Employee Reservation 2026 and Salary Criteria for Critical Status

Employee reservation in 2026 calls for accounting and HR to work in step. Reservation is Ukraine’s employment-based deferment from mobilization for eligible employees. As a general rule, the salary threshold for a critically important company is UAH 25,941. The company’s average salary and the amounts accrued to an individual reserved employee are checked separately. Before the lists are submitted you also need to confirm that the decision on critical status is still valid, that the company remains within its quota and that employment records are accurate.

What follows is the review sequence for a privately owned company that is obtaining the status of critically important for the functioning of the economy. Defense companies, Diia City residents, state and municipal institutions and other special categories are subject to exceptions. The rules and amounts are given as of September 21, 2026, under Cabinet of Ministers Resolution No. 76 in its current wording.

Have all earlier critical status decisions expired?

Not every decision expired on September 1. Subparagraph 1 of paragraph 2 of Cabinet of Ministers Resolution No. 692, as amended by Resolution No. 862, applies to decisions that were valid on the day Resolution No. 692 itself took effect. It limits their term to September 1, 2026, but provides for an exception.

If the company filed the certificate of average accrued salary and the payroll tax return (Ukraine’s combined payroll tax and social contribution return) for the last calendar month by August 10, 2026, as the resolution requires, its decision could keep its original term. This does not cover companies whose critical status was due to be revoked because the industry or territorial criterion on which they had been recognized was removed.

So start with your own decision, with proof that the documents were filed and with the records held by the authority that granted the status. A date in an old order does not in itself prove that the company has been through the review. At the same time, September 1 does not automatically terminate every decision without exception.

If you are advised to file documents by September 25, 2026, check what that advice rests on. September 25 is not a general statutory filing deadline: the Criteria and Procedure approved by Resolution No. 76 contain no such deadline. Under paragraph 6, the authority has to consider an application within no more than 10 working days from the day it is received. Plan your filing from the date your own status expires, leaving time to prepare and refine the documents. Confirming critical status and applying for reservation in Diia (the government’s online services portal) are two different procedures.

Which salary figures does reservation require?

The accountant has to keep two figures under control, even when the numerical threshold is the same for both.

What you check	Why	General requirement
Average accrued salary of insured persons (the company’s employees)	Obtaining or confirming critical status	At least 3 minimum wages for the last calendar month
Accrued salary of each employee on the reservation list	Meeting the salary requirement throughout the deferment	At least 3 minimum wages every month

The first requirement is set by the third paragraph of subparagraph 6 of paragraph 2 of the Criteria and Procedure, the second by the third paragraph of paragraph 8 of the Reservation Procedure. Both documents are approved by Resolution No. 76. Under Article 8 of the Law on the State Budget of Ukraine for 2026, the monthly minimum wage is UAH 8,647. The general threshold therefore works out at 8,647 × 3 = UAH 25,941.

These are accrued amounts, before tax is withheld, not what lands on a bank card. A company can pass the average salary test and still fail the individual salary requirement for one of its reserved employees. A high salary for the chief executive does not fix that.

For certain companies in areas of combat operations or occupation, the threshold is 2.5 minimum wages instead of 3, that is 8,647 × 2.5 = UAH 21,617.50. It applies both to the company’s average salary and to the amounts accrued to a reserved employee. The basis is the fourth paragraph of subparagraph 6 of paragraph 2 of the Criteria and the fourth paragraph of paragraph 8 of the Reservation Procedure.

To rely on this rule, the company must both be located in and actually operate in an area of possible or active combat operations or in temporarily occupied territory. The area has to be on the list kept by the Ministry of Development, with no set date on which the possibility of combat operations, the operations themselves or the occupation ended. A registered address alone is not enough. The full lists of exceptions for the company-wide figure and for the individual one have to be checked separately against Resolution No. 76.

How do you calculate the average salary from the payroll tax return?

For the new form of the return, the Ministry of Economy has issued guidance on calculating the average salary. For legal entities the reporting period is a calendar month, as paragraph 5 of section I of the Procedure for completing the return states directly. The ministry recommends the following formula:

Average salary = (line 1.1 + line 1.3 + line 1.4) ÷ line 092.

The numerator covers accrued salary, employer-funded pay for the first five days of temporary disability and temporary disability benefit funded by the Pension Fund of Ukraine. The denominator is the number of employees in the reporting period for whom salary was accrued, excluding those who receive service pay rather than wages. That is the figure in line 092, not a headcount or an average payroll number picked at will.

The letter is explanatory and does not create legal rules. The salary criterion itself is set by Resolution No. 76. Do not carry this formula over to the individual salary requirement for a reserved employee, and do not reuse line numbers from the old reporting form by rote.

Example. For the last calendar month, line 1.1 shows UAH 760,000, line 1.3 shows UAH 12,000, line 1.4 shows UAH 8,000 and line 092 shows 30 employees. The average salary comes to 780,000 ÷ 30 = UAH 26,000. The general threshold of UAH 25,941 is met, but with only UAH 59 to spare.

If a review shows that the correct figure for line 092 is 31 employees, the same amounts give an average of UAH 25,161.29. The criterion is no longer met. What you fix is the error in the reporting, if there is one, rather than picking a denominator that produces the answer you want.

In practice, it is worth keeping a separate calculation that cites the lines of the accepted return and reconciling it with the certificate used to confirm critical status. Off-the-books payments are no substitute for the accruals shown in the reporting. Bonuses, sick pay and corrections for earlier periods have to be classified correctly in the reporting rather than added by hand to reach the figure you need.

What else do the critical status criteria require besides salary?

For a privately owned company outside the special categories, the general rule is that it has to meet at least three criteria. Two of them are mandatory: the salary criterion and the absence of arrears on taxes and the unified social contribution. The company confirms an additional criterion separately, for example its importance to an industry or to a local community. For the special categories, paragraph 3 of the Criteria and Procedure sets different conditions.

A certificate of average salary does not stand in for the documents on the other criteria. Before filing, the accountant and the person responsible for the status should agree on the following points.

1. Which criteria apply to the company and which documents support each of them.
2. Which last calendar month the salary certificate covers and whether it matches the payroll tax return.
3. Whether proper confirmation that there are no arrears has been obtained.
4. Whether the reporting for the last tax period has been filed and whether there is proof that it was accepted.
5. When the current decision expires and which authority the package goes to.

Paragraph 8 of the Criteria and Procedure defines the package for confirming the status. Any additional industry or territorial requirements should be checked against the current decision of the relevant authority. A universal set of certificates borrowed from someone else’s successful application may not match the grounds your company relies on.

How do you check the quota and count employees with second jobs?

As a general rule, no more than 50% of the total number of employees liable for military service may be reserved. That limit is set by the first paragraph of paragraph 8 of the Procedure for companies recognized as critically important to the economy, which it calls “critically important institutions”. It is not half of the entire workforce. A higher limit or a special ground has to be confirmed separately.

Paragraph 12 defines who goes into the headcount used for the calculation. Among other things, women liable for military service and people reserved by another company are left out, while employees mobilized after May 18, 2024, are counted in. This is not a complete list, so you cannot simply take the headcount from the staffing schedule and multiply it by 50%.

A separate rule applies to employees who hold a deferment on other grounds under Article 23 of the Law of Ukraine “On Mobilization Preparation and Mobilization”, and to those who also work at another critically important company or institution. They are included in the total at one place of work only: the one where the employment relationship has lasted longest. “Main place of work” and “longest employment” do not necessarily point to the same employer.

If dismissals or another change in headcount push the company over the limit, its head must not wait for the next confirmation of critical status. Under paragraph 9-2 of the Procedure, they must file an application through Diia within ten working days from the day the limit was exceeded to cancel reservations and bring the company back within it. Recalculate the quota after each round of staffing changes, not only before a new application.

What to check if Diia will not reserve an employee?

Start by reading the reason given in the outcome of the application. The official Diia service page distinguishes between “reserved”, “not reserved” with an explanation and “not eligible for reservation”.

Situation	What to check
There is a decision on critical status, but the service is unavailable	Whether the authority that granted the status has entered the company in the Unified List of critically important companies
An employee does not show up, or the number of employees is wrong	The employment records held by the Pension Fund and how they appear in the Oberih register (Ukraine’s unified military registration database)
The person already has a reservation or another deferment	The valid ground for the deferment and the result of the check in the military register
Staffing changes have left no room within the limit	That the headcount used for the calculation is correct, plus current reservations and the rules on second jobs

To bring employment records up to date, Diia recommends using the relevant service on the Pension Fund portal. Changing a record in the company’s HR software does not in itself mean the state registers have been updated. Once a correction has been made, check the result of the data exchange and the status of the application. Confirmation of reservation appears in the electronic military registration document.

If an employee has already been mobilized, that is a different HR procedure. It is covered in our article on documenting mobilization and settlements with the employee.

Before the lists are submitted, the head of the company needs confirmed data: a valid status, the average salary calculation, control over individual accruals and the quota recalculated after the latest staffing changes. That reconciliation helps identify problems before Diia refuses the application or the deferment runs out.

UHY Prostir helps align payroll, HR administration and reporting, to support checks of the salary figures used for reservation. If you need your accruals and reported data checked before the documents go in, talk to our team.

Larysa Sterniuk (Tax & Accounting Advisory Lead)