New booking rules: detailed explanations
28 November 15:43Deputy Minister of Economy of Ukraine Vitaliy Kindrativ met with representatives of the European Business Association (EBA). During the meeting, he explained in detail to the business the new rules for booking employees liable for military service. The EBA published these explanations on its website, according to Komersant ukrainskyi.
Eligibility criteria
The new procedure for reserving employees subject to military service establishes strict requirements for companies applying for criticality status. By the end of February 2025, all companies must go through a procedure to recertify their criticality, which will certify their compliance with the new criteria.
From now on, all companies applying for criticality status must meet three criteria. Two of the criteria are mandatory, while the third is optional.
The first mandatory criterion is the absence of tax arrears. This must be confirmed by an official certificate from the State Tax Service.
The second mandatory criterion is that the average salary at the enterprise must be at least UAH 20 thousand per month. The employee to be booked must have the same salary for the last reporting period.
The third criterion is chosen by the company from a list of industry or regional criteria. These criteria must be developed by the relevant ministries and regional military administrations within 10 days after the adoption of the resolution (November 22) and must be approved by the Ministry of Defense and the Ministry of Economy.
Booking quotas
The new procedure introduces a differentiated approach to the quota for reservations of persons liable for military service at enterprises.
One hundred percent quota for employee reservations is granted to enterprises in the fuel and energy and defense industries.
For all other enterprises, regardless of industry and form of ownership, a single quota of 50% of the total number of employees liable for military service is set.
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Booking procedure
From now on, reservations for persons liable for military service will be made only through the Diia portal. The only exception is non-resident companies, which have a separate mechanism for submitting documents. Such companies will submit lists of employees liable for military service directly to the Ministry of Economy, which will carry out the booking procedure.
The new procedure provides for regular automatic checks of the criticality status of enterprises. By integrating with the Pension Fund and State Tax Service databases, the system will check the companies’ compliance with the established criteria on a monthly basis, ensuring that reservations are up-to-date and legitimate.
An important aspect of the new procedure is the possibility of withdrawing the reservation from employees at the request of the company. However, unless there are special reasons, such as the employee’s dismissal, the company may initiate such a withdrawal no more than once a month.
Restrictions on booking
Employees who have been working at the company for less than three months are not allowed to make a reservation. This temporary restriction is expected to be revised after the tax legislation is amended to reduce the required length of service to one month.
Special conditions are set for part-time employees. If an employee already has a reservation at his or her main place of work, he or she cannot be included in the general database of persons liable for military service at another company to receive an additional reservation.
The system provides for a transition period for reservations already issued. All existing reservations will remain in force until the company reconfirms its criticality status in accordance with the new rules.
New bookings for employees will be possible only after the company receives an updated criticality status in accordance with the new requirements.