For Ukrainian businesses, retaining employees during mobilization is not only a way to preserve their workforce but also a legal procedure that requires strict compliance with regulations and government standards.

1. UKRAINIAN LAWS

According to the Resolution of the Cabinet of Ministers of Ukraine dated May 30, 2026, No. 692:

“To amend Resolution No. 76 of the Cabinet of Ministers of Ukraine dated January 27, 2023, ‘Certain Issues Concerning the Implementation of the Provisions of the Law of Ukraine “On Mobilization Preparation and Mobilization” Regarding the Reservation of Persons Subject to Military Service for the Period of Mobilization and in Wartime,’ as set forth in the attached amendments.”

The government’s changes are aimed at strengthening control over the soundness of decisions and the application of the “critical” status exclusively to those business entities, activities of which are of strategic importance for defense, the economy or the livelihoods of the population.

2. REVIEW OF CRITICALITY STATUS

The process of reviewing current criticality decisions and updating the criteria will take place in several phases throughout the summer of 2026.

Businesses should pay particular attention to the deadlines:

• By June 10, 2026: the relevant ministries and regional military administrations (RMA) will review sectoral and regional criteria to ensure their objectivity.
• By July 1, 2026: The authorities will assess whether the companies already identified comply with the new rules. If the criterion on the basis of which an enterprise was granted the status of “critical to the industry or community” is removed, that critical status is revoked.
• By September 1, 2026: there will be a comprehensive review of all previously adopted decisions designating enterprises as critical.

Important: All decisions regarding the criticality of enterprises remain in effect only for the period for which they were adopted, but no later than September 1, 2026.

DIGITALIZATION AND UPGRADES TO “DIA”

In general, the technical implementation of these changes can be divided into two categories: updating the functionality of e-services for businesses and synchronizing government information resources.

What will change in the digital databases?

• Within 14 days of the resolution taking effect, the Ministry of Digital Transformation will update the “Diya” portal to implement the new time limits on the validity of statuses.
• By August 1, 2026 The Ministry of Defense, together with the Ministry of Digital Transformation and the Pension Fund of Ukraine, will ensure full electronic integration between their registries to automate the verification of employee data.
• Within 3 days of the approval of any new sector-specific criteria by ministries or regional state administrations, the technical administrator is required to incorporate them into the “Dii” platform.

3. STEP-BY-STEP GUIDE FOR BUSINESSES

To successfully complete the re-certification period and retain their reservation rights, managers must follow these steps:

• monitor official announcements from the relevant ministries and regional state administrations regarding changes to sector-specific criteria by June 10;
• check the company’s metrics (wage levels, amount of taxes paid, absence of outstanding debts) in advance to ensure they meet the new, stricter requirements;
• Ensure that all data on employees subject to military service are up to date in the state registries, as electronic interaction between the Ministry of Defense and the Pension Fund of Ukraine will be enhanced by August 1.

The resolution shall take effect as of the date of its official publication, however certain technical subparagraphs, which regulate the updated process of electronic booking, will take effect in full effect as of September 1, 2026. You can review the text of the amendments to Order No. 76 directly in Resolution No. 692 of the Cabinet of Ministers of Ukraine.

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