Ukraine has suspended accepting applications for the status of critically important agricultural enterprises: what happened?

In Ukraine, they temporarily stopped accepting applications from enterprises of the agro-industrial complex to obtain the status of critical importance for the economy. The reason was changes to the rules for booking conscripts, which the government approved in October 2026. Acceptance of documents will be resumed after revision of industry criteria in accordance with updated legislation.

Why did they stop accepting applications?

The State Agrarian Register (DAR) has temporarily suspended the possibility of submitting applications to identify enterprises of the agro-industrial complex as critical for the functioning of the economy and ensuring the livelihood of the population in a special period.

The reason was the adoption of Resolution No. 1328 of October 23, 2026 by the Cabinet of Ministers of Ukraine “Some issues of organizing the reservation of conscripts for the period of mobilization and wartime”.

The document foresees the need to review the criteria by which enterprises receive the status of critical importance.

In particular, the central bodies of executive power and other authorized institutions must bring the relevant requirements into line with the updated legislation.

How much time do they have to review the criteria

According to paragraph 2 of Resolution No. 1328, the authorized bodies must review and agree on the criteria for determining critical enterprises within 10 days from the moment the resolution enters into force.

This refers to the industry requirements that are used during the consideration of applications of enterprises to obtain the relevant status.

The submission of new applications through the State Agrarian Register is suspended while the process of agreeing the criteria continues.

At the same time, a specific date for resuming the acceptance of documents has not been announced yet.

How will this affect employee bookings?

The status of a critical enterprise is one of the necessary prerequisites for the reservation of conscript workers in accordance with the procedure established by law.

For agricultural enterprises, the opportunity to obtain such a status is of particular importance, because it allows to ensure personnel stability and continuity of production processes.

The temporary suspension of applications means that businesses that were planning to apply for a criticality determination for the first time through the DAR are currently unable to submit the relevant documents this way.

At the same time, the notification of the suspension of the acceptance of applications does not mean the automatic cancellation of previously granted statuses of critical enterprises or the already issued reservation of employees.

The notification of the Ministry does not mention such decisions.

When they resume receiving documents

The relevant ministry noted that the acceptance of applications will be resumed after the settlement of issues related to the updating of industry criteria.

The resumption of work of the relevant mechanism is promised to be reported additionally through official information resources.

Until then, agricultural enterprises should monitor updates of regulatory requirements in order to prepare documents in accordance with the new criteria.

What agricultural enterprises should know

Changes to the procedure for determining critical enterprises may affect the procedure for obtaining the relevant status and the subsequent reservation of employees.

However, the final implications will depend on the content of the updated industry criteria.

It is currently known that:

the reception of new applications through DAR is temporarily suspended;
the reason is the need to harmonize the criteria with Cabinet Resolution No. 1328;
authorized bodies have 10 days from the moment the resolution enters into force to revise the criteria;
the date of resuming the acceptance of documents will be announced additionally.

Thus, we are talking about a temporary limitation of the application procedure, related to the update of the rules for the reservation of conscripts, and not about a complete termination of the mechanism for determining critical enterprises.