The Ukrainian government has issued clarifications regarding recent changes to the rules governing the reservation of military personnel, emphasizing that the exemption process for businesses remains intact. The updates aim to ensure that the needs of enterprises for retaining essential employees are accurately reflected.
Will Existing Reservations Automatically Change?
No, during the transitional period, existing critical designations and military reservist reservations will remain valid until September 1, 2026. After this date, businesses will need to re-confirm their status according to the new criteria.
What Are the New Salary Requirements for Employers?
The salary threshold for confirming critical status and reserving an employee has increased to three minimum wages, totaling 25,941 UAH. For enterprises located in frontline areas, a separate condition applies, requiring a minimum of 2.5 minimum wages, or 21,618 UAH. It is important to note that this refers to gross salary, which is calculated before tax deductions.
How Will Employees with Multiple Jobs Be Accounted For?
Employees working at multiple enterprises will only be counted once for reservation purposes, regardless of how many jobs they hold. This means that businesses can no longer count the same individual multiple times based on part-time or fractional employment.
Will Businesses Need to Resubmit Documentation?
Yes, businesses must submit new documentation to confirm their critical status. Government agencies will evaluate these requests based on updated criteria and only after receiving a complete set of documents from the enterprise.
What About Individual Entrepreneurs and State Enterprises?
There are no changes for individual entrepreneurs, as the law does not provide for their reservation. For state and municipal enterprises, the new average salary requirements do not apply.
How Quickly Will Documents Be Processed?
Government agencies are required to review submissions within ten working days. To avoid delays, businesses are advised to submit a complete and accurate set of documents; otherwise, they may face additional waiting periods.
The government has assured that it has coordinated the operations of relevant state agencies to prevent a backlog from simultaneous submissions.
What Should Employees and HR Personnel Do?
Employees who are reserved do not need to submit any documents themselves. They should:
- Check with their employer to confirm the status of their reservation;
- Ensure their military registration data is up to date;
- Clarify their status with the designated contact person at their workplace.
HR representatives are encouraged not to postpone their tasks until the last minute. They should verify whether their enterprise meets the updated criteria, review the list of employees eligible for reservation, specifically check on part-time workers, and assess the average salary levels for both the enterprise and individual employees.
Where to Find Updated Criteria?
Businesses should refer to the official decisions from the authorities that determine critical status in their respective sectors or regions. Once ministries, central government bodies, or regional military administrations re-approve the criteria, the updated information will be made available through their official channels.
The Ukrainian government has clarified recent changes to military reservist exemption rules, maintaining existing reservations until 2026 while updating salary thresholds and documentation requirements. These adjustments aim to better reflect the needs of businesses in retaining essential personnel.