Critically Important Status of Agricultural Enterprises: New Criteria for Submission Through the SAR" for clarity

25.06.2026

On June 24, 2026, the Ministry of Economy, Environment and Agriculture of Ukraine approved Order No. 6954 "Criteria for Determining Enterprises, Institutions and Organizations That Are of Important Significance for the Sectors of the National Economy." The document establishes the criteria for confirming the critically important status of enterprises for the functioning of the economy.

The order enters into force on June 24, 2026. From this date, enterprises that meet the defined criteria can submit a package of documents through the SAR state electronic system.

Experts of the Ukrainian Agri Council (UAC), within the framework of a project to support Ukrainian agricultural producers from affected regions in partnership with the international humanitarian organization Mercy Corps, explain what exactly agricultural enterprises need to take into account when confirming their critically important status.

According to Order No. 6954, separate criteria have been approved for enterprises that are of important significance for the national economy in the field of agriculture. At the same time, in accordance with Resolution No. 76, an enterprise must meet at least three criteria, two of which are mandatory.

The first mandatory criterion is the absence of debt on the payment of taxes to the state and local budgets and the unified social contribution.

The second mandatory criterion is the amount of the accrued average wage of insured employees at a privately owned enterprise for the last tax period, that is, a month. It must be no lower than the amount of the minimum wage in the country multiplied by a factor of 3. This is confirmed by a certificate provided by the enterprise.

For enterprises whose location is, and which actually operate in, territories of possible hostilities, active hostilities, or territories of Ukraine temporarily occupied by the Russian Federation for which, according to List No. 376, no date has been determined for the cessation of the possibility of hostilities, the end of hostilities, or the temporary occupation, the monthly wage during the deferment period must be no lower than the amount of the minimum wage in the country multiplied by a factor of 2.5.

The third criterion is that the enterprise is of important significance for the sector of the national economy.

In accordance with paragraph 4 of Order No. 6954, separate sectoral criteria have been defined for enterprises in the field of agriculture. One of them concerns the scale of the enterprise's activity. In particular, the enterprise must meet one of the following indicators:

cultivate agricultural land with an area of at least 1,000 hectares for conducting agricultural activity. This is confirmed by the information provided for in subparagraph 2 of paragraph 3 of the List of Information of the State Register of Agricultural Producers, approved by Resolution of the Cabinet of Ministers of Ukraine of May 13, 2025, No. 549;

cultivate land of perennial plantings with an area of at least 50 hectares for the production of fruit products, which are on the enterprise's balance sheet. This is confirmed by the form of state statistical observation No. 29-сг annual "Report on Areas and Gross Harvests of Agricultural Crops, Fruits, Berries and Grapes," approved by Order of the State Statistics Service of Ukraine of April 4, 2024, No. 91, with a receipt of acceptance by the electronic reporting system of the state statistics bodies;

have an annual income, that is, net income from the sale of products, goods, works, or services, of at least UAH 40 million. This is confirmed by a certified copy of the annual financial statements, which consist of the balance sheet and the income statement for the previous reporting year.

Another criterion concerns the type of the enterprise's activity. The enterprise must carry out one of the defined lines of activity:

  • production, processing, and sale, including export, of agricultural products;
  • production and/or supply of plant protection products, including pesticides, seeds and/or planting material, veterinary preparations, fertilizers, agricultural machinery, equipment, and spare parts for them;
  • ensuring production and technological processes for the reception, cleaning, drying, storage, and processing of grain, oilseed, and leguminous crops, as well as products of their processing;
  • scientific and technical activity aimed at creating conditions for increasing the efficiency of agricultural production and the level of food security of Ukraine;
  • activity in providing partial guarantees for the credit obligations of small and medium-sized business entities operating in the field of agriculture.

At the same time, the main type of the enterprise's activity as of June 1, 2026, according to KVED-2010 (the Classifier of Types of Economic Activity), must be one of the defined KVED codes.

Separately, the order provides for a criterion for enterprises in which 100% of the shares or stakes in the authorized capital belong to the state. This concerns enterprises formed through the transformation of a state enterprise and which carry out activity in subleasing state-owned agricultural land plots at land auctions.

Such a criterion is confirmed by an extract from the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Formations, generated in the manner determined by the law on state registration, as well as a certificate on activity signed by the head of the enterprise. The certificate must indicate the number of land auctions held for subleasing state-owned agricultural land plots, the number of concluded land sublease agreements, the total area of the land plots, and the amount of sublease payment received.

Important: to make a decision on determining an enterprise as one of important significance for the national economy in the field of agriculture, a certified copy of the Tax Calculation for the last reporting period must be submitted, with confirmation from the controlling authority of acceptance of this Tax Calculation.

As a reminder, agricultural producers can contact the UAC legal advisory line free of charge with practical questions arising in the operation of farms: from the reservation of workers and confirmation of critically important status to tax accounting, land relations, and participation in state support programs.

To get a consultation, submit your request via the electronic form: https://forms.gle/v56UzTAsrD9Zrx998

For clarification, contact the legal advisory line at: +38 067 522-03-43


For reference:

MERCY CORPS is an international humanitarian organization that operates in more than 40 countries worldwide and provides assistance to people affected by disasters, wars, poverty, and the consequences of climate change.