Requirement for average salary of UAH 26,000 for military deferral in effect since June – Economy Ministry

Enterprises applying for the status of critically important for the military service deferral of their employees or wishing to confirm such status in July this year must have an average salary higher than three minimum salaries (UAH 25,941) already for June, the Ministry of Economy, Environment and Agriculture said in response to a request from the Interfax-Ukraine agency.

"From what date should the average salary at an enterprise be higher than three minimum salaries? – For the last (previous) calendar month. For example, if an enterprise applies to the relevant state body in July, the average salary of the enterprise for June will be taken into account," the Ministry of Economy said in its response.

At the same time, the agency noted that a decision to recognize an enterprise as critically important, which is valid as of June 2, 2026, remains valid for the period for which it was adopted, but no longer than until September 1, 2026.

When asked what companies whose deferral ends in June-July or which planned to apply for the first time during these periods should do, the Ministry of Economy advised submitting the necessary package of documents to the relevant state body to grant the enterprise critically important status after all state bodies review sectoral or regional criteria (by June 10, 2026).

The ministry noted that decisions on new deferrals will be made until August, "but not earlier than the review of sectoral or regional criteria by state bodies (by June 10, 2026)".

Regarding the possible cancellation of an enterprise’s critically important status in June due to the exclusion of a sectoral or regional criterion, such an enterprise can re-submit a package of documents to the state body to determine its new status, taking into account the revised sectoral or regional criteria, the response to the request says.

Earlier, a number of law firms, for example Sayenko Kharenko and Asters, noted that although companies must ensure the increased level of the average salary of three minimum salaries from the date of entry into force of government resolution No. 692 of May 30, the salary for each booked employee must correspond to the specified level from September 1, 2026.

"The updated salary criterion comes into effect from the date of publication of resolution No. 692 (June 1, 2026) – so starting from May 2026, the average salary of insured employee-persons at the enterprise must be accrued at a level not less than UAH 25,941," Asters believe.

Sayenko Kharenko reminded that for critically important enterprises whose location is determined and which actually operate in territories of possible or active hostilities, the rule on an average salary higher than 2.5 minimum salaries (UAH 21,618) has been preserved.

As reported, the specified resolution on changes to deferral also clarifies the rules for determining the number of employees who can be booked: employees who already have the right to a deferment from mobilization on other grounds, as well as part-time employees, will be counted toward the deferral quota at only one place of work, and these changes take effect on September 1, 2026.

"The resolution also strengthens control over compliance with the established deferral limits. In the event that an enterprise exceeds the permissible number of booked employees, the manager is obliged to submit an application through the Diia portal within 10 working days to cancel the relevant deferrals," Asters added.

"For violation of the specified obligation, a clear consequence is provided in the form of cancellation of criticality," Sayenko Kharenko emphasized.

Asters also reported that for Diia City residents, the new resolution clarified the requirements for confirming criticality.

"The very fact of being a Diia City resident is no longer a sufficient ground for obtaining the corresponding advantages. The enterprise must meet the requirements of Article 5 of the law ‘On Stimulating the Development of the Digital Economy in Ukraine’, namely regarding the established level of salary, which is confirmed by tax reporting for the last six months," the lawyers noted.

As Economy Minister Oleksiy Sobolev previously noted, if all companies increase salaries for their booked employees, the budget will receive an additional UAH 10-13 billion.

The review of the criteria for determining criticality for enterprises, according to the minister, was last conducted back in early 2025, and enough time has passed since then to conduct their audit.

"We do not expect any significant radical changes in changing the criteria… These will be pinpoint changes that regional administrations and ministries should review and see for a small share of companies whether these companies really meet critical urgency in order to balance the needs of the defense forces and the economy," Sobolev added.

The minister informed that more than 1.3 million people are currently booked in Ukraine, and he expects that this number will not change in the future.

"Over the past few years, it has fluctuated from 1.1 to 1.3 million – within these parameters, the deferral system has been working for several years, and it will continue to work within these parameters," the head of the Ministry of Economy said.