Employee reservation in 2026 calls for accounting and HR to work in step. Reservation is Ukraine’s employment-based deferment from mobilization for eligible employees. As a general rule, the salary threshold for a critically important company is UAH 25,941, but the company’s average salary and the amounts accrued to an individual reserved employee are monitored separately. Before the lists are submitted you also need to confirm that the decision on critical status is still valid, that the company remains within its quota and that employment records are accurate.
Below we cover how to calculate the average salary, show that the critical status criteria are met, determine the quota and count employees with second jobs, as well as what to check if Diia (the government’s online services portal) will not reserve an employee.
The rules and amounts are given as of September 21, 2026, under Cabinet of Ministers Resolution No. 76 in its current wording.
Have all earlier critical status decisions expired?
No, not every decision expired on September 1. Subparagraph 1 of paragraph 2 of Cabinet of Ministers Resolution No. 692, as amended by Resolution No. 862, applies to decisions that were in force on the day Resolution No. 692 itself took effect. This provision limits their term to September 1, 2026, but provides for an exception.
If the certificate of average accrued salary and the payroll tax return (Ukraine’s combined payroll tax and social contribution return) for the last calendar month were filed by August 10, 2026, as the resolution requires, the decision could keep its original term. However, this does not cover companies whose status was due to be revoked because the industry or territorial criterion on which they had been recognized as critically important was removed.
So the first thing to check is proof that the documents and information were submitted to the authority that granted the company its critical status. The date stated in an old order does not in itself prove that the company has been through the confirmation procedure and kept that status. At the same time, September 1 does not automatically terminate every decision without exception.
If you are advised to file documents by September 25, 2026, check what that advice rests on. September 25 is not a general statutory filing deadline: the Criteria and Procedure approved by Resolution No. 76 contain no such deadline. Under paragraph 6, the authority has to consider an application within no more than 10 working days from the day it is received. Plan your filing from the date your own critical status expires, leaving time to prepare and refine the documents. Confirming critical status and applying for reservation in Diia are two different procedures.
Which salary figures does reservation require?
The accountant has to monitor two separate salary figures, even when the numerical threshold is the same for both.
| What you check | Why | General requirement |
|---|---|---|
| Average accrued salary of insured persons (the company’s employees) | To obtain or confirm critical status | At least 3 minimum wages for the last calendar month |
| Accrued salary of each employee on the reservation list | To meet the salary requirement throughout the deferment | At least 3 minimum wages every month |
The first requirement is set by the third paragraph of subparagraph 6 of paragraph 2 of the Criteria and Procedure, the second by the third paragraph of paragraph 8 of the Reservation Procedure. Both documents are approved by Resolution No. 76. Under Article 8 of the Law on the State Budget of Ukraine for 2026, the monthly minimum wage is UAH 8,647. The general threshold therefore works out at 8,647 × 3 = UAH 25,941.
The check is based on accrued salary before tax is withheld, not on the amount paid into the employee’s bank account. A company can pass the average salary test and still fail the individual salary requirement for one of its reserved employees. So a high salary for the chief executive can bring the average up to the required level, but it does not guarantee that the individual requirement is met.
For certain companies located in areas of combat operations or in temporarily occupied territories, the threshold is 2.5 minimum wages instead of 3, that is 8,647 × 2.5 = UAH 21,617.50. It applies both to the company’s average salary and to the amounts accrued to a reserved employee. This is set out in the fourth paragraph of subparagraph 6 of paragraph 2 of the Criteria and the fourth paragraph of paragraph 8 of the Reservation Procedure.
A registered address alone is not enough: the company must not only be located in an area on the Ministry of Development’s list but also actually operate there. The list must show no end date for that area, whether for the possibility of combat operations, the operations themselves or the temporary occupation. The full lists of exceptions for the company-wide figure and for the individual one should be checked separately against Resolution No. 76.
How do you calculate the average salary from the payroll tax return?
For the new form of the return, the Ministry of Economy has issued guidance on calculating the average salary. For legal entities the reporting period is a calendar month. This is stated directly in paragraph 5 of section I of the Procedure for completing the return.
The ministry recommends the following formula:
Average salary = (line 1.1 + line 1.3 + line 1.4) ÷ line 092.
The numerator covers accrued salary, employer-funded pay for the first five days of temporary disability and temporary disability benefit funded by the Pension Fund of Ukraine. The denominator is the number of employees in the reporting period for whom salary was accrued, excluding those who receive service pay rather than wages. The calculation uses the line 092 figure specifically, not a staffing-schedule or average headcount chosen at will.
Also take into account vacation and sick pay that straddle more than one month. If the full amount was paid and reported in the current month, it counts toward that month’s income. As a result, the income accrued in the following month may be lower, which will affect whether the salary criterion is met.
The letter is explanatory and does not create legal rules. The salary criterion itself is set by Resolution No. 76. Do not apply this formula to the individual salary requirement for a reserved employee, and do not reuse line numbers from the old reporting form by rote.
Example. For the last calendar month, line 1.1 shows UAH 760,000, line 1.3 shows UAH 12,000, line 1.4 shows UAH 8,000 and line 092 shows 30 employees. The average salary comes to 780,000 ÷ 30 = UAH 26,000. The general threshold of UAH 25,941 is met, but with only UAH 59 to spare.
If a review shows that the correct figure for line 092 is 31 employees, the same amounts give an average of UAH 25,161.29. In that case, the criterion is no longer met. If there is an error in the reported figures, correct it rather than picking a denominator that produces the answer you want.
The accountant should keep a separate calculation that cites the lines of the accepted return and reconcile it with the certificate used to confirm critical status. Off-the-books payments are no substitute for the accruals shown in the reporting. Bonuses, sick pay and corrections for earlier periods have to be classified correctly in the reporting rather than added by hand to reach the figure you need.
What else do the critical status criteria require besides salary?
A company, institution or organization outside the special categories has to meet at least three criteria. Two of them are mandatory: the salary criterion and the absence of arrears on taxes and the unified social contribution. An additional criterion is determined separately, for example the company’s importance to an industry or to a local community. For the special categories, paragraph 3 of the Criteria and Procedure sets different conditions.
Before you file the documents, check:
- Which criteria apply to the company and which documents support each of them.
- Which last calendar month the certificate of average salary covers and whether its figures match the payroll tax return.
- Whether proper confirmation that there are no arrears has been obtained.
- Whether the reporting for the last tax period has been filed and whether there is proof that it was accepted.
- When the term of the current decision ends and which authority the package of documents goes to.
A certificate of average salary does not by itself prove that the company meets all the criteria.
Paragraph 8 of the Criteria and Procedure lists the documents for confirming the status. Any additional industry or territorial requirements should be checked against the current decision of the relevant authority.
A generic set of certificates used by another company may not match the grounds on which your company confirms its critical status.
How do you check the quota and count employees with second jobs?
As a general rule, no more than 50% of the total number of employees liable for military service may be reserved. That limit is set by the first paragraph of paragraph 8 of the Procedure for companies recognized as critically important for the functioning of the economy. It does not mean half of the entire workforce. Any entitlement to a higher limit, or to rely on a special ground, has to be confirmed separately.
Paragraph 12 defines who is included in the total number of employees liable for military service. Among other things, women liable for military service and people reserved by another company are left out, while employees mobilized after May 18, 2024, are counted in. This is not a complete list, so you cannot simply take the headcount from the staffing schedule and multiply it by 50%.
A separate rule applies to employees who hold a deferment on other grounds under Article 23 of the Law of Ukraine “On Mobilization Preparation and Mobilization”, and to those who also work at another critically important company or institution. They are included in the total at one place of work only: the one where the employment relationship has lasted longest. So the main place of work and the longest employment do not necessarily point to the same employer.
If dismissals or another change in headcount push the company over the limit, do not wait for the next confirmation of critical status. Under paragraph 9-2 of the Procedure, the head of the company must file an application through Diia within ten working days from the day the limit was exceeded to cancel reservations and bring the number of reserved employees back within the quota. That is why the quota should be recalculated after every staffing change, not only before a new application is filed.
What to check if Diia will not reserve an employee?
Start by checking the reason stated when the application was reviewed. The official Diia service page distinguishes between “reserved”, “not reserved” (with the reason explained) and “not eligible for reservation”.
| Situation | What to check |
|---|---|
| There is a decision on critical status, but the service is unavailable | Whether the authority that granted the status has entered the company in the Unified List of critically important entities |
| An employee does not show up, or the wrong number of employees is shown | The employment records held by the Pension Fund and how they appear in the Oberih register (Ukraine’s unified military registration database) |
| The employee already has a reservation or a deferment on other grounds | Whether the ground for the deferment is still valid and the result of the check in the military register |
| Staffing changes have left no room within the limit | That the headcount used for the calculation has been determined correctly, plus current reservations and the rules on second jobs |
To bring employment records up to date, Diia recommends using the relevant service on the Pension Fund portal. Editing the data in the company’s HR software does not mean the state registers already reflect the change. Once corrections have been made, check the result of the data exchange and the status of the application. Confirmation of reservation appears in the electronic military registration document.
If an employee has already been mobilized, that is a different HR procedure. It is covered in our article on documenting mobilization and settlements with the employee.
Before the lists are submitted, the head of the company should check that its critical status is still valid and review the average salary calculation, individual accruals and the quota in light of the latest staffing changes. That reconciliation helps catch a problem before Diia refuses the application or the deferment period runs out.
UHY Prostir helps align payroll, HR administration and reporting, to support checks of the salary figures used for reservation. If you need your accruals and reported data checked before the documents go in, talk to our team.