May legislative initiatives signal the formation of a new architecture for mobilization, reserves, and employee reservation in Ukraine. Alongside draft laws on reserve service, digitalization of Territorial Recruitment Centers (TCC), and mobilization transparency, the Government has begun practical reforms to the reservation system. For business, the priority in the coming months will be confirming the status of “critically important enterprise” and adapting HR policies to the updated requirements.
Legislative Drafts (As of May 13, 2026)
1. Draft Law No. 15231: “On the Long-term Military Service and Reserve System”
- Key Concept: Introduces a multi-level model: basic military service (12 months), active reserve (5 years), and operational reserve.
- Business Impact: Reservists must attend two-week annual training sessions, during which employers must retain their position and average salary. This may impact logistics, energy, and manufacturing sectors.
2. Draft Law No. 15232: “On a Transparent Call-up and Mobilization Sequence System”
- Key Concept: Creation of a Unified Register of Mobilization Needs, providing citizens with free access to their status and sequence number.
- Business Impact: Potentially improves workforce planning predictability, though the mechanism and level of data detail remain undefined.
3. Draft Law No. 15237: “On Fair Reservation and Participation in Defense”
- Key Concept: Standardizes reservation rules, bans indefinite reservation, and introduces mandatory regular reviews.
- Business Impact: Proposes that reserved individuals participate in defense via critical infrastructure work, reserve service, or targeted defense contributions. Financial obligations for employers or employees remain a critical concern.
4. Draft Law No. 15236: “On TCC Reform and Service-Oriented Mobilization”
- Key Concept: Full digitalization of interaction with conscripts (e-summons, e-cabinet, mandatory video recording of TCC interactions, and independent appeal mechanisms).
- Business Impact: Should reduce administrative burden and minimize the “human factor,” streamlining communication between staff and recruitment centers.
5. Draft Law No. 15239: “On Economic Resilience During War”
- Key Concept: Guarantees include a 6-month transition period for tax changes, risk-oriented audits, and protection from arbitrary pressure.
- Business Impact: If enacted, this could be a landmark act for business stability, though many guarantees are currently declarative.
Government Update: New Reservation Rules (Effective May 30, 2026)
The Cabinet of Ministers has updated the procedure for determining “critically important enterprises” and reserving staff.
Key Changes:
- Salary Threshold: The average salary for reserved employees or critical status must be at least 3 minimum wages (25,941 UAH). For companies in frontline territories, the threshold is 2.5 minimum wages (21,618 UAH).
- Part-time Employees: An employee working at multiple jobs will count toward the reservation quota only once.
- Recertification: Ministries and Regional Military Administrations (OVA) must re-approve their criteria. Consequently, all enterprises must re-confirm their status.
Transition Period:
- Existing critical status and reservations remain valid.
- The transition period ends on September 1, 2026.
Recommendations for Business:
- Audit Payroll: Check if your workforce meets the new salary thresholds.
- Update Data: Ensure all conscript records are accurate.
- Check Multi-jobbers: Audit part-time employees against your quotas.
- Prepare Documentation: Start compiling packages for re-confirmation early.
- Monitor Criteria: Watch for updates from your specific profile ministry or local OVA.
- Avoid Delays: Do not wait until the end of August; processing takes up to 10 working days.
