NACP identified three corruption risks in new booking rules: government supported changes despite comments

The National Agency for the Prevention of Corruption (NACP) has identified three corruption-prone factors in the government’s draft amendments to the rules for reserving military personnel. Despite recommendations to finalize the document, the Cabinet of Ministers supported it the very next day after the agency’s conclusion.

According to the parliamentarian, the NACP prepared the conclusion on October 12, 2026, and on October 13, the government supported the draft resolution. At the same time, the proposed changes to the reservation quotas were excluded from the document.

The first risk: enterprises could lose part of the reservation

One of the main comments of the NACP concerned the new approach to calculating the number of employees that enterprises can reserve from mobilization.

The initial draft proposed not to take into account when calculating the quotas of employees who already have a deferral from mobilization for other reasons.

This could lead to an actual reduction in the number of employees available for reservation, even if the formally permitted quota remained at 50%.

For example, an enterprise could be able to book fewer employees due to a change in the calculation base, although the established reservation percentage would not change.

The NACP recommended excluding the relevant norm.

According to Zheleznyak, during the government review, changes to the quotas were indeed removed from the project.

The second risk: opaque definition of critically important enterprises

Another remark of the anti-corruption agency concerned the procedure for granting enterprises the status of critically important.

The project provided for the involvement of the Coordination Center in approving such status.

However, the document did not properly define:

A clear procedure for considering applications from enterprises.

The deadlines for adopting relevant decisions.

An exhaustive list of grounds for refusing approval.

According to the NACP, the lack of clear rules creates opportunities for subjective decision-making and potential abuse.

The agency recommended establishing a transparent procedure for approving the status of critical enterprises in order to minimize corruption risks.

The third risk: enterprises could arbitrarily deprive of critical status

The third corruption-prone factor is related to the procedure for revoking the status of a critical enterprise.

In the proposed wording, ministries and regional state administrations could independently decide whether to take into account the recommendations of the Coordination Center on depriving an enterprise of such status.

This created a risk of uneven application of the rules.

In particular, under similar circumstances, one enterprise could lose critical status, while another could retain it.

The NACP recommended making the relevant recommendation of the Coordination Center a mandatory basis for making a decision to deprive the status.

Have the new reservation rules come into force?

On the evening of October 13, the Cabinet of Ministers supported changes to the employee reservation system with a five-day revision of the document.

According to Economic Truth sources in the government, the final text of the resolution is expected no earlier than October 18.

Thus, as of October 15, the final version of the new rules has not yet been published.

It is known that the provisions on changing reservation quotas have been excluded from the draft. At the same time, it does not follow from the above message that all other comments of the NACP have already been taken into account.

What does this mean for business and employees

The proposed changes are of particular importance for enterprises that depend on the possibility of booking military-duty employees.

The status of a critically important enterprise is one of the key conditions for applying the reservation mechanism. Therefore, the transparency of the procedure for obtaining and maintaining it directly affects the personnel planning of the business.

The lack of clear deadlines, criteria, and grounds for making decisions can create legal uncertainty for employers.

For now, enterprises should focus on the current reservation rules and wait for the official publication of the final text of the government changes.

The mere fact that the NACP has identified corruption-prone factors does not mean that specific cases of corruption have been identified. It is about the provisions of the draft that, in the agency’s opinion, may create conditions for abuse.