Ukraine has tightened the criteria for critical enterprises
The Ministry of Economy, Environment, and Agriculture of Ukraine has updated the criteria for identifying enterprises that are of critical importance to the economy. The changes significantly raise the requirements regarding land area, revenue, and wage levels for companies seeking this status and the right to reserve employees.
The stricter criteria apply to enterprises’ eligibility for “critically important” status, which entitles them to certain benefits, particularly regarding employee retention.
The following changes have been introduced for the agricultural sector:
- the minimum land area has been increased from 500 hectares to 1,000 hectares
- the minimum annual revenue has been raised from 20 million UAH to 40 million UAH
- certain tax criteria (particularly regarding personal income tax) have been removed
- the option to obtain this status through ownership of 90% of the capital of other enterprises has been abolished
Additionally, mandatory confirmation of tax returns by the tax authority has been introduced.
In this sector:
- the land area requirement has increased from 500 hectares to 2,500 hectares
- The minimum headcount under the alternative criterion has been reduced from 15 to 10 people
- A new financial threshold has been introduced—at least 10 million UAH in annual revenue
- a number of KVED codes have been excluded (hunting, engineering, geology, education, and others)
Differentiated requirements for average salary have been introduced for the first time:
- enterprises with more than 50 employees—salaries must be at least twice the national average
- 20 or more employees — ×3
- Interregional status: a staff of at least 10 people and minimum tax payments of 24,000 UAH in each region over a 3-month period
- Representative offices of non-residents — salary must be three times the national average
Manufacturers of equipment may obtain this status if their products are included in the Ministry of Economy’s list and are partially subsidized from the budget.
The following enterprises continue to be recognized as critical:
- receive government grants
- have been operating under government contracts for at least 6 months
- are under the jurisdiction of the Ministry of Economy
- operate in three or more regions
- are participants in industrial parks
- implement large-scale investment projects in manufacturing, processing, or extraction.
The relevant Order No. 6954 is dated June 24, 2026.
Earlier, the Cabinet of Ministers of Ukraine adopted a new resolution providing for a large-scale audit of enterprises with “critically important” status and stricter rules for reserving conscripts during mobilization.
