New Booking Rules Effective September 1: Clarifications on Salaries, Debts, and TCC Inspections

Starting September 1, new booking rules will come into effect. To avoid losing their booking, businesses need to reconfirm their status: settle tax debts and ensure a salary of at least 25,941 UAH. We explore how to update documents in time and avoid issues with the TCC.

As of September 1, 2026, all decisions recognizing enterprises as critically important, made before the update of government regulations according to CMU Resolution No. 692, will no longer be valid.

Now, businesses are required to reconfirm their status under new, stricter criteria. To ensure that employees do not lose their deferrals, action must be taken now.

For Delo.ua, the legal nuances of the procedure, financial calculations, and risks for employees are explained by Irina Domitrashchuk, lawyer and partner at Magnet Legal Law Firm.

How Transitional Rules Work

The Cabinet of Ministers has established a transitional period: decisions regarding the criticality of enterprises operating as of June 2, 2026, will remain in effect for a certain period, but no longer than September 1, 2026. Since booking directly depends on the company's status, it cannot remain in effect longer than the decision on criticality.

At the same time, specialists explain that changing or updating criteria does not automatically terminate the status. If the authorized body has not issued a separate document for cancellation, the booking of employees remains valid until the end of summer.

Who Is Not at Risk of Status Cancellation

The September 1 deadline does not apply to all businesses. Automatic cancellation does not threaten the following categories:

• Companies that have submitted reports: If an enterprise provides the relevant authority with a certificate of average salary, reports on ESV/NDFL/VZ for July 2026 by August 10, 2026, and meets the updated criteria, the validity of the decision will be extended not until September 1, but until the end of the original term.
• Defense Industry Enterprises: For enterprises providing defense forces and other military formations, the September 1 deadline does not apply at all.

The Main Deadline of Summer: Why It’s Important to Act Before August 10

To maintain continuous employee booking, companies must submit an updated document package by August 10: a certificate of average salary, tax calculation of income amounts, and data on ESV payments for the last calendar month.

If submitted on time, the company's status and current deferrals will continue to be valid for the entire initial term.

Authorities are obliged to review documents even if they arrive after August 10; however, this creates significant threats to the stable operation of the business.

"If the package is submitted after August 10, the state authority will review it in any case. However, this creates the risk that as of September 1, the enterprise will not have a valid decision confirming its status. In this case, the company temporarily loses the opportunity to book employees until a new decision is made," explains Irina Domitrashchuk.

Minimum Salary: How to Account for Part-Time Workers and Maternity Leaves

The main financial requirement for confirming criticality has become the average accrued salary. It must be at least three minimum salaries for the enterprise as a whole — that is 25,941 UAH.

This figure is calculated by dividing the total amount of all accrued salaries and sick leaves by the number of employees who received these payments. External part-time workers must also be included in the calculations if they were paid a salary.

Many enterprises are facing questions regarding employees who are physically considered on the payroll but do not receive payments, as well as IT sector specialists. According to an expert, only those employees who have been paid wages are included in the calculation. Consequently, employees who are on unpaid leave and women on maternity leave are not counted.

As for gig specialists residing in Dія.City, they work under gig contracts and are not considered employees under the Labor Code, so the requirement for three minimum salaries does not apply to them.

Tax Debts and the Right to Correct Errors

The second non-negotiable condition concerns the complete absence of tax and social security debts. Even a minimal debt arising from technical payment delays or bank rounding is grounds for refusing to maintain status. The enterprise must first settle any debts, wait for data updates in the tax information systems, and then submit documents for critical status with a certificate confirming the absence of debt.

However, receiving a refusal is not a final verdict for the company.

"If the authorized body refuses to grant status due to non-compliance with the criteria, such a refusal does not deprive the enterprise of the right to reapply after correcting the identified deficiencies," notes a partner at Magnet Legal Law Firm.

Therefore, after settling the debt, the enterprise can resubmit the document package and claim the status.

Synchronization of Registers and Required Documents for TCC Checks

By September 1, a complete electronic synchronization of the databases of the Ministry of Defense and the Ministry of Digital Transformation must take place. If the enterprise fails to update its status in time, information about the termination of deferrals will appear in the "Oberih" register, and employees will be subject to mobilization on general grounds. The greatest risk arises when the enterprise's documents are already under review, but no decision has yet been made.

The lawyer notes that the mere fact of submitting documents to confirm critical status does not create a right to deferment for employees, as it only arises after a decision is made. In a situation where they meet with representatives of the TCC, employees should inform them that the documents are under review and provide appropriate confirmation.

"At the same time, the legislation does not obligate the TCC and SP to halt mobilization activities solely on the grounds that documents are under review," warns the attorney.

In case of technical failures, when the current reservation is temporarily not displayed in the "Oberih" register or the "Reserve+" application, it is recommended to carry a printed military registration document and a list of military personnel prepared by the employer through the "Diia" portal. However, the determining factor for military personnel will always remain the official data from the unified electronic register.

How Reservation Will Work in Autumn

If the company successfully passes the check and confirms its critical status by August 10, this decision remains in effect for the entire established period.

The enterprise will no longer need to submit separate salary level certificates to the relevant ministries monthly. The company retains the right to reserve new employees within the limit.

At the same time, the state retains the tool for control: authorities can conduct selective checks. If during such a check it turns out that the average salary has fallen below 25,941 UAH or the company has accumulated tax debts, the status of a critical enterprise will be revoked.

Context of Changes in Reservation Rules

At the end of June, the Cabinet of Ministers of Ukraine strengthened the criteria for companies seeking to obtain critical status and the right to reserve their employees. In particular, the government significantly raised the requirements for annual revenue volumes and the level of average salaries.

Later, the government established a requirement for the average salary at the enterprise in the current month. It must be at least 26,000 hryvnias. Otherwise, it was noted that businesses risk losing their critical status, and employees risk losing their current deferrals from mobilization.

At the same time, the government simplified the procedure for confirming status and re-reserving employees after September 1. Those enterprises that maintain compliance with the updated criteria for criticality during the review will be able to confirm their status in an almost automatic mode and continue reserving for their employees.