What it's about

The Ministry of Economy, Environment and Agriculture has reinstated the requirement on average wages as one of the criteria for identifying enterprises important to the national economy. This is set out in Order No. 3650 of December 22, 2025, published on the ministry's website.

Why it matters now

The decision has a direct impact on mobilization practice: employees of enterprises with the relevant status may receive exemptions from mobilization. At a time when the state must balance between defense needs and preserving critical infrastructure, the criteria for identifying these enterprises are not merely a technical detail but an element of national security.

Which criteria were restored

According to the order, status may be granted to enterprises under the following conditions:

• for companies with at least 50 employees — the average salary for the most recent month must be at least twice as high as the national average for the previous tax year;
• for companies with 20–49 employees — the requirement is stricter: the salary must be at least three times higher than the national average.

At the same time, official results for the average salary for the whole of 2025 are not yet available; the State Statistics Service reported that in October 2025 the average salary was approximately UAH 26,913 per month.

Expansion of the list and security requirements

The order also allows manufacturers of machinery and equipment whose products are partially subsidized from the budget to obtain the status. At the same time, security restrictions have been tightened: enterprises will not be recognized as important if their beneficiaries are citizens or residents of Russia, Belarus, or countries on the FATF blacklist, except for persons who lawfully permanently reside in Ukraine.

"The return of the wage criteria is a mechanism that combines economic expediency with national security: we aim to preserve jobs while also protecting critical supply chains,"

— press service of the Ministry of Economy, Environment and Agriculture

Context: previous changes and business reaction

The criteria were already in effect under the December 2024 order but were removed from the text in September 2025. The rules' return comes against the backdrop of an appeal by the European Business Association on November 27, 2025 requesting changes to rebooking rules, and following Cabinet of Ministers' decisions in early December 2025 on 45-day booking and the cancellation of inspections for defense‑industry enterprises.

What it means for businesses and employees

The criteria will incentivize some enterprises to raise average wages — this may lead to real improvements in working conditions, but also carries the risk of formal adjustments to the payroll fund to obtain benefits. For small and medium enterprises (20–49 employees), the threshold of three times the national average wage is a significant barrier.

Because there is no final figure for the average salary for 2025, a transitional period of uncertainty arises: companies will need to quickly adapt accounting and HR practices, and the state must ensure transparent mechanisms for verifying owners and payroll calculations.

Conclusion — what next

In practice, this decision combines an economic incentive with a security element: it raises the bar for those seeking exemption from mobilization and at the same time introduces new requirements for transparency of ownership structures. Now the ball is in the court of the Cabinet of Ministers and businesses: will these criteria become a real mechanism to protect critical infrastructure, or will parts of the market seek legal and accounting workarounds?