culture and Strategic Communications established additional criteria for creative industry entities, which may include some media. They are intended to confirm that the enterprise's activity has systemic social significance and is not limited to commercial activity.

One of the key conditions is the implementation of at least two nationwide or international projects within the last 12 months. Nationwide projects are those covering at least 10 regions of Ukraine, and international projects are events or initiatives implemented outside the country. Their main goal should be the promotion of Ukrainian culture, creative industries, and national cultural products.

Another important criterion is the social activity of the enterprise. To confirm compliance, at least three projects aimed at supporting servicemen and war veterans must have been implemented in the past year. Such projects may include information campaigns, cultural events, charitable initiatives, or other activities with confirmed social character.

Work experience and main economic activity profile. The enterprise must be registered and actually operate for at least three years. In addition, its main economic activity must be included in the List of economic activities belonging to creative industries, approved by Cabinet of Ministers of Ukraine Order No. 265-r.

For most online publications, these criteria may become the most realistic basis for obtaining the status of a critically important enterprise. At the same time, merely producing informational content is not enough. It is necessary to document the scale of implemented projects, their social significance, activities supporting the Defense Forces of Ukraine, and compliance with requirements regarding the duration of operation and the relevant economic activity code. The combination of these circumstances may indicate the enterprise's importance for the functioning of the industry under martial law conditions.

Publishing Direction as a Separate Opportunity for Online Media

Another mechanism for obtaining the status of a critically important enterprise may be conducting publishing activities. If online media simultaneously functions as a publisher, it may claim compliance with certain criteria established for publishing entities.

For this, the enterprise must meet the following conditions:

• Implement at least two book projects (excluding school textbooks) within the last 12 months;
• Ensure their distribution and promotion in at least eight regions of Ukraine or at least two foreign countries;
• Be included in the State Register of publishers, manufacturers, and distributors of publishing products;
• Have the main economic activity code KVED 58.11 "Book publishing";
• Be registered no later than January 1, 2022.

Practical Significance

Analysis of current Ministry of Culture orders shows that the state's approach to defining critically important enterprises in the information and creative industries has significantly changed. Priority is given to entities that can document the social significance of their activities, participation in implementing state information policy, support for the Defense Forces of Ukraine, the scale of their own projects, or execution of state programs.

For most online media, practical steps may include:

• Expanding activity formats — implementing not only digital but also offline projects, conferences, exhibitions, presentations, or other socially significant nationwide events;
• Participation in supporting servicemen and veterans with proper documentary evidence of relevant informational or social projects;
• Cooperation with the state through participation in artistic competitions, information campaigns, or execution of state contracts in the field of strategic communications;
• Compliance with organizational requirements, including main KVED, work experience, and, if necessary, registration as a publishing entity.

At the same time, it should be noted that for certain criteria, especially when executing state contracts or implementing projects within special programs, the status of a critically important enterprise is granted only for the duration of the respective work, but not more than 12 months. This means that the enterprise must not only meet the established requirements once but also systematically confirm their fulfillment to maintain such status.

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