On July 2, 2026, critically important enterprises began receiving letters from the Ministry of Economy regarding the exceeding of the reservation limit in accordance with the requirements of Resolution of the Cabinet of Ministers of Ukraine of July 1, 2026, No. 862. The document, in particular, introduced new rules for accounting for workers who work part-time (by concurrent employment).

What enterprises need to take into account in the event of receiving such a letter, and how to avoid the risk of losing the status of a critically important enterprise, is explained by experts of the Ukrainian Agri Council, within the framework of a project to support Ukrainian agricultural producers from affected regions in partnership with the international humanitarian organization Mercy Corps.

In the letters, the Ministry of Economy provides enterprises with information regarding the existing number of:

• military-liable workers, in particular those reserved;
• workers who work by concurrent employment (part-time);
• the excess of reservation volumes due to the changes introduced by Resolution No. 862 to the Reservation Procedure and the criteria defined by Resolution No. 76.

In the letter, enterprises are recommended to cancel the reservation of a specified number of workers. Otherwise, there is a risk of losing the status of a critically important enterprise.

In accordance with Resolution No. 692, from June 2, 2026, the following requirement is in effect: if an enterprise has exceeded the limit on the number of reserved workers, the head is obliged, within 10 working days, to submit through the Diia portal an application for the cancellation of the reservation. In the event of non-compliance with this requirement, there is a direct consequence — this is grounds for revoking the enterprise's critically important status.

Taking this provision into account, the Ministry of Economy conducted an analysis of the information provided by the Ministry of Defense from the Oberih register and by the Pension Fund of Ukraine from the PFU register.

From the available information, it follows that such an analysis was carried out on the basis of the data of the relevant information systems as of June 15, 2026. This means that if, for example, a part-time (concurrently employed) worker resigned from another place of work, where they were formally employed for a longer period than at their main place of work, after June 15, such changes might not yet have been reflected in the information received by the Ministry of Economy. Accordingly, the calculation of the reservation quota might have taken place without accounting for this concurrently employed worker.

It is expected that the Ministry of Economy will conduct a repeated analysis of the data of the Ministry of Defense and the Pension Fund of Ukraine at approximately July 13, 2026.

If, as of that moment, the information in the registers has not yet managed to update, the relevant concurrently employed workers may be counted toward the quota of other enterprises. This may lead to the exceeding of the enterprise's reservation quota, the loss of critically important status, and, as a consequence, the loss of the reservation of all workers and owners of the enterprise.

In view of this, UAC experts recommend that enterprises clearly verify the reservation quota calculations according to the data of the Pension Fund of Ukraine and obtain from workers the OK-5 and OK-7 certificates, which can be generated through Diia.

In the event of exceeding the quota, the enterprise must urgently cancel the reservation in the amount of such excess.

If an enterprise has any doubts about the correctness of the calculations or the risk of exceeding the quota, in order to avoid the complete loss of reservation, the experts advise canceling the number of military-liable workers specified by the Ministry of Economy by July 13, 2026.

As a reminder, agricultural producers can receive a free consultation on issues arising in the operation of farms, in particular regarding the reservation of workers, confirmation of critically important status, tax accounting, land relations, and participation in state support programs, etc.

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

For information, 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.