“Ukraine provides for booking of enterprise employees. However, the rules are constantly changing, and recently worked through the portal “Action”. But everything is ideal in the booking system of employees, and how simple and fast employers can provide a deferral for critical specialists? The government is constantly reviewing the booking rules.”, – WRITE: www.pravda.com.ua
The government is constantly reviewing the booking rules. On the one hand, the Cabinet of Ministers responds to the remarks of the real sector of the economy, on the other-it tries to prevent abuse of the booking procedure, such as the creation of fictitious educational institutions or “admission to work with booking”. However, unfortunately, the procedure remains complicated, not always clear, predicted and transparent.
Resolutions, rules, restrictions: who and for what time can workers today can be book The procedure for reservation of conscripts by state authorities, other state bodies, local self -government bodies and enterprises, institutions and organizations for the period of mobilization and for wartime approved by the government resolution of February 4, 2015 No. 45 and has a stamp “for official use”, so its text is not available. This resolution provides for the possibility of booking in accordance with the established list of professions and positions, it was used by both railway and educational institutions. Another document governing reservation is the Resolution of the Cabinet of Ministers of Ukraine “Some Issues of Implementation of the Provisions of the Law of Ukraine” On Mobilization Training and Mobilization “on the Booking of the Military and Millennium for the Mobilization and War period” of January 27, 2023 No. 76, which is constantly made. But even one point change is able to influence the booking criteria and, accordingly, the ability of Ukrainian businesses to keep critical personnel.
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Currently, companies that do not have tax debts to the state may now offer an official wage at least 20 thousand UAH for a worried person, as well as if the average salary at the enterprise is not less than the amount mentioned. However, these companies should also belong to critically important enterprises and institutions that work to meet the needs of the armed forces or the functioning of the economy and life of the population. In addition, the possibility of reservation involves the presence of a resident “Action. City”. The timing of the deferral of resolution No. 76 may not exceed the term of the contract (contract) for the supply of goods, the performance of the works and the provision of services necessary to meet the needs of the Armed Forces – for companies operating for the defense complex, as well as 12 months – for military personnel of other critical enterprises.
Of course, businesses are not able to book all employees. Critically important enterprises can book up to 50 % of military personnel, more – up to 75 % – can book energy companies for production, transportation of thermal energy, heat supply, centralized hot water supply, centralized water supply and centralized sewage, management of household waste. And up to 100 %-the reservation of military personnel, which is provided for in paragraph 5 of the Resolution of the Cabinet of Ministers of Ukraine of January 27, 2023 No. 76, which is, in particular, employees of the enterprises of the fuel and energy complex, the defense sector, etc.
To design a reservation: what is the specificity of the reservation procedure in Ukraine now The main innovation in the booking procedure of 2025 – it is carried out through the portal “Action”. Therefore, neither companies nor employees need to visit the CCC or send the documents necessary for booking.
The main changes on the booking procedure were made at the end of 2024 (CMU Resolution No. 1332 of November 22, 2024), they set the task of updating the status of criticality for the possibility of booking 2025. In addition, the staff of companies or those who maintain military accounting have the question: should workers who were resolved under the CMU Resolution No. 45? In March, the Ministry of Economy in the letter further explained that Resolution No. 1332 did not apply to this issue.
Problems with Resolution No. 45 emerged later, in May 2025, when reports of “removal” and simultaneous search began to receive. Companies allegedly received letters to cancel mobilization tasks, which served as a basis for abolition of armor. Later, such information was denied and stated that resolution No. 45 continues.
It is important that in 2025, thanks to the CMU Resolution No. 233 of February 28, 2025, it was possible to calculate the average salary of reserved on the database over the last month (earlier – the last calendar quarter). This made it possible to book a newly accepted worker at once. It also provides for automatic verification of the proper salary by electronic exchange of data with the Pension Fund.
Another innovation is the new formula for calculating the number of booked. Since April 2025, the number of conscripts at the enterprise is considered as follows: to the actual amount on the day of filing the application is added mobilized after May 18, 2024 and reserved under Resolution No. 45, but do not attach women-military women, reserved by other enterprises and those who are entitled.
Also, this spring was increased from 50 % to 75 % of the proportion of booked persons at communal infrastructure enterprises (CMU Resolution No. 360 of March 28, 2025).
The changes made by the CMU Resolution No. 847 of July 14, 2025 do not provide for the cancellation of criticality due to the adoption of new criteria or the reorganization of ministries. Therefore, companies that already have status should not submit documents again.
Reservations and guarantees: Does everything work properly and why companies lose their staff Reservations due to “action” take place within 72 hours, but delays in the employee may occur in the list of reserved if the Pension Fund has not provided the relevant information for the “Oberig” register. But the main problem is that the mobilization process is irreversible, even the recognition of the conscription procedure does not involve the restoration of the previous position of the person by dismissing it. This is stated in a relatively fresh decision of the Supreme Court of February 5, 2025 in case No. 160/2592/23. Therefore, the threats of the court or the expectations for him will be in vain if the booked worker is still mobilized.
So if the reservation application is Dana, but not yet confirmed, and the employee has already been detained and delivered to the shopping center, the employer must contact the shopping center where the employee is located and notify the reservation application. It is very important to provide all the necessary documents confirming the application and its status. And it is better that the external lawyer or legal counsel of the company does this.
Additionally, I recommend contacting the Ministry of Economy or other sectoral ministry through which there was a booking to obtain a formal confirmation of the reservation application. However, I remind you, the application is not yet reservation. Dyjitization of reservation has simplified the lives of the workers themselves, but it is still necessary to make considerable efforts to make the process of criticality transparent and predicted.
It is possible to positively evaluate the possibility of reservation of ultimate beneficial owners and members of supervisory boards of critical enterprises, but still to account for the number of conscripts at the enterprise not take them at the beginning of a large -scale invasion. And domestic companies began to lose their employees from the moment, and unfortunately, many lost forever.
To improve the procedure, you can provide an automatic continuation of the reservation after its expiration, if the conditions in the company have not changed and the country continues to operate.
Business is still faced with a problem when a few days without armor of a previously booked employee are turning into a “competition” with a shopping mall regarding its mobilization. Therefore, it is worth providing a certain “transition period” when the employer is able to renew reservation or get critical status if it has been lost for some reason.
Nowadays, the possibility of booking is an important condition for many companies to continue their activities, while many workers are now an important condition for employment. And how closely do employers need to monitor the timely booking of their critical workers, it is also closely worth watching the critical criteria that generally allow business to book specialists. Every time the next changes (or they are unexpected) are planned in such criteria, especially sectoral, employers need to involve all communication opportunities with their profile ministry, business communities and sectoral associations so that one small change does not become a fleeing of the firlus.
Nowadays, the reservation procedure lacks transparency and systematicity. The changes are regularly applied to Resolution No. 76, and the “secret” resolution No. 45 exists and the enterprises are referred to when booking. New changes made to different regulations by regular regulations only fill in the spaces, but at the same time a new uncertainty arises, which prevents enterprises from clearly and in time to book their critical employees. In order to put an end in this chaos of endless government regulations, it is necessary that the Parliament finally develops a clear and understandable booking legislation. After all, a single transparent and understandable bill with the appropriate amendments to all the mobilization of laws is really capable of transforming the employee booking system into a transparent and effective mechanism.
Julia Tatik
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