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Ukraine’s Ministry of Economy, Environment and Agriculture has updated the requirements for companies seeking critical enterprise status, a designation that allows eligible employees to receive draft exemptions.
Under the new rules, agricultural companies must now cultivate at least 1,000 hectares of farmland, up from the previous threshold of 500 hectares. The minimum annual revenue requirement has also doubled from UAH 20 million to UAH 40 million.
The ministry has removed two previously valid qualification criteria. Companies can no longer obtain critical status based solely on quarterly personal income tax payments of at least UAH 324,000 or by owning 90% of the capital of other critical enterprises.
Agricultural businesses must now provide a tax reporting document officially confirmed by the relevant tax authority.
For forestry enterprises, the minimum area of permanently managed land has increased from 500 hectares to 2,500 hectares. The required number of insured employees has been reduced from 15 to 10, but a new mandatory annual revenue threshold of UAH 10 million has been introduced.
Several business activity categories have also been removed from the list of qualifying forestry operations, including hunting, engineering, geology, and certain educational services.
The updated regulations introduce new salary requirements as well:
- Companies with more than 50 employees must pay an average salary at least twice the national average wage for the previous year.
- Companies with at least 20 employees must meet a coefficient of three times the national average wage.
- Permanent representative offices of foreign companies must also meet the three-times-average-wage requirement.
Businesses operating in three or more regions of Ukraine must additionally:
- Employ at least 10 staff members.
- Pay at least UAH 24,000 in taxes and social contributions per region over the previous three months.
Manufacturers of Ukrainian machinery and equipment may qualify for critical status if their products are included on the Ministry of Economy’s approved list and are eligible for state compensation programs.
According to Economy Minister Oleksii Sobolev, more than 1.3 million employees are currently covered by reservations at critical enterprises, representing roughly 12% of Ukraine’s workforce. Critical infrastructure companies account for more than 60% of state budget revenues, he said.
