From the New Year, part of Ukrainians will be deprived of protection from the draft: the factor is indicated.

Military ID Photo: Ministry of Defense

The government makes adjustments to the requirements for the strategic importance of companies, “salary limits” for entrepreneurship and volumes for number of reserved. In 2026, provisions regarding reservation will also undergo changes: the “salary threshold” will be increased for the private sector. The requirements for proving the strategic importance of the worker will be made more stringent and the restrictions on the maximum proportion of reserved employees will be extended. Some conscripts who currently enjoy deferrals due to lower pay, less formalized duties, or “notional” strategic importance status may lose their reserve after the 2026 roster revisions.

Normative basis of reservation Reservation in 2025 and in the coming year 2026 is regulated by Article 23 of the Law of Ukraine “On Mobilization Training and Mobilization” and the Rules approved by the Resolution of the CMU No. 76, which have already been amended several times in 2024-2025. The latest government regulations specify the scope, the procedure for submission through “Diya” and specify that it is possible to reserve only those who are actually on the military register, and not nominal “civilian” employees. Special Law No. 4630-IX of December 2025 expanded the ability of vital defense enterprises to book even those who have problems with military registration, but only for a short period of up to 45 days and no more than once a year.

Basic rules for 2025 In 2025, employers operate with the updated Rules, which clearly define the largest share of reserved employees and strengthen the requirements for arguments. The main reservation limit for most companies is up to 50% of the military personnel in the state, while certain categories – women, part-time employees, specific beneficial owners – may not be taken into account in this limit.

There is a “salary threshold” of UAH 20,000 for private entrepreneurship: the average salary for the enterprise and the monthly salary of each reserved worker cannot be lower, while state and communal enterprises are reserved according to other criteria without such a strict salary requirement.

The procedure is increasingly moving to an online format: submission of lists is carried out through authorities or directly in electronic form, and in 2025, a unified logic of submission through “Diya” is being formed for employers and the possibility to draw up a reserve without personal visits to the TCC, subject to correct military records. Reservation decisions are made for a period of up to six months with the possibility of extension, but only on condition that the grounds are preserved – both for the enterprise and for a specific position.

What will change from 2026 From January 1, 2026, due to the increase in the minimum wage, it is planned to increase the requirements for the salary of reserved workers mainly for private entrepreneurship – to approximately UAH 21.6 thousand and higher both for the average salary for the enterprise and for each reserved worker, while the public sector does not expect significant changes in this regard. This approach should cut off the cases of registration of a reserve for workers with the minimum official wage and stimulate the exit from the shadow of income in the private sector.

The emphasis on real importance is also increasing: relevant ministries are already demanding evidence from employers that this particular employee is indispensable for carrying out mobilization tasks or providing critical infrastructure. By 2026, this practice is expected to become the norm, and standard positions without a compelling rationale will be more likely to be rejected.

Who can lose the deferral Conscripts whose average official salary will not reach the new threshold are at risk: in the absence of other legal grounds for postponement, their reserves may not be extended after the expiration of the decisions. Also at risk are those whose role in the enterprise will not be sufficiently proven to be vital or copied by other employees.

A separate group is workers with “problematic” military records: only short-term reservation at defense enterprises is provided for them, so it is not worth counting on a long delay without getting the documents in order. In addition, persons who received other types of postponement (for family or medical reasons) will not be able to simultaneously use the reservation from the employer, which limits the maneuver for entrepreneurship.

Therefore, in 2026, the risk of losing the postponement is primarily the workers of private strategically important enterprises, where the average salary for the company or the individual salary of the reserved employee does not reach the new threshold of 21.6 thousand UAH. This applies to those who currently receive less than UAH 20,000 officially, and the employer is unable or unwilling to increase payments to maintain the reserve.

Also at risk are employees of companies that do not confirm the status of “strategically important” during the inspection: without stable taxes, foreign exchange earnings or real significance for the industry, the reservation will be canceled for the entire list. Those whose positions are recognized as replaceable, or workers with an invalid military record.

State enterprises are less vulnerable, because for them the salary criterion is not the key, but they also have to prove the strategic nature of the positions. In general, the main impact will fall on small and medium-sized businesses.