The Cabinet of Ministers of Ukraine is preparing changes to the procedure for reserving liable-for-military-service employees. For Ukrainians, this will mean the abolition of 100% reservations, particularly in the "defense industry" and energy sectors, UNN reports, citing a post by Member of Parliament Yaroslav Zhelezniak, which he published on his official Telegram channel.
Details
The draft also introduces a new approach to calculating the number of reserved employees and revises the criteria for a business’s critical importance. According to the parliamentarian, the document was prepared by the Ministry of Economy. It should be emphasized separately that it has not yet been adopted, so the rules described by the parliamentarian are not currently in effect and may change during the approval process.
Which enterprises will have their reservation quotas reduced
Under the changes proposed by officials from the Ministry of Economy, even enterprises whose operations are essential to the country’s defense capability or the functioning of vital infrastructure may lose the ability to reserve their entire staff.
The most significant restrictions are proposed for the defense-industrial complex and the energy sector. Instead of the current ability to reserve up to 100% of liable-for-military-service employees, the maximum limit for such enterprises would be 85%. This applies, in particular, to fuel and energy enterprises and contractors that ensure their operation.
For heat-supply enterprises, water utilities, and household-waste management companies, the share is proposed to be reduced from 75% to 60%. For all other critically important enterprises, the overall limit would remain at 50%.
How the calculation of the number of employees eligible for reservation will change
One separate innovation concerns the rules for enterprises that can reserve up to half of their liable-for-military-service employees. They are proposing to exclude from the calculation base employees who already have a deferment from mobilization on other legal grounds. This includes, in particular, students, caregivers, and parents of three or more children. Previously, such people were taken into account when determining the maximum number of reservations.
For example, if an enterprise has 100 liable-for-military-service employees, 20 of whom have deferments on other grounds, under the current approach it could expect to receive 50 reservations. Under the proposed mechanism, the quota would be calculated based on 80 people, leaving only 40 reservations available.
Who will decide whether an enterprise is critical
The draft resolution referred to by Yaroslav Zhelezniak also provides for the creation of a Coordination Center under the Cabinet of Ministers consisting of 17 people. It is to include representatives of the Ministry of Economy, the Ministry of Defense, the Security Service of Ukraine, the Main Directorate of Intelligence, the Foreign Intelligence Service, the National Police, and other agencies. According to the information released, without a recommendation from this center, enterprises will not be able to obtain critically important status or have a reservation quota above 50% approved. The center will also be able to recommend revoking a status that has already been granted.
At the same time, the draft does not establish clear deadlines for issuing recommendations, a transparent assessment procedure, or a separate mechanism for appealing such conclusions.
What is to change by October 20, 2026
Under the draft, by October 20, ministries and regional state administrations must review the sectoral and regional criteria under which enterprises are recognized as critically important. However, attention should be paid to the fact that, at this stage, the document does not explain what will happen to reservations already оформed above the proposed limits. Therefore, there are currently no grounds to speak of their automatic cancellation.
How society reacted to the changes in the reservation rules
The initiative has already prompted objections from representatives of the defense industry. In particular, Ihor Fedirko, executive director of the Ukrainian Council of Armaments Manufacturers, emphasized that the restrictions could complicate the fulfillment of defense contracts due to a shortage of specialists.
From paper lists to "Diia": how the rules for reservation from mobilization have changed since 2022
Since the beginning of Russia’s full-scale invasion, Ukraine has changed the rules for reserving conscripts for military service several times. Over four and a half years, the procedure has evolved from paper lists to processing through "Diia," while the requirements for enterprises have become stricter.
In March 2022, the government adopted Resolution No. 194, which established the procedure for reserving employees of government bodies and enterprises that met the needs of the military and the population. The lists were approved through government bodies, while the decisions were made by the Ministry of Economy. Deferrals were granted for up to six months.
In January 2023, Resolution No. 76 introduced a system of critically important enterprises. Companies that met economic and sectoral criteria were granted the right to reserve employees. For most, a basic limit of 50% of conscript-eligible personnel was established, while exceptions were provided for.
In 2024, the rules were changed in view of the needs of the defense industry and the energy sector. Certain enterprises were allowed to reserve up to 100% of their employees, and the reservation period was extended to one year. In July, the service became available through "Diia." At the end of the year, the authorities tightened inspections and introduced a salary requirement for most private companies, set at least 2.5 times the minimum wage.
In 2025, reservation opportunities were expanded for enterprises that support the Armed Forces of Ukraine and critical infrastructure facilities. A limit of up to 75% was established for water utilities, heat-supply enterprises, and waste-management operators. Critically important enterprises in areas of hostilities were allowed to reserve up to 100% of their personnel. The law also provided for a 45-day temporary deferral for certain new employees in the defense sector who had violations related to military registration.
In 2026, the government raised the salary threshold for most private enterprises from 2.5 to three minimum wages and provided for the repeated confirmation of critical status.
We remind you
From September 1, 2026, Ukraine raised the salary requirements for reserved employees to three minimum wages. In addition, employees working part-time for multiple employers and persons with another deferral began to be counted at only one place of employment.