Starting January 1, 2026, Ukraine plans to introduce new, stricter requirements for the salary levels of employees that employers wish to reserve for work at their enterprises. The new rules will primarily affect the private sector: the average salary for reservation must be no less than 21,600 hryvnias, both at the enterprise level and for each individual employee.
This is reported by Finway
What will change for enterprises and employees
The introduction of a higher wage threshold has two main objectives. First, it aims to prevent the mass reservation of employees with minimal official salaries. Second, this step is intended to stimulate the de-shadowing of incomes in the private sector of the economy.
The public sector does not expect significant changes; instead, private businesses will face stricter requirements for justifying the criticality of each employee. Already, relevant ministries are demanding that employers provide documentary evidence confirming that a specific employee is indispensable for carrying out mobilization tasks or ensuring the operation of critical infrastructure.
This approach is intended to eliminate cases of reserving employees with minimal official salaries and to stimulate the de-shadowing of incomes in the private sector
Who may be denied the extension of reservation
Starting in 2026, it is expected that the new requirements will become a common norm. At the same time, template or mass positions without convincing justification of criticality will be denied more frequently. Employees who are subject to military service and whose average official salary does not meet the new minimum threshold risk losing their deferral from mobilization. In the absence of other legal grounds for deferral, the reservation will not be extended after the expiration of previous decisions.
Those whose roles in the enterprise are not sufficiently justified as critically important, or if similar functions are performed by other employees, also face risks. A separate category includes employees with “problematic” military records: they are only eligible for short-term reservations at defense enterprises and only if the documentation is properly completed.
Additionally, individuals who have already received other types of deferral from mobilization (for example, due to family or medical circumstances) will not be able to simultaneously benefit from employer reservations. This significantly narrows the options for businesses to retain personnel in critical positions.