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: 24 January 2026

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 the KVP status for the economy

Starting from 2026, a single list of criteria for private companies applies under CMU Resolution No. 76. To obtain KVP status, a company must meet two basic conditions and at least one additional criterion.

1. The average salary of employees for the last quarter must be no less than 2.5 minimum wages, i.e., at least 21,617.50 UAH in 2026. 

2. No outstanding tax debt to the state and local budgets, as well as SSC.
   

These two criteria are mandatory for all private companies that submit documents to obtain critically important status. 

In addition, as a general rule, you must meet at least one of the additional criteria described in CMU Resolution No. 76:

• €1.5 million in paid taxes and SSC per year
• €32 million in foreign currency revenues per year
• status of an enterprise from the strategic CMU list No. 83
• the enterprise is important for a sector of the national economy or a territorial community
• Diia.City resident status
• the company is an electronic communications operator with the relevant annual income 

Resolution No. 1425 dated 13.11.2025 is already in effect. If a company applies for critical status as a startup after obtaining Diia.City status, the application must include:

1. Documents confirming submission of the initial compliance report – it is submitted based on the results of 3 months following the month in which the status was obtained. In practice, this means you can apply for critical status no earlier than 4 months after registration in Diia.City.
2. Documents confirming income of at least €20,000 for the three months covered by the initial report.

Or as an alternative: you can apply for critical status based on the annual compliance report together with the auditor’s opinion – this package is submitted by June 1 based on the results of the previous year. In this case, the mandatory income requirement does not apply.

For certain categories of enterprises, Resolution No. 76 allows applying only two criteria to obtain the status of a critically important enterprise (KVP). This applies to:

• Fuel and energy complex (FEC)
• Managers of multi-apartment buildings (legal entities)
• State assay control enterprises
• Enterprises that service the property of state bodies
• Healthcare, education, science, social protection, sports, and veterinary institutions
• Linear audiovisual media (TV broadcasters)
• State and municipal cultural institutions
• Passenger and freight carrier enterprises

If such a company meets at least two criteria of Resolution No. 76, it may obtain KVP status and reserve up to 50% of military-liable employees.

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

The Ministry of Defense has officially approved how to determine defense industry complex (DIC) enterprises, aircraft manufacturing, and the space sector that are considered important for the national economy (criterion 4 in the list of optional criteria). The Ministry of Defense now accepts documents (they must be sent to admou@post.mil.gov.ua), not the Ministry of Strategic Industries.

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

The main advantage of obtaining such status is the ability to reserve up to 100% (instead of only 50%) of military-liable employees.

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

• has a government contract or participates in its execution (including foreign economic activity), and the volume of production of defense-related products for the last reporting period exceeds 50% of total production,
• received a grant under CMU Resolution No. 262 (programs for the development of innovations and technologies for defense),
• performs the functions of the body that manages defense industry enterprises.

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

1. has government contracts in the defense sector;
2. is involved in fulfilling defense orders;
3. is included in the electronic register of selection participants and government contract performers;
   
4. participates in government programs for aircraft manufacturing or space activities;
5. implements DIC development programs, introduces new technologies, or expands production;
6. manufactures goods or provides services used in the production of defense products.
   

Summary table (in simple words)

Enterprise category	Which criteria must be met	Reservation option
Main DIC manufacturers	≥1 of the 3 basic criteria	up to 100% of employees
Other DIC enterprises	≥3 of the 6 additional requirements	by decision of the Ministry of Defense

The state has provided an opportunity not only for large strategic plants, but also for related manufacturers, service providers, and innovative companies to retain specialists who are truly working for defense. If the company’s activities even partially support the defense sector, there are real chances to obtain the status and gain the right to extended reservations.

Important! 

Companies should pay special attention to complying with the requirements of paragraph 3 of clause 8 of the Reservation Procedure. If a company violates these conditions – in particular, pays a reserved employee less than 21,617.50 UAH for any month of the reservation period – it will lose its critically important status. It can be restored no earlier than 6 months after cancellation.

In addition, together with the loss of status, all active reservations granted on its basis are automatically canceled. This means that employees lose their mobilization deferment, and the company loses the right to reserve until the status is confirmed again.

How critically important enterprises are determined: who makes the decision

The system for determining critically important enterprises in Ukraine has finally received clear guidelines. The responsible authorities are: ministries and agencies, as well as Regional Military Administrations (RMAs). In other words, the former determine which enterprises are important for the country’s economy, while the latter determine which enterprises are essential for meeting the needs of local communities during a special period.

How it works in practice:

On the websites of ministries, regional and military administrations, official explanations, request templates, and lists of documents required to confirm the status of a critically important enterprise are increasingly being published.

Some regions even create detailed step-by-step guides – for example, the Kyiv RMA published a roadmap on January 9, 2025, outlining the entire process of obtaining the status. In addition, since October 30, 2025, updated criteria have been in effect in the Kyiv region: enterprises that want to confirm their importance for the community must meet one mandatory and at least two additional criteria defined by Order No. 1579. If a company also meets the requirements of Resolution No. 76, it may be recognized as critically important for the country’s economy – and this already gives the right to reserve up to 50% of its military-liable employees.

Regions such as Dnipropetrovsk, Zakarpattia, Luhansk, and Chernihiv have also done this and published new versions of the criteria. Municipal and local enterprises in these regions can already apply under the updated requirements.

Vinnytsia RMA clarified: the status will be granted to those whose primary KVED matches the area defined by the regional criteria – with supporting documents.

The Ministry of Health also revised its criteria – now private medical institutions cannot obtain critically important status through regional or military administrations.

Attention! In accordance with the requirements of Resolution No. 76, regional administrations are authorized to review requests for granting status from:

• enterprises, institutions, and organizations of municipal ownership,
• private sector entities located within the relevant administrative-territorial unit and operating in the sector,
• agriculture, forestry, or fishing,
• extractive industry and quarrying,
• manufacturing,
• electricity, gas, steam, and air conditioning supply,
• water supply,
• sewerage, waste management,
• construction,
• wholesale and retail trade,
• repair of motor vehicles and motorcycles,
• transportation, warehousing, postal and courier activities.

Documents required to obtain KVP status

To obtain “critically important” status, an enterprise submits an application to the relevant authority, requesting recognition as an entity that is important for the economy and for ensuring the functioning of the population during a special period.

The application must include:

• copies of supporting documents;
• information confirming submission of tax reporting for the last calendar quarter.
• information on the total number of military-liable employees of the company (in the form of a certificate in free form, or details from the Unified State Register of conscripts, military-liable persons, and reservists generated via Diia).
  

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

• a copy of the tax declaration with the receiving stamp of the supervisory authority;
• a receipt confirming acceptance of the declaration (if submitted electronically);
• a receipt from the tax service accepting the reporting package;
• or a postal notice with a delivery mark confirming submission of the declaration to the supervisory authority (if sent by mail).

Where to submit an application to obtain KVP status

Depending on the company’s field of activity and form of ownership, the application is submitted:

1. To the central executive authority or another state body whose jurisdiction covers the entire territory of Ukraine – if the company operates in a sector of the national economy or in an area where this body forms or implements state policy.

2. To the regional, Kyiv, or Sevastopol city state administration (or military administration) – if the company:

• has municipal ownership, or
  
• is located within the relevant region or city and operates in the following sectors:
  • agriculture, forestry, fishing,
  • extractive or manufacturing industry,
  • supply of electricity, gas, steam, and conditioned air,
  • water supply, sewerage, waste management,
  • construction,
  • wholesale and retail trade, repair of cars and motorcycles,
  • transport, logistics, postal and courier activities.

(Not) obtaining critically important enterprise status 

The authority that receives an enterprise’s, institution’s, or organization’s application must, within 10 business days from the date of receipt, verify the documents for compliance with the “criticality” criteria and make one of two decisions.

1. On the enterprise’s compliance with the “criticality” criteria
Such a decision indicates:

• the legal entity code in the EDRPOU;
• the taxpayer identification number;
• the full and abbreviated name of the enterprise;
• the criteria it meets.
  

2. On NON-compliance with the criteria
In this case, the decision must contain a reasoned justification of the grounds for refusal.

Monitoring and control after obtaining KVP status

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

Control will be carried out monthly via the Diia app, which will display information on average salary, tax payments, and the number of military-liable employees.

If non-compliance is detected during the review, the enterprise receives a request for explanation. If violations are confirmed, the “critically important” status will be revoked, and employee reservations will be canceled.

Important: if a private enterprise (except Diia.City residents) loses its status due to failure to meet the requirement to pay reserved employees at least 21,617.50 UAH per month (in 2026), it will be able to obtain it again no earlier than in 6 months.

When KVP status can be lost

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

1. Changes in criteria or failure to meet them
For IT companies, the critical factors are economic indicators: salary levels, income volume, and team size. If at least one of these parameters falls below the установлен level, the enterprise risks losing its status and, accordingly, employee reservations.

Starting January 1, 2026, monthly automatic monitoring has been introduced. If the average salary at the enterprise or the salary of a specific reserved employee falls below 21,617.50 UAH, critical status and the reservation will be canceled automatically by the system.

2. Suspension of operations or change of business profile
If a company stops operating in the sector under which it obtained the status, or changes its line of business, the “critically important” status will be automatically revoked.

3. Violation of additional conditions set by the RMA or the профиль ministry
This includes failure to fulfill state orders, staff сокращення, wage delays, or other violations recorded by supervisory authorities.

4. Missing the deadline for status confirmation
KVP status usually remains valid for one year. If the company does not submit documents for extension on time, “criticality” is automatically terminated.

Important! According to the new rules, all enterprises that obtained critical status before November 2025 must undergo mandatory re-confirmation by February 28, 2026. If documents are not submitted by this deadline, critical status and active employee reservations will be automatically canceled.

5. Loss of strategic importance
The state may change priorities: if the company’s sector 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 condition for maintaining the status is an audit of the compliance report under Law No. 1667. This is not a full financial audit, but an assessment of key indicators:

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

The auditor confirms that the report data is accurate and supported by documents. If the company does not pass the audit or submits the report without an opinion, it loses its resident status and, along with it, “criticality”.

What helps maintain KVP status

To avoid losing the status and keep reservations, IT companies should focus on three areas:

1. Proper maintenance of military personnel records.
2. Stability of financial indicators and compliance with the “Diia.City” criteria.
3. Timely completion of the compliance audit.
   

Although the law allows the possibility of correcting minor violations, in practice state authorities approach inspections thoroughly. Therefore, even small mistakes can put the status of a critically important enterprise at risk and, as a result, the reservation of key specialists.