The Ministry of Economy of Ukraine is preparing amendments to the procedure for reserving employees subject to military service at critical infrastructure enterprises. According to published information, it is proposed to reduce the maximum quotas for the defence industry and certain critical infrastructure enterprises, to review the procedure for calculating the number of employees reserved, and to tighten controls over the granting of ‘critical’ status to enterprises. The proposal to limit the number of employees reserved at defence enterprises to 85% has been confirmed by the Ukrainian Council of Arms Manufacturers.
- The Ministry of Economy has drawn up proposals to restrict the booking of staff at critical enterprises.
- For some defence industry enterprises, it is proposed to reduce the maximum quota from 100% to 85%.
- There are reports of a possible reduction in the quota for certain utility companies from 75% to 60%.
- It is proposed that the calculation of the base booking quota in 50% be reviewed.
There are plans to reduce the number of employees at defence enterprises to 85%
The Ministry of Economy has drawn up a draft resolution of the Cabinet of Ministers which provides for a change to the maximum number of employees available for booking at enterprises within the defence-industrial complex. This was announced on 9 October by the executive director of the Ukrainian Gunmakers’ Council Ihor Fedirko.
According to him, the document has been submitted to the Ministry of Defence for approval. For some critically important defence industry enterprises It is proposed to set the maximum booking quota at 85% instead of the current 100%.
The Ukrainian Gunsmiths’ Council has spoken out against this restriction. Representatives of the sector emphasise that defence enterprises require qualified engineers, process engineers, equipment operators and other specialists to fulfil government contracts.
According to Fedirko, a reduction in quotas could hamper the expansion of defence production.
New limits have been announced for the energy and utilities sectors
According to widely reported information regarding the preparation of the amendments, the review of reservations may also affect energy companies and essential services providers. The report states that it is proposed to limit the maximum reservation quota for certain energy companies to 85%. For heat supply companies, water utilities and waste management organisations, there are reports of a possible reduction in the quota from 75% to 60%.
Current government regulations allow for the reservation of up to 75% employees subject to military service from certain categories of water supply, wastewater disposal and essential services enterprises.
How might the calculation of the 50% staff booking be affected?
Another proposed change concerns the method for determining the number of employees subject to military service, on the basis of which a company calculates its available recruitment quota.
According to a widely cited description of the draft, employees who already have a deferral from mobilisation on other lawful grounds may be excluded from the calculation basis. This applies, in particular, to students, parents of three children and citizens who are entitled to a deferral on the grounds of caring for relatives.
For example, if a company has 100 employees subject to military service, 20 of whom have been granted a deferment on other grounds, the calculation basis under the proposed model will be 80 people. Accordingly, the quota under 50% would allow 40 employees to be reserved instead of 50.
However, back in June 2026, the Ministry of Economy had already clarified certain rules regarding the treatment of employees who have other deferrals or who hold secondary employment. Therefore, the full impact of the new proposal can only be determined once the full text of the amendments has been published.
The Cabinet of Ministers is proposing to tighten controls on bookings
Reports of possible changes also mention the establishment of a Coordination Centre under the Cabinet of Ministers. According to the description of the initiative, representatives of the Security Service of Ukraine, the Main Intelligence Directorate, the Foreign Intelligence Service and the National Police may be involved in its work.
It is claimed that the recommendations of such a body could influence the granting of ‘critical’ status to enterprises, an increase in booking quotas beyond the baseline 50%, and the review of previously adopted decisions. However, the government had already considered a similar initiative to establish a Coordination Centre in July 2026, after which it revoked the relevant decision.
The criteria for determining which businesses are critical may be reviewed again
There are separate reports of a possible update to the sectoral and regional criteria for identifying critical enterprises.
The information circulated states that ministries and regional state administrations are to review the relevant criteria by 20 October. The government had already decided to review the criticality criteria in May 2026, whilst enterprises were undergoing procedures to confirm their status.
The new deadline of 20 October and its mandatory nature have not yet been confirmed by a specific government decree that has been published.
