Employee Reservation in Ukraine 2026: Eligibility, Process, and Penalties

You’ve already lost one specialist to mobilization — and you’re trying to protect the rest. Employee reservation in Ukraine in 2026 isn’t a formality. It’s a legally precise procedure where a single document error wipes out a month of HR work and puts the company at risk.

As of April 2026, Ukraine’s Ministry of Economy had more than 4,200 legal entities registered in the Critical Enterprises Registry. But a large share of them get the procedure wrong. Here’s who actually qualifies for reservation, how to file through Diia, and what happens when it goes sideways.

# Which Companies Qualify for the Critical Enterprises Registry

A company can only reserve employees after it’s been added to the registry — retroactive inclusion doesn’t exist. The registry is jointly maintained by Ukraine’s Ministry of Economy and the relevant sector ministries.

Under Resolution No. 76, as amended in 2025, a company qualifies as critical under four main criteria:

1. State defense orders. Government defense contracts must account for at least 50% of total revenue over the prior 12 months. This is the most common category — manufacturers of ammunition, armored vehicles, communications equipment, and drones.

2. Critical infrastructure. Energy facilities (Ukrenergo, regional power distributors), water supply systems, the gas transmission system (Gas Transmission System Operator of Ukraine), and railway transport. The specific list of such facilities is approved by the Cabinet of Ministers and published by Ukraine’s State Service of Special Communications (DSSZZI).

3. Healthcare and pharmaceuticals. State and municipal hospitals at regional level or above, plus manufacturers of medicines included in Ukraine’s National Medicines List. Private clinics qualify only if they operate under state medical guarantee programs worth at least UAH 30 million (~$750,000) per year.

4. Strategic production. Companies where the state holds at least a 50% ownership stake, or companies executing export contracts generating at least $5 million USD per quarter in foreign currency revenue.

IT companies without a government contract can’t get into the registry — full stop. That’s one of the most common mistakes HR teams make. Outstaffing and outsourcing aren’t critical activities by definition. If you’re building HR processes that minimize legal risk, our article on outstaffing and outsourcing for Ukrainian businesses covers the structural logic.

# How to Apply for Registry Inclusion

The application goes to the relevant sector ministry — not Diia, directly to the ministry. The package includes: an extract from Ukraine’s Unified State Register of Legal Entities and Individual Entrepreneurs (USR), certified copies of state contracts, 12-month financial statements, and a written justification. Review takes 30 business days. Once approved, the company receives a certificate and a registry code — that code is required when filing through Diia.

# How to Reserve an Employee Through Diia — Step by Step

This is the part that trips people up most. Diia Business isn’t a perfect tool, but it works if you know the sequence.

Step 1. Log in. Go to business.diia.gov.ua using a Qualified Electronic Signature (QES) belonging to an authorized company official. Either the director or an employee authorized by internal order — both work.

Step 2. Registry check. In the “Бронювання” (Reservation) section, the system automatically verifies your company’s code against the Critical Enterprises Registry. No code, no application — there’s no manual workaround.

Step 3. Upload the employee list. A strictly formatted .xlsx file: full name, individual taxpayer number (RNOKPP/INN), date of birth, military specialty, and job title. The system cross-checks each person against the military-eligible persons registry. A data mismatch returns that row as an error.

Step 4. Limit check. Diia automatically calculates what percentage of your military-eligible headcount you’re reserving. Exceed 50% — the system trims the list. Not by your choice. Alphabetically — A goes first.

Step 5. Sign and submit. The full package is signed with QES. After submission, the system generates an application number and registration date. Save it — that’s your confirmation.

Step 6. Wait. Up to 15 business days. Track status in your personal account. Three statuses: “under review,” “approved,” “rejected.” Rejections always include a stated reason.

Step 7. Receive certificates. Approved employees get personal reservation certificates in their Diia accounts. That document is what they show at the Territorial Recruitment Center (TRC). The employer keeps a copy in the personnel file.

Honestly, Step 3 is where most applications fail. Verify every employee’s RNOKPP against the State Tax Service database before you submit. That process takes roughly a week — build it into the timeline.

# Who Can’t Be Reserved Even If the Company Qualifies

Being in the Critical Enterprises Registry is necessary — but not sufficient. Diia will automatically reject certain individuals regardless.

The following cannot be reserved:

• Military-eligible persons who have already received a summons and failed to report to the TRC;
• Individuals with an unexpunged conviction for evading military service (Art. 336 of the Criminal Code);
• Employees currently on the wanted list per Ministry of Internal Affairs records;
• Citizens previously classified as deserters from the Armed Forces of Ukraine;
• Persons over 60 — they’re outside standard military-eligible age.

Diia cross-checks databases in real time. If the TRC has already flagged someone, the system will reject that person with no on-screen explanation. You’ll only learn the reason by visiting the TRC in person.

But here’s a nuance almost everyone misses. Reservation doesn’t stop an employee who wants to serve from enlisting voluntarily. Reservation is protection against forced conscription — not against a voluntary enlistment application.

# Why Reservations Get Revoked — and What Comes Next

A reservation being revoked isn’t just the employee’s problem. It’s a signal that the whole company may be reviewed.

Three grounds for revocation under Resolution No. 76:

1. Employee resignation. The employer must notify the TRC within 3 business days of the termination. Miss that window — administrative fine. A terminated employee without notification stays listed as reserved for 30 more days. During that period, they’re legally your responsibility.

2. Company removed from the registry. This happens when the defense order share drops below 50%, during reorganization, or when fraudulent contracts are discovered. When the company leaves the registry, all reservations are canceled simultaneously. Employees must be notified within 5 business days.

3. TRC inspection finds violations. The most painful scenario. An inspector discovers that an employee’s documented job title doesn’t match their actual role — or that the person hasn’t been showing up to work. The reservation is revoked immediately.

After revocation, the military-eligible employee receives a standard TRC notice within 10 days. The employer cannot re-file a reservation application for that individual for 90 days — this is explicit in the resolution.

And for business leaders planning growth or restructuring: account for this risk early. The same logic applies to business survival strategies under uncertainty — preparation beats reaction every time.

# Penalties for Getting Reservation Wrong in 2026

This isn’t theoretical. In the first five months of 2026, Ukraine’s Prosecutor General’s Office opened more than 140 criminal proceedings related to fraudulent employee reservation — per official data from May 2026.

Administrative liability. Art. 172-14 of the Code of Administrative Offenses: a fine of UAH 8,500 to 51,000 (~$213–$1,275) per responsible official. And it’s personal — the fine lands on the individual who signed the application. The director, HR director, or designated military records officer. Not the company. The person.

Criminal liability. If a court establishes that the reservation was filed to help someone evade military service — Art. 336 of the Criminal Code of Ukraine. Up to 5 years imprisonment. Applied in cases of systematic violations or coordinated schemes.

Registry removal. The company is stripped of Critical Enterprise status for at least 1 year. Reinstatement means the full package again and another 30 business days. Every reserved employee loses protection immediately.

Reputational damage. Removal from the registry is published on the Ministry of Economy’s website. That directly affects eligibility for tenders on Ukraine’s public procurement platform Prozorro.

And — this matters — even honest data errors can trigger a fine. A wrong RNOKPP, a job title that doesn’t match the staffing schedule. So before every submission: verify the data. Not after.

If you want to build document management systems that prevent these risks systematically, financial fundamentals for managers covers the same underlying discipline — precision in records saves companies.

# How to Maintain Military Records to Keep Reservations Active

Reservation isn’t a one-time event. It’s an ongoing system.

Every 6 months — renewal. A reminder appears in the Diia personal account 30 days before expiration. Miss the renewal window and the reservation expires automatically. No TRC call, no warning. The protection just disappears.

Every quarter, update the list: who’s resigned, who’s been hired, any role changes. This isn’t paperwork theater — during TRC inspections, auditors cross-check data against the USR and staffing schedules. A discrepancy is grounds for revoking all reservations, not just one person’s.

Designate a single point of responsibility. One person — the authorized military records officer — must complete official training (the Ministry of Economy runs free webinars; the most recent was in March 2026) and hold a QES. Their details are registered in Diia as the company’s contact person.

Maintain a military records journal — this is required under Art. 34 of Ukraine’s Law “On Military Duty and Military Service.” TRC document audits start with that journal.

One practical detail that gets overlooked: reservation doesn’t exempt an employee from the obligation to register with the TRC and keep their personal data current. If an employee hasn’t updated their address or military specialty, their reservation can be technically revoked — even if the company did everything right.

# What Changed in 2026 Compared to 2024–2025

The trend is consistent — tighter rules.

From January 2026, the reservation cap for companies without a direct defense order was cut from 50% to 35% of military-eligible employees. This hit agro-holdings, transport companies, and construction firms hard.

Mandatory verification through the “Rezerv+” mobile app is now required. Every reserved employee must confirm their location and place of employment in the app monthly. Fail to confirm — the reservation is suspended pending review.

From March 2026, Territorial Recruitment Centers gained the right to conduct unannounced inspections of registry companies — on-site, without advance notice. Previously, inspections were scheduled and companies had 10 days’ warning.

So it’s already happening. According to dou.ua (Ukraine’s leading tech industry publication) data from April 2026, several large IT outsourcing companies that attempted to obtain critical enterprise status through fictitious Ministry of Defense contracts were removed from the registry after unannounced inspections.

# What “Critical Function” Actually Means for a Specific Role

The company’s in the registry. The headcount cap isn’t exceeded. But the TRC inspector revokes a specific employee’s reservation. Why?

Because what’s being reserved isn’t just a person — it’s a person in a specific role performing a critical function. A marketing manager at a rocket engine manufacturer isn’t a critical function. The design engineer at that same factory is.

A critical function is one whose absence prevents the company from fulfilling a state contract or maintaining critical infrastructure operations. That has to be documented: a job description, a department charter, a direct reference to a specific government contract.

HR teams that reserve “everyone who fits in the quota” — they’re creating real risk. For the company and for themselves personally.

# See Also

• Business organization and team management in Ukraine
• Financial tools for small and medium businesses
• Business loans and credit for sole proprietors in Ukraine
• Calculators for business metrics

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