On 9 October 2025, the Verkhovna Rada of Ukraine adopted the Law of Ukraine “On Amendments to Certain Legislative Acts of Ukraine Regarding the Organisation of Labour Relations under Martial Law“. The law has not yet been signed by the President and therefore has not entered into force. The law provides for the following changes:
Temporary booking
From now on, companies have the opportunity to book militarily liable employees, even if these militarily liable employees:
Such an employee may be temporarily booked for a period of up to 45 calendar days from the date of conclusion of the employment contract, and such booking may be made no more than once a year for each employee. If during this time the employee rectifies the violation, they may be booked on general grounds.
Shortened probationary period
The law also stipulates that the probationary period for all military liable employees of critically important enterprises may not exceed 45 days, and the employer has the right to dismiss them if the documents are not brought into compliance during the probationary period.
Employment of an employee without military registration documents
The amendments to the legislation effectively remove the responsibility of officials of critically important enterprises for hiring military liable employees personnel who have unresolved issues with military registration until the end of the probationary period for such employees.
Changes to financial criteria for booking
It should be noted that one of the criteria for recognizing an enterprise as critical is the size of the average salary of the enterprise’s employees: the average salary at the enterprise must not be less than 2.5 times the minimum wage. As of 1 January 2025, the minimum wage is UAH 8 000, so the threshold for critically important enterprises is UAH 20 000.
Currently, a draft law of Ukraine “On the State Budget of Ukraine for 2026“ has been submitted to the Verkhovna Rada, which provides for an increase in the minimum wage from 1 January 2026 to UAH 8 647. Therefore, the wage threshold for critically important enterprises will also increase to UAH 21 617.5.
For further information, please contact Natalia Gerus, Counsel, or Zakhar Kymberskyi, Associate.