New reservation criteria for employees 2025: detailed analysis, requirements, procedures

General provisions and aims of changes
Due to martial law and mobilization needs, from 2025, the Ukrainian government has revised and updated criteria for enterprises whose employees may be reserved. The main goal is to ensure the uninterrupted functioning of critical sectors of the economy, energy, security, medicine, and logistics. Reservation procedures allow companies to protect qualified specialists, maintain productive and managerial potential, and prevent essential process disruptions nationwide.

Definition of a critical enterprise
To qualify for reservation rights, a company must meet at least one sectoral or regional criterion approved by the executive authorities. Key areas include: energy (supply of electricity, gas, steam, water, etc.); transport, communications, logistics; agriculture and food provision; medical institutions and pharmacies; state bodies and strategic state companies; defense industry and military equipment manufacturers; and enterprises servicing critical infrastructure. Local authorities may supplement this list according to regional specifics. Eligibility is determined by the relevant ministry or regional military administration.

Main criteria for enterprises
New conditions for reservation include a minimum number of insured employees—at least 5 for municipal and 10 for private ownership; consistent salary payments over the last three months; no tax or fee debts; average monthly salary for reserved employees of at least UAH 20,000; actual operation for not less than two years, or performing state-approved production volumes.

Confirmation of status procedure
Enterprises must confirm critical status via the Diia Portal or submit necessary documentation in paper form if technically required. All enterprise data in state registers must be updated and accurate.

Employee requirements for reservation
An employee to be reserved must be registered for military service, not under investigation or wanted, officially employed by a listed critical company, and receive a salary of no less than UAH 20,000 per month. Documents are filed exclusively through Diia, with rare exceptions for paper submission.

Quotas and limitations
Maximum quotas are set for different organizations: for top-level state bodies—up to 100% of liable staff; for categories B and C (mid- and junior staff)—up to 50%; for private critical companies—a basic quota of 50%, which may be increased upon Ministry of Defense approval.

Enhanced control and sanctions
Since 2025, monitoring of salary compliance has intensified, with regular checks and requests to companies. Failure to comply will result in loss of critical status, a ban on new reservations for six months, and possible financial penalties.

New mechanisms and digitalization
Reservation of employees is conducted exclusively online via Diia, with immediate decision-making—renewal and status updates occur in real time. Annual reconfirmation of status is mandatory.

Sectoral and regional specifics
Criteria may differ by industry and region (determined through ministerial orders and RMAs); companies should track actual local requirements to confirm strategic status. Special regional priority lists are often published.

Conclusions and recommendations
Deadlines and requirements change rapidly—it is essential to monitor regulatory updates, ensure transparent financial discipline, fulfill tax obligations, and maintain a sufficient qualified workforce. Prompt digital registry updates are key to retaining staff and business stability. Overall, the new reservation criteria for 2025 have enhanced targeting and transparency but increased responsibility for strategic enterprises to support Ukraine’s economic stability during wartime.

Svitlana Krutorogova — Attorney, “WINNER” Law Firm.