In summer 2026, the Ukrainian government significantly updated the rules for reserving employees liable for military service. The changes affect the salary criterion, confirmation of critical enterprise status, accounting for part-time employees, and control of reservation limits.
Following the adoption of Cabinet of Ministers Resolutions No. 692 and No. 862, the Ministry of Economy separately published clarifications and answers to frequently asked questions regarding the new reservation procedure. This is a clear indication that the changes genuinely affect employers and HR departments.
If you are dealing with the reservation procedure for the first time, we recommend first reviewing our comprehensive guide to employee reservation in 2026. In this article, we focus only on the summer changes that employers need to consider right now.
What Changed in Summer 2026
The main amendments were introduced by CMU Resolutions No. 692 dated 30 May 2026 and No. 862 dated 1 July 2026, which updated the Procedure for Reserving Persons Liable for Military Service (Procedure No. 76).
The key practical change for HR departments is that reservation is no longer a procedure that is sufficient to complete once. After the summer amendments, employers must regularly monitor the salaries of reserved employees, the reservation quota, the status of part-time employees, and the deadlines for confirming the enterprise’s critical status.
Who Is Affected by the Changes
The new rules apply to all employers with reserved employees, but with different implications:
- Critically important enterprises must confirm their status under the new requirements by 10 August 2026; otherwise, after 1 September they will lose the right to reserve employees.
- Employers with part-time employees must verify whether they are entitled to include such employees in the reservation limit calculation.
- Enterprises close to the reservation limit should note that since 17 June the Ministry of Economy has been checking compliance with reservation limits, so it is better to correct any excess independently rather than wait for an official notification.
- Diia.City residents are not subject to the minimum salary threshold requirement, but all other changes — status confirmation, part-time employee accounting, and reservation limits — apply to them in the same way as to other employers.
Checklist for HR Inspectors: What to Verify Right Now
After the amendments to the reservation rules, HR departments should conduct a comprehensive review. This will help avoid problems during confirmation of critical enterprise status or inspections by the Ministry of Economy.
1️⃣ Check Salaries
Verify whether the salary of each reserved employee meets the new minimum threshold:
- UAH 25,941 (general rule), or
- UAH 21,618 (for enterprises located in frontline territories).
2️⃣ Check Part-Time Employees
- Prepare a list of all employees working on a part-time basis.
- Make sure your enterprise is entitled to include them when calculating the reservation limit.
3️⃣ Check the Reservation Limit
- Calculate the actual share of reserved persons liable for military service.
- If the limit has been exceeded, submit an application to cancel reservations within 10 working days.
4️⃣ Prepare Documents for Status Confirmation
Prepare:
- a certificate of the average salary, and
- the unified tax reporting for the last calendar month.
These documents must be submitted by 10 August 2026.
5️⃣ If the Enterprise Is a Diia.City Resident
- Verify compliance with the general requirements for critically important enterprises.
- Do not rely on the common myth about increased reservation limits for IT companies.
Deadlines You Must Not Miss
Add these dates to your HR calendar:
- June 2 — new salary threshold;
- June 17 — start of inspections for compliance with reservation limits;
- July 1 — Resolution No. 862 entered into force;
- July 3 — new rules for accounting for part-time employees;
- August 10 — deadline for submitting documents to confirm critically important enterprise status;
- September 1 — end of the transitional period, after which an unconfirmed status becomes invalid.
Common Mistakes After the Amendments
In practice, enterprises most often lose the right to reserve employees not because they are unaware of the new rules, but because of implementation errors. The most common are:
- Selective salary review — the HR department checks only newly hired employees instead of the full list of reserved staff.
- Double counting of a part-time employee — both employers continue to believe they have the right to reserve the employee, although under the new rules only one of them may do so.
- Missing the 10 August deadline — the company prepares documents at the last moment or forgets about the need to reconfirm its status.
- Assuming that critically important enterprise status is preserved automatically — decisions valid as of 2 June remain effective only until 1 September and become invalid without confirmation.
- The myth of increased limits for Diia.City residents — Diia.City residents are subject to the general reservation limit; increased limits apply to specific sectors (energy, defense industry, water and heat supply), not to Diia.City resident status.
- Lack of limit monitoring after HR changes — hiring, dismissal, or transfer of employees changes both the total number of persons liable for military service and the share of reserved employees, but these figures are often not recalculated immediately.
How to Organize Control of These Processes
Manual control becomes risky as the number of deadlines and criteria increases. To reduce risks, HR departments should:
- appoint a person responsible for each of the four areas (salaries, part-time employees, limits, and status);
- review the reservation limit after every HR change, not once per quarter;
- add key deadlines to the corporate or HR calendar;
- use an HRM system that provides reminders about upcoming important dates.
For example, Vchasno.Kadry helps responsible employees monitor HR deadlines and receive reminders about key dates. Applications and supporting documents are still submitted by the responsible person through the Diia Portal; the service only helps ensure that important deadlines are not missed.
After the summer 2026 amendments, employee reservation became significantly more controlled. For employers, the greatest risk is not the reservation procedure itself, but a missed deadline, an unaccounted-for part-time employee, or a salary that no longer meets the new requirements.
If the HR department regularly reviews salaries, the reservation quota, the enterprise’s critical status, and key deadlines, most risks can be identified before they lead to the loss of reservation rights. That is why now is the right time to audit the lists of reserved employees, verify the key deadlines, and ensure that the enterprise is already operating under the updated 2026 reservation rules.
