Updating the rules for the reservation of employees: What is in the draft law No. 13335?

Bill No. 13335, approved by the president, introduces long-awaited adjustments to the process of reserving employees by companies. However, they will not be applied to everyone enterprises, informs Polina Marchenko, managing partner of Polina Marchenko Law Firm. What will be the reservation procedure now?

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The President signed draft law No. 13335 dated May 30, 2025 on the reservation of employees of the Ukrainian Air and Air Transport Agency and strategic enterprises. How and for whom will this document come into effect, which allows booking even with existing violations of military registration rules?

A step towards entrepreneurship After the changes to the procedure for the reservation of employees in November 2024, a significant obstacle to the reservation of employees at enterprises that have the status of critical importance for the economy was the presence of violations of the rules of military accounting among reservation applicants.

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Until this violation is corrected, the employee cannot be reserved. In order to settle such a violation, in most cases it is necessary to contact the Territorial Center for Recruitment and Social Support (RTCC and SP).

Without reservation, the result of such a visit to the RTCC and SP for the employee is voluntary mobilization: the absence of postponement or other grounds for exemption from mobilization leads to mobilization in 90% of cases. And it does not matter what position the employee holds or his critical importance for the company. This turns into a vicious circle: the enterprise is of critical importance, but it is impossible to reserve the necessary employee.

For the last six months, the Verkhovna Rada has been debating the issue of eliminating the gap, which will still allow the reservation of employees, even those who have violated the rules of military registration. Bill No. 13335 was registered back in May 2025, and only on October 31 was it approved by Volodymyr Zelenskyi.

What will be the order of reservation now First, it is allowed to reserve employees by enterprise:

• who have violations of the rules of military registration;
• who do not have or have not properly issued a military registration document;
• if such conscript is not on military registration.

This positive change is aimed at eliminating personnel shortages and labor shortages at enterprises that are in the category of critical importance for the economy.

The exception, in which it will be impossible to reserve in the future, is a violation of the rules of military registration, which is caused by evasion of mobilization and open criminal proceedings under Art. 336 or Art. 337 of the Criminal Code of Ukraine.

Secondly, it will be possible to reserve an employee with such violations for no more than 45 days.

But this time will be enough for the employee to appear before the RTCC and SP to bring his military registration document into compliance with the current legislation.

After the completion of 45 days, such an employee will be eligible for re-enlistment if he corrects all violations of the rules of military registration.

Thirdly, most importantly, the norms of the draft law apply exclusively to enterprises, institutions and organizations that have the status of critical importance for the functioning of the economy in the field of the defense-industrial complex. For example, manufacturers of weapons, military ammunition, special equipment or ammunition, or other accessories that have a military purpose.

That is, not every enterprise that has the status of “critical” can use the new reservation procedure.

Only one of the industries that are critically important for the functioning of the economy, HVAC, will be able to restore the personnel shortage, and the rest of the business will continue to either wait for changes in the legislation, or look for other ways to preserve their enterprise.

The draft law No. 13335 will enter into force in one month – from the day following its promulgation, with the exception of some clauses.

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