Reservation from mobilization will be extended until February 1, 2027: which enterprises will be affected by the changes

Ukraine plans to automatically extend the status of critical enterprises, the validity of which expires in November-December 2026. The corresponding decision should ensure business continuity and preserve the possibility of reserving military personnel during the transition to the updated rules.

Who will be granted the status of a critical enterprise?

The Cabinet of Ministers of Ukraine is preparing changes to the procedure for determining enterprises as critical for the functioning of the economy and meeting the needs of the population under martial law.

According to the Ministry of Economy, a draft regulatory act has already been prepared, which provides for the automatic extension of the critical status of enterprises until February 1, 2027.

This will apply to companies whose relevant status expires during November or December 2026.

The purpose of such a decision is to prevent interruptions in the work of enterprises that are of strategic importance to the state while the updating of industry criteria is ongoing.

At the same time, it is important to take into account that this is a draft act that has been prepared. The final procedure for extending statuses and reserving will depend on the decision adopted by the government.

Will reservations for employees be automatically extended?

The proposed transitional mechanism is designed to ensure that the possibility of reserving reservations for military personnel of enterprises that have the status of critical.

However, the automatic extension of the status of an enterprise and the extension of an individual reservation for an employee are not identical procedures.

Therefore, employers and employees need to monitor the final version of the government decision and check the relevance of the issued reservation.

How will the rules for determining the criticality of enterprises change?

According to the Ministry of Economy, about 90% of state bodies have already revised the industry criteria by which enterprises can receive the status of critical.

The updated criteria are also being agreed upon in the newly created Coordination Center.

After the approvals are completed, the relevant regulatory acts must undergo state registration with the Ministry of Justice of Ukraine within five business days.

After they enter into force, a review of previously granted criticality statuses will begin.

Which enterprises may lose the right to reserve?

Enterprises that have received the status of critical based on criteria that have lost their validity may lose the corresponding status.

At the same time, this does not mean that they will permanently lose the ability to reserve employees.

Such companies will be able to reapply and confirm their compliance with the new applicable requirements.

For enterprises whose criticality criteria have not changed, it is possible to submit documents to the relevant central executive body or regional military administration.

What requirements will be imposed on enterprises?

To confirm criticality, employers will need to substantiate the importance of their activities for the state.

In particular, the enterprise must:

Confirm the importance of its work for the defense capability of Ukraine or ensuring the vital activity of the population.

Prove the compliance of its activities with one of the 13 identified critical areas.

Submit the necessary documents to the authorized state body.

The list of critical areas may be expanded upon the submission of the relevant authorities. The final decision on such changes will be made by the Coordination Center.

What do employees with reservations need to know?

Employees who already have reservations from mobilization should clarify with their employer the date until which the enterprise was granted critical status and whether it falls under the proposed transitional mechanism.

It is also necessary to check the validity period of their own reservation, since the presence of critical status with the employer does not in itself guarantee the automatic extension of each individual deferral.

Employers, in turn, should prepare documents in advance to confirm compliance with the updated criteria.

When will the new rules come into effect?

According to the Ministry of Economy, the government has already prepared a draft act on the transitional period.

It is expected that it will allow enterprises whose critical status ends at the end of 2026 to maintain it until February 1, 2027.

The final conditions for extending the reservation will become known after the adoption and publication of the relevant regulatory act.