Reserving employees from mobilization in 2026 requires coordinated work between the accounting and HR departments. As a general rule, the salary threshold for a critically important company is UAH 25,941, but the average salary at the company and the pay accrued to each reserved employee are monitored separately. Before submitting lists, you also need to check that the critical importance decision is still valid, as well as the quota and the employment records.
Below we look at how to calculate the average salary, confirm the critical importance criteria, determine the quota and count part-time employees, and what to check if the Diia portal doesn't reserve an employee.
The rules and amounts are given as of September 21, 2026, under Cabinet of Ministers Resolution No. 76 as currently in force.
Have all earlier critical importance decisions expired
No, not all decisions expired on September 1. Subclause 1 of clause 2 of Cabinet of Ministers Resolution No. 692, as amended by Resolution No. 862, applies to decisions that were in force on the day Resolution No. 692 itself took effect. This rule limits them to September 1, 2026, but provides for an exception.
If the certificate of average accrued salary and the payroll tax report for the last calendar month required by the resolution were submitted by August 10, 2026, the decision could keep its original term. However, this doesn't apply to companies whose status was to be canceled because the industry or territorial criterion on which their critical importance was based had been removed.
So first, check the confirmation that the documents and information were submitted to the body that granted the company critical importance status. The date stated in the old order doesn't by itself prove that the company went through the confirmation procedure and kept this status. At the same time, September 1 doesn't mean all decisions automatically expired without exception.
If you're advised to submit documents by September 25, 2026, check the basis for this advice. September 25 isn't a general statutory deadline for submitting documents: the Criteria and Procedure approved by Resolution No. 76 don't contain such a deadline. Under clause 6, the body must review the application within the period it sets, starting from the day it receives it; we determine this period under the current version of Resolution No. 76. Plan your submission based on the expiry date of your own critical importance status, leaving time to prepare and clarify the documents. An application to confirm critical importance and an application to reserve employees in Diia are different procedures.
Which salary figures are needed to reserve employees
The accountant must monitor two separate salary figures, even when the numerical threshold for them is the same.
| What we check | Purpose | General requirement |
|---|---|---|
| Average accrued salary of insured persons — the company's employees | To obtain or confirm critical importance | At least 3 minimum wages for the last calendar month |
| Accrued salary of a specific employee on the reservation list | To meet the salary requirement during the deferral | At least 3 minimum wages every month |
The first requirement is set by paragraph three of subclause 6 of clause 2 of the Criteria and Procedure, the second by paragraph three of clause 8 of the Reservation Procedure. Both documents are approved by Resolution No. 76. Under Article 8 of the Law on the State Budget of Ukraine for 2026, the monthly minimum wage is UAH 8,647. So the general threshold is 8,647 × 3 = UAH 25,941.
The check uses accrued salary before tax deductions, not the amount paid to the employee's bank account. A company can pass the average salary check and still fail the personal salary requirement for one of its reserved employees. A high salary for the director may bring the average up to the required level, but it doesn't guarantee that the personal salary requirement is met.
For certain companies located in combat areas or temporarily occupied territories, the threshold is 2.5 minimum wages instead of 3, that is, 8,647 × 2.5 = UAH 21,617.50. This applies to both the company's average salary and the personal pay accrued to a reserved employee. The grounds are set by paragraph four of subclause 6 of clause 2 of the Criteria and paragraph four of clause 8 of the Reservation Procedure.
A registered address alone isn't enough: the company must not only be located but also actually operate in a territory on the list of the Ministry for Development of Communities and Territories of Ukraine (the Ministry for Development) for which no end date of possible hostilities, hostilities or temporary occupation has been set. The full lists of exceptions for the average and personal figures should be checked separately under Resolution No. 76.
How to calculate the average salary from the payroll tax report
For the new form of the payroll tax report, the Ministry of Economy has issued guidance on calculating the average salary. For legal entities, the reporting period is a calendar month. This is directly set by clause 5 of Section I of the Procedure for Completing the Report.
The Ministry recommends the following formula:
Average salary = (line 1.1 + line 1.3 + line 1.4) ÷ line 092.
The numerator includes accrued salary, pay for the first five days of temporary incapacity for work paid by the employer, and temporary incapacity benefits paid by the Pension Fund of Ukraine (PFU). The denominator is the number of employees in the reporting period who were accrued a salary, excluding persons receiving military pay. The calculation uses the line 092 figure, not an arbitrarily chosen headcount or average number of employees.
You should also take into account vacation pay and sick pay that relate to several months. If the full amount of such payments was paid and reported in the current month, it's included in that month's income. As a result, the accrued income in the following month may be lower, which will affect whether the salary criterion is met.
The letter is explanatory and doesn't establish legal rules. The salary criterion itself is set by Resolution No. 76. This formula shouldn't be applied to the personal salary requirement for a reserved employee, and line numbers from the old report form shouldn't be used mechanically.
Example. For the last calendar month, line 1.1 shows UAH 760,000, line 1.3 — UAH 12,000, line 1.4 — UAH 8,000, and line 092 — 30 employees. The average salary is 780,000 ÷ 30 = UAH 26,000. The general threshold of UAH 25,941 is met with a margin of only UAH 59.
If a reconciliation shows that the correct line 092 figure is 31 employees, with the same amounts the average will be UAH 25,161.29. In that case, the criterion will no longer be met. If there's an error in the reports, it must be corrected rather than adjusting the denominator to get the desired result.
The accountant should keep a separate calculation with references to the lines of the accepted report and reconcile it with the certificate used to confirm critical importance. Unofficial payments don't replace accruals shown in the reports. Bonuses, sick pay and corrections of earlier periods need to be correctly classified in the reports, not added manually to reach the required figure.
What the critical importance criteria require besides salary
A company, institution or organization that doesn't belong to special categories must meet at least three criteria. The salary criterion and the absence of tax and unified social contribution arrears are mandatory. The additional criterion is determined separately, for example, importance for an industry or a territorial community. For special categories, clause 3 of the Criteria and Procedure sets other conditions.
Before submitting documents, check:
- Which criteria apply to the company and which documents confirm each of them.
- For which last calendar month the average salary certificate was prepared and whether its figures match the payroll tax report.
- Whether proper confirmation of no arrears has been obtained.
- Whether reports for the last tax period have been filed and whether there's confirmation that they were accepted.
- When the current decision expires and to which body the documents are submitted.
The average salary certificate alone doesn't confirm that all criteria are met.
The list of documents for confirming the status is set by clause 8 of the Criteria and Procedure. Additional industry or territorial requirements should be checked against the current decision of the relevant body.
A standard set of certificates used by another company may not match the grounds on which your company confirms critical importance.
How to check the quota and count part-time employees
As a general rule, no more than 50% of the total number of employees liable for military service can be reserved. This limit is set by paragraph one of clause 8 of the Procedure for companies recognized as critically important for the economy. It's not half of the entire staff. The right to a higher limit or to a special ground must be confirmed separately.
Clause 12 sets out who's included in the total number of employees liable for military service. In particular, women liable for military service and persons reserved by another company aren't counted, while employees mobilized after May 18, 2024, are. This isn't a complete list, so the headcount from the staff schedule can't simply be multiplied by 50%.
A separate rule applies to employees with a deferral on other grounds under Article 23 of the Law of Ukraine "On Mobilization Preparation and Mobilization", and to part-time employees at another critically important company or institution. They're included in the total number at only one place of work — where their employment relationship has lasted longest. So the main place of work and the longest employment relationship don't necessarily mean the same employer.
If the set limit is exceeded after a dismissal or another change in headcount, don't wait for the next confirmation of critical importance. Under clause 9-2 of the Procedure, the director must, within ten business days from the day the excess arises, submit an application through Diia to cancel reservations, so that the number of reserved employees matches the set quota. That's why the quota should be recalculated after every staff change, not only before a new application.
What to check if Diia doesn't reserve an employee
First, check the reason stated in the result of the application review. The official service page in Diia distinguishes between the statuses "reserved," "not reserved" with an explanation of the reason, and "not eligible for reservation."
| Situation | What to check |
|---|---|
| There's a critical importance decision, but the service isn't available | Whether the body that granted the status has added the company to the Unified List |
| The employee isn't shown or the number of employees is wrong | Employment records with the PFU and how they're reflected in the Oberih register |
| The employee already has a reservation or a deferral on another ground | Whether the deferral ground is valid and the result of the check in the military register |
| After staff changes, the limit isn't enough | Whether the headcount for the calculation is correct, current reservations and the rules for part-time employees |
To update employment records, Diia recommends using the relevant service on the PFU portal. Changing data in the company's HR software doesn't mean it's already been updated in state registers. After making corrections, check the result of the data exchange and the status of the application. Confirmation of the reservation is shown in the electronic military registration document.
If the employee has already been mobilized, a different HR procedure applies. We covered it in our article on documenting the mobilization of an employee and settling accounts with them.
Before submitting lists, the director should check that the company's critical importance status is valid, as well as the average salary calculation, personal accruals and the quota, taking into account the latest staff changes. This check helps detect a problem before a refusal in Diia or the end of the deferral. UHY Prostir assists in aligning payroll, HR records and reporting, which the check of salary figures for reservation relies on. If you need to check accruals and reporting data before submitting documents, contact our team.
Tetiana Zvarych (accountant)
