Ukraine’s leading business associations have opposed new restrictions on reserving conscription-eligible employees. They warn the government about risks to the economy, defense production, and the operation of critical enterprises. Business representatives have repeatedly called on the authorities to hold consultations and take employers’ position into account. The government promised dialogue and held a meeting with entrepreneurs on October 29; however, no specific agreements were reached on revising the reservation rules, UNN writes.
Business associations oppose new restrictions on reservations
The changes proposed by the Cabinet of Ministers to the procedure for reserving conscription-eligible employees have triggered a wave of criticism from Ukrainian businesses. Representatives of leading business associations, employers, the defense-industrial complex, the aviation sector, energy companies, and other strategically important sectors of the economy have opposed reducing the possibilities for reservations.
In particular, their concerns were voiced by the Union of Ukrainian Entrepreneurs, the Federation of Employers of Ukraine, the Ukrainian Air Transport Association, representatives of defense companies, and think tanks.
Despite differing sectoral interests, business associations and analysts agree that changing the reservation rules without an adequate transition period and an assessment of the economic consequences could lead to the loss of skilled workers, reduced production, disrupted contracts, and lower tax revenues.
The government’s plans to reduce reservation quotas for defense-industrial and energy-sector companies caused particular concern. Business representatives emphasized that for many production facilities, even the loss of several highly specialized professionals could mean a halt to technological processes. Such employees cannot be replaced quickly, as their training requires considerable time.
Businesses warn of airlines halting operations and defense contracts being disrupted16.10.26, 16:30
Businesses are also drawing attention to the constant changes in the reservation rules. Companies obtained critical-enterprise status, drew up production plans, signed contracts, and assumed obligations based on the mechanisms for reservations in force at the time. Revising these conditions without sufficient time for adaptation creates additional risks for their operations.
Entrepreneurs emphasize that strengthening mobilization must not be carried out by weakening enterprises that supply the army, ensure energy stability, and generate revenues for the state budget.
The government promised consultations: did it hear the entrepreneurs?
Business representatives and the expert community called on the Cabinet of Ministers not to make decisions without prior discussion with employers and representatives of strategic sectors.
Businesses insisted on the need for consultations during which the actual needs of enterprises for skilled personnel, possible losses to the economy, and alternative mechanisms for meeting the state’s mobilization needs could be assessed. The government, for its part, agreed with the demand.
On October 29, a working meeting chaired by Prime Minister Serhii Koretskyi was held with the participation of representatives of the Ministry of Economy, the Ministry of Internal Affairs, the State Emergency Service, civil society organizations, and businesses.
The meeting addressed the reservation of conscription-eligible employees, the working conditions of enterprises during air-raid alerts, and problems arising in connection with the new regulatory requirements.
The Union of Ukrainian Entrepreneurs told UNN in a comment that during the meeting it once again emphasized the need to ensure predictability of the reservation rules.
We insist on retaining the existing critical-enterprise status until the expiration of the relevant decisions for companies that comply with the requirements on the basis of which they were granted this status. The transition to updated criteria must provide sufficient time for adaptation
In addition, representatives of the Union raised the issues of procedural transparency, shortening the deadlines for document reviews, and the possibility of retaining employees necessary for the uninterrupted operation of critical production facilities.
However, businesses have not yet received any concrete results regarding a revision of the reservation rules.
The specific changes to the reservation system and the timelines for their introduction were not determined at this meeting. The Union continues to advocate for transparent procedures and the involvement of business in preparing further decisions
It turns out that the consultations insisted upon by entrepreneurs took place only after the government adopted the resolution. At the same time, the issue of taking businesses’ reservations into account and the possible revision of controversial provisions remains open.
At the same time, the meeting with the Prime Minister also addressed specific problems that could arise as early as the coming months.
As one of the meeting’s participants, who wished to remain anonymous, told UNN, particular concern is being caused by the situation involving enterprises whose status as critically important expires in November–December. Business representatives proposed that the Cabinet of Ministers provide for the automatic extension of this status for at least two months so that companies would not lose the ability to reserve employees during the transition to the new mechanism.
According to him, the main problem is that the full operation of the new Coordination Center, through which enterprises’ documents are to be processed, has not yet been established. At the same time, the mechanism provided for allows documents to be considered within a month. For companies whose status as critically important is expiring, such a wait could result in the loss of the ability to reserve key employees. For production facilities with continuous technological processes, this could threaten stable operations and the fulfillment of contractual obligations.
If an enterprise already has the status of critically important, meets the established criteria, and continues its operations, it should not lose the ability to reserve employees merely because the new verification mechanism has not yet begun operating properly
Business representatives hope that the government will take these risks into account and ensure the prompt and transparent consideration of documents without additional bureaucratic procedures.
It is extremely important for enterprises to have clear rules and predictable timelines for document processing. After all, they should not lose the ability to reserve employees because of delays in the work of state bodies
At the same time, according to UNN, no specific agreements on changing the reservation rules or the timeline for their introduction were reached during the meeting. The government preliminarily agreed to consider extending the status of critically important enterprises, but there is still no official position on the matter.
The government made decisions despite reservations from its own ministries
Entrepreneur and leading analyst at the EAC Vladyslav Smirnov reported that on October 22 he approached Prime Minister Serhii Koretskyi with a proposal to revise approaches to reserving employees of the state apparatus and to provide statistics on the number of reserved conscripts in different categories.
On October 22, I addressed Prime Minister Serhii Koretskyi with an open letter and an official proposal: to establish a maximum reservation quota of 50% for the civilian state, local-government, and law-enforcement apparatus; to review position-related privileges; and to end administrative experiments involving critically important enterprises
In response, according to him, the Cabinet of Ministers did not provide the information Smirnov had requested. Instead, the documents state that certain ministries had expressed reservations about the proposed changes, but some of these comments were not taken into account.
In particular, according to Smirnov, the Ministry of Digital Transformation opposed the creation of a Coordination Center for organizing the reservation of conscripts, warning of duplication of functions, additional administrative barriers, and the risks of subjective decisions.
The Ministry of Justice drew attention to granting the advisory body powers that do not correspond to its status.
In addition, the National Agency on Corruption Prevention identified corruption-generating factors in the proposed regulation. Some of the comments were addressed, but certain provisions that allow for ambiguous application of the rules remained.
A separate issue concerns the economic justification for government decisions. According to Smirnov, the documents he received did not include calculations of possible losses in production and tax revenues, or risks to the fulfillment of defense contracts.
Also, according to his information, a 95-percent reservation quota is предусмотрено for some enterprises in the defense-industrial complex and energy sectors, with the possibility of exceeding it subject to additional approval.
Reservation in exchange for mobilization — the government's new idea
Another contentious issue was the proposed model of interaction between the state and business, under which enterprises could be allowed to reserve up to 100% of their employees provided that they ensured a predictable replenishment of the Armed Forces.
According to Vladyslav Smirnov, the minutes dated October 23 contain an instruction to develop a mechanism that would allow for full reservation in exchange for sending up to 1% of liable-for-military-service employees to the army each month.
Solomiia Bobrovska, chair of the Subcommittee on Human Capital Development of the Verkhovna Rada Committee on National Security, Defense and Intelligence, criticized the idea of a new social contract between the state and business.
Responsible businesses do not hide their employees. They officially employ them, submit the necessary documents, pay taxes, and operate within the law
In her opinion, instead of increasing the mobilization burden on transparent enterprises, the state should focus on identifying fictitious reservations, questionable employment, and other abuses.
The lawmaker also drew attention to the fact that production depends on qualified engineers, workers, and technical specialists who cannot be quickly replaced.
Factories employ engineers, qualified workers, and specialists who maintain equipment, perform physically demanding work, and ensure the continuity of technological processes. They cannot simply be replaced the next day. Some of these specialists take years to train
In addition, Bobrovska also questioned the need to create a new Coordination Center for Organizing the Reservation of Persons Liable for Military Service, including the advisability of involving representatives of intelligence agencies in its work.
I believe there is no need to create another coordinating structure, because all the necessary tools to resolve these issues already exist, at least within the Cabinet of Ministers
The situation surrounding reservations demonstrated differences between the government's approaches and employers' expectations. Representatives of leading business associations opposed tighter restrictions, warned of possible economic consequences, and demanded consultations before decisions were adopted. The authorities promised dialogue and held a meeting with entrepreneurs. However, it is still unclear whether the business community was heard.