Critically Important Enterprise (CIE): How to Obtain the Status, New Criteria, and 100% Employee Reservation in 2026

The author of the article: Philipp Orlov

Modified date: 04 December 2025

Critically important enterprises are the foundation of national stability during wartime. They ensure the functioning of energy, defense, transport, healthcare, communications, the agricultural sector, and the IT industry. The CCE status gives companies the right to defer employees from mobilization, confirms their strategic importance, and simplifies cooperation with government authorities.
However, obtaining this status is not easy – a company must meet clear economic indicators, have no tax debts, and comply with specific criteria.In this article, I explain in detail who can qualify for the status, which documents are required, what mistakes companies most often make, and how to avoid losing their “critical importance.”

Critical enterprises (hereinafter – CE) are those without which the economy and national security cannot operate stably. These include enterprises in the fields of energy, defense, transportation, healthcare, communications, agriculture, and IT.

The CE status allows companies to defer conscription for their employees, simplifies interaction with government authorities, and confirms the strategic role of the business in the functioning of the country. But obtaining it is not just a formality – you must go through a full “selection process”. 

How exactly to obtain this status, who can apply, what documents are required, what may lead to the status being revoked, how to avoid common mistakes, and what nuances companies with CE status must pay special attention to – we will break it down in detail further in the article. If you still have questions after reading – do not act blindly. Consulting with an accountant or tax lawyer will help tailor the solution to your specific business and avoid unpleasant surprises.

Who can obtain the status of a critically important enterprise

Only legal entities – enterprises, institutions, and organizations – regardless of ownership type or industry – can obtain this status if they meet the defined criteria. 

• critically important for the economy;
• critically important for the needs of the Armed Forces of Ukraine and other military formations. A separate category includes companies working for the needs of the Armed Forces or the defense sector: for them, the decision is made by the Ministry of Defense under a special procedure.

Sole proprietors (FOP) are not included in this list. 

Basic criteria for obtaining CE status for the economy

Since 2025, private companies must comply with a unified list of criteria from CMU Resolution No. 76. To obtain CE status, an enterprise must meet two basic conditions and at least one additional criterion.

1. The average salary of employees for the last quarter must be not less than 2.5 minimum wages, meaning not less than 20,000 UAH in 2025. 

According to draft law No. 14000, the minimum wage in 2026 will be 8,647 UAH, so the salary criterion will be not less than 21,617.50 UAH.

2. No debt in paying taxes to state or local budgets, as well as Unified Social Contribution (USC).
   

These two criteria are mandatory for all private enterprises applying for CE status. 

In addition, at least one of the additional criteria from Resolution No. 76 must be met:

• 1.5 million euros paid in taxes and USC per year
• 32 million euros in foreign currency revenue per year
• status of an enterprise from the strategic list of CMU No. 83
• enterprise important for a national economy sector or a local community
• status of Diia.City resident
• enterprise is an electronic communications operator with required annual revenue 

Important! Amendments to the Law are not yet approved, but Resolution No. 1425 of 13.11.2025 is already in effect. If a company applies as a startup after obtaining Diia.City residency, it must add:

1. Documents confirming submission of the initial compliance report – submitted for 3 months following the month of residency. Meaning, it is possible to apply only after 4 months from Diia.City registration.
2. Documents proving at least 20,000 euros in revenue for those three months covered by the initial report.

Alternatively: CE status may be obtained based on the annual compliance report with an auditor’s conclusion – submitted by June 1 for the previous year.

For certain categories of enterprises, Resolution No. 76 allows applying only two criteria to obtain CE status. This applies to:

• Fuel and energy sector
• Managers of multi-apartment buildings (legal entities)
• Assay supervision state enterprises
• Enterprises servicing state property
• Healthcare, education, science, social protection, sports, veterinary institutions
• Linear audiovisual media (broadcasters)
• State and municipal cultural institutions
• Passenger and freight transport companies

If such a company meets at least two criteria from Resolution No. 76, it may obtain CE status and defer up to 50% of conscription-eligible employees.

Updated rules for defense industry enterprises: who can obtain status and defer up to 100% of employees

The Ministry of Defense officially approved how to determine defense industry, aviation, and space sector enterprises important for the national economy (criterion 4 in the list of optional criteria). The Ministry of Defense now receives applications (email: admou@post.mil.gov.ua), instead of the Ministry of Strategic Industries.

Enterprises that have already received this status do NOT need to reapply.

The key advantage of the status is the ability to defer up to 100% (not just 50%) of conscription-eligible employees.

An enterprise may obtain status if it meets one of the following conditions:

• has a state defense contract or participates in it (including foreign activity), and defense products make up more than 50% of total production in the last reporting period,
• received a grant under CMU Resolution No. 262 (innovation and technology programs for defense),
• performs the functions of a management body of defense enterprises.

If an enterprise does not meet these requirements, it may still qualify as important for the national economy if it meets at least 3 out of 6 conditions:

1. has state defense contracts;
2. is involved in defense orders;
3. is included in the electronic registry of participants and executors of defense contracts;
   
4. participates in aviation or space programs;
5. implements defense development programs, introduces new technologies, or expands production;
6. produces goods or services used in defense production.
   

Simplified summary table

Category	Required criteria	Deferment
Main defense manufacturers	≥1 out of 3 basic criteria	up to 100% of employees
Other defense enterprises	≥3 out of 6 additional conditions	by decision of MoD

The state has enabled not only large strategic plants, but also related manufacturers, service, and innovative companies to retain specialists who truly contribute to defense. If an enterprise at least partially supports the defense sector, it has real chances to obtain status and extended deferment rights.

Important! 

Enterprises must strictly comply with the requirements of subparagraph 3, clause 8 of the Deferment Procedure. If these conditions are violated – e.g. a deferred employee receives less than 20,000 UAH in any month (in 2026 – 21,617.50 UAH) – the CE status will be revoked and may be restored no sooner than 6 months after cancellation.

Additionally, losing CE status automatically cancels all deferments granted on its basis. This means employees lose deferment from mobilization and the enterprise loses the right to defer until the status is restored again.

How critically important enterprises are determined: who makes the decision

The system for determining critically important enterprises in Ukraine has finally received clear rules. The responsibility lies with: ministries and agencies, as well as regional military administrations (RMAs). The former determine enterprises important to the national economy, while the latter – those needed to support local communities during a special period.

How it works in practice:

Websites of ministries and regional military administrations increasingly publish official guidelines, application templates, and document lists required to confirm CE status.

Some regions even prepare step-by-step guides – for example, the Kyiv RMA published a roadmap on January 9, 2025, outlining the entire application process. Moreover, since October 30, 2025, updated criteria apply in the Kyiv region: enterprises seeking to confirm importance to the community must meet one mandatory and at least two additional criteria from Order No. 1579. If a company simultaneously meets the requirements of Resolution No. 76, it may be recognized as critically important for the national economy – giving the right to defer up to 50% of conscription-eligible employees.

Regions such as Dnipropetrovsk, Zakarpattia, Luhansk, and Chernihiv have also published updated criteria. Municipal and local enterprises there can already apply under the new rules.

Vinnytsia RMA clarified that status will only be granted if the company’s main NACE code matches an economic area defined in regional criteria – with supporting documents.

The Ministry of Health also updated its criteria – private medical institutions can no longer obtain CE status through regional or military administrations.

Attention! Under Resolution No. 76, RMAs are authorized to review applications from:

• municipal enterprises, institutions, and organizations,
• private sector companies located in the administrative region and operating in sectors such as:
• agriculture, forestry, or fishing,
• mining and quarrying,
• manufacturing industry,
• electricity, gas, steam and air conditioning supply,
• water supply,
• wastewater management and waste treatment,
• construction,
• wholesale and retail trade,
• repair of motor vehicles and motorcycles,
• transport, warehousing, postal and courier services.

Documents required to obtain CE status

To obtain the status of “critically important”, the enterprise submits a request to the relevant authority – asking to recognize its importance for the economy and the functioning of the population during a special period.

The request must include:

• copies of supporting documents;
• information on submission of tax reports for the last calendar quarter.
  

Submission of tax reporting is confirmed by one of the following documents:

• a copy of the tax declaration with a mark from the controlling authority confirming receipt;
• a receipt confirming acceptance of the declaration (if submitted electronically);
• a receipt from the tax authority that receives the reporting package;
• or a postal notification with a delivery mark confirming submission of the declaration to the tax authority (if sent by mail).

Where to submit a request to obtain CE status

Depending on the field of activity and form of ownership, the enterprise submits its request to:

1. A central executive authority or another state authority whose jurisdiction extends throughout Ukraine – if the enterprise operates in a sector of the national economy where this authority forms or implements state policy.

2. A regional, Kyiv or Sevastopol state administration (or military administration) – if the enterprise:

• has municipal ownership, or
  
• is located within the respective region or city and operates in one of the following sectors:
  • agriculture, forestry, fishing,
  • mining and manufacturing industries,
  • electricity, gas, steam, air conditioning supply,
  • water supply, sewerage, waste management,
  • construction,
  • wholesale and retail trade, repair of motor vehicles and motorcycles,
  • transport, logistics, postal and courier services.

Granting (or not granting) the status of a critically important enterprise 

The authority that receives the enterprise’s request must within 10 working days verify compliance with the criteria of “critical importance” and make one of two decisions.

1. On compliance with the criteria of “critical importance”
This decision will specify:

• the enterprise’s EDRPOU code;
• the taxpayer registration number;
• the full and short legal name of the enterprise;
• the criteria that it meets.
  

2. On NON-compliance with the criteria
The decision must include a well-reasoned explanation for the refusal.

Monitoring and control after CE status is granted

After obtaining “critically important” status, enterprises will be under constant monitoring to ensure compliance with the established criteria.

Control will be carried out monthly through the Diia app, which displays information on average salaries, tax payments, and the number of conscription-eligible employees.

If a violation is identified during the review, the enterprise will receive a request for explanation. If the violation is confirmed, CE status will be revoked, and the deferment of employees – cancelled.

Important: if a private enterprise (except Diia.City residents) loses CE status due to failing to pay deferred employees at least 20,000 UAH per month (in 2025), it will not be able to reapply earlier than 6 months after revocation.

When a Company May Lose the CCE Status

The status of a critically important enterprise is NOT granted indefinitely – it can be revoked in several situations. Below are five main scenarios when this may happen.

1. Change of criteria or failure to meet them
For IT companies, the critical indicators are salary level, revenue volume, and team size. If at least one of these parameters drops below the required threshold, the company risks losing the status and, accordingly, the ability to defer employees from mobilization.

2. Termination of activity or change of business profile
If a company stops operating in the field for which it obtained the status or changes its area of activity, the status of “critically important” is revoked automatically.

3. Violation of additional conditions from the RMA or the relevant ministry
This refers to non-performance of government contracts, staff reduction, salary delays, or other violations recorded by supervisory authorities.

4. Missed deadline for status confirmation
The CCE status is usually valid for one year. If a company fails to apply for renewal in time, the “critical importance” status is terminated automatically.

5. Loss of strategic importance
The state may change its priorities: if the industry of the company is no longer considered critical for the economy or defense – the status is canceled.

How Diia.City Residents Can Maintain Their Status

For IT companies that are residents, the main requirement for maintaining the status is an audit of the report confirming compliance with the requirements of Law No. 1667. It is not a full financial audit, but an assessment of key indicators:

• the average monthly remuneration – at least €1200;
• the average number of employees and gig-specialists – minimum 9 people;
• the share of qualified income – from 90%.
  

The auditor confirms that the data in the report is accurate and supported by documentation. If a company fails the audit or submits the report without the conclusion – it loses resident status, and with it the “critical importance”.

What Helps to Preserve the CCE Status

To avoid losing the status and maintain deferral rights, IT companies should focus on three areas:

1. Proper maintenance of military registration records of personnel.
2. Stability of financial indicators and compliance with Diia.City requirements.
3. Timely completion of compliance audits.
   

Although the law allows the possibility of correcting minor violations, in practice state authorities approach inspections thoroughly. Therefore, even small errors can threaten the status of a critically important enterprise and, as a result, the ability to defer key specialists from mobilization.