New employee reservation rules from June 2026: salary, critical status and part-time workers

Employee reservation rules in 2026 have undergone significant changes. Starting in June, the salary criterion for reservation increases, the approach to part-time employees changes, and companies with critically important status must confirm compliance with the updated criteria. If the company does not pass re-confirmation, the business risks losing its critically important enterprise status – and with it, the right to reserve employees.
In this article, we will look at the new employee reservation rules in 2026, the deadlines for reviewing the criticality status of enterprises, and the practical steps businesses should take now.
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Employee reservation in 2026: what the Cabinet of Ministers has changed
The rules for employee reservation in 2026 are undergoing significant changes. The Cabinet of Ministers adopted Resolution No. 692 on May 30, 2026. It amends Resolution No. 76 – the main document regulating employee reservation and criticality status.
The current criticality status of enterprises and current employee reservations remain in force for now, but only for a transitional period: no longer than until September 1, 2026. At the same time, there are already specific deadlines for reviewing the rules:
- by June 10 the criticality criteria must be updated,
- by July 1 – enterprises must be analyzed for compliance with the updated criteria,
- and by September 1 – current decisions on criticality status must be reviewed.
If you do not confirm compliance on time, you risk losing your critically important enterprise status and the right to reserve employees. So it is not worth waiting until the end of the transitional period: it is better to think about the status in advance.
There is a separate risk for enterprises that do not meet the new criteria based on the analysis conducted by July 1. If, following the review, the enterprise loses its critically important status, the right to reserve employees may also be lost until that status is obtained again. In other words, the enterprise may lose both its status and the ability to reserve employees until its criticality is re-confirmed.
New employee reservation rules in 2026
The new reservation rules cover three key areas: the new salary threshold for reservation, the rules for part-time employees, and the review of critically important enterprise status. Let us look at each of them in more detail.
Salary for employee reservation in 2026
The salary criterion for employee reservation in 2026 is increasing. To confirm the criticality of an enterprise and to reserve a specific employee, the average accrued salary must be at least three minimum wages. In 2026, this is UAH 25,941.
For enterprises located in frontline areas, a separate, lower threshold remains in place – 2.5 minimum wages, or UAH 21,618. You can check whether your enterprise belongs to frontline areas in the current list of combat areas and temporarily occupied territories.
| Category | Minimum salary for reservation |
|---|---|
| Standard enterprises | UAH 25,941 (3 minimum wages) |
| Frontline areas | UAH 21,618 (2.5 minimum wages) |
Important nuance: this refers to the average accrued salary, meaning before taxes, not the net amount paid “in hand”.
If you plan to confirm or obtain criticality status, check compliance with the salary criterion now. If this indicator is not met at the time the documents are submitted, criticality status may be denied.
However, these changes do not apply to:
- state-owned enterprises,
- municipal enterprises.
For them, the conditions remain unchanged.
Reservation of part-time employees: what has changed
Reservation of part-time employees in 2026 works according to a new principle: one person liable for military service may be counted in the reservation quota only once, regardless of the number of places of employment.
Previously, it worked like this: a person employed by several enterprises formally increased the reservation quota for each of them. In other words, each enterprise counted that person in its total number of persons liable for military service and obtained the right to reserve more of its other employees.
But now this will no longer be possible, because part-time employment no longer creates an additional place in the quota for other employers.
The place where the employee is counted does not necessarily have to be the main place of employment. Reservation for part-time employees is also possible: if an enterprise includes a part-time employee in its quota, that employee may be reserved there. Which enterprise will count the employee in its quota has not yet been decided. But counting the same employee twice will not be possible.
The main principle:
one person liable for military service – one quota – one enterprise.
Therefore, the employer should check whether the part-time employee has already been counted in the quota of another enterprise.
What should you do if you exceed the reservation limits?
If the enterprise has reserved more employees than allowed, it must submit an application through Diia within 10 business days to cancel the excess reservations. If this is not done, the enterprise may lose its critically important status.
New criteria for enterprise criticality in 2026
The criticality criteria must be reapproved by the relevant authorities in agreement with the Ministry of Defense and the Ministry of Economy. Under the new rules, they should apply only to businesses whose activities are genuinely critical for the economy, the functioning of the population, or defense needs. This means that enterprises that obtained criticality status with minimal justification are the first to risk losing it.
The transitional period will remain in effect until September 1, 2026. During this time, current criticality status and employee reservations remain valid, unless that status expires earlier.
Important: the old critically important enterprise status is not extended automatically.
After the criteria are updated, the enterprise must confirm compliance with the new requirements. If the criterion on the basis of which the enterprise received its status is removed, the status may be canceled, along with the ability to reserve employees.
The review period for an application to confirm criticality status is no more than 10 business days. But this applies only if a complete package of documents has been submitted. If the documents are incomplete or unreliable, the review period may increase, and the employee reservation process may be put on hold.
For Diia.City residents, the employee reservation conditions are also becoming stricter. Now, compliance for criticality status must be confirmed through tax calculations for the last 6 months. At the same time, it is not enough simply to register as a Diia.City resident. Compliance with the requirements of Article 5 of the Law on the Digital Economy must be confirmed.
Will your enterprise retain its criticality status?
It is better to check compliance before the status is canceled. The buh.ua team will analyze your situation and prepare the documents.
What critically important enterprises should do now
To avoid losing status and employee reservations, businesses should not wait until the transitional period ends. The sooner they start taking action, the better their chances of retaining criticality status.
Check whether the enterprise complies with the updated criteria. The new sectoral and regional criteria must be published by June 10. As soon as they appear, compare your company against them. If the enterprise does not comply, it is better to find this out independently than to suddenly receive a decision canceling criticality status.
Review the list of employees for reservation. Separately check part-time employees to see whether they have already been counted in another enterprise’s quota. From September 1, one employee may be counted in only one quota, and if an excess is identified, the reservation will have to be canceled within 10 business days.
Assess the salary level. Check the average salary across the enterprise. It must already meet the threshold of UAH 25,941.
Prepare a complete package of documents for re-confirming criticality status. The state authority reviews the application within 10 business days, but only if the documents are complete and reliable. An incomplete package delays the review, and you risk leaving the enterprise without status. That is why it is better to prepare the documents together with accountants.
Do not postpone submitting documents until the end of the transitional period. If the documents are submitted at the last moment and you receive a refusal, there may be no time left to fix the issue.
FAQ: employee reservation and enterprise criticality in 2026
Will employee reservation remain valid during the transitional period?
Yes. Criticality status and employee reservation remain valid until the end of the period for which they were granted, but no longer than until September 1, 2026.
Do documents need to be submitted again to confirm criticality status?
Yes. There is no automatic extension of critically important enterprise status. State authorities will make decisions based on the updated criteria and only after you provide a complete package of documents.
Is the minimum salary for reservation calculated before or after taxes?
Before taxes. This refers to the average accrued salary.
Can an employee be reserved at an enterprise where they work part-time?
Yes, if this particular enterprise has included the employee in its quota. The place where the employee is counted does not necessarily have to be the main place of employment.
What happens if an enterprise exceeds the reservation limit?
The enterprise must submit an application through Diia within 10 business days to cancel the excess reservations. If this is not done on time, the enterprise may lose its critically important status.
What has changed in reservation for sole proprietors?
Nothing, reservation for sole proprietors is not provided for by law.
What should a reserved employee do?
The employee does not need to submit documents independently. They should check with the employer whether the current reservation remains valid and keep their military registration data up to date.
Conclusion
The new criticality rules do not cancel employee reservation, but they significantly complicate the conditions for businesses. Criticality status now requires a higher salary threshold, new rules for part-time employees, and new status criteria. All of this requires employers to take specific action now.
The main risk is failing to understand the new rules and deadlines. In that case, an enterprise may lose its critically important status, and with it, the reservation of all its employees.
Risking the loss of criticality status and employee reservation?
The buh.ua team will help check compliance with the new requirements and prepare documents for re-confirmation.









