Update of Sectoral Criteria for Determining Critically Important Enterprises

26/ 01/ 2026

Listen to online Stop   Pavlo Kotenko. Senior Legal Advisor Accountor Kyiv In late December 2025, the Ministry of Economy, Environment and Agriculture of Ukraine, by Order No. 3650 dated 22 December 2025, approved updated sectoral criteria for determining enterprises that are of significant importance to sectors of the national economy. The document was registered with the Ministry of Justice of Ukraine on 29 December 2025 under No. 1953/45359 and entered into force on the date of its official publication. From a practical perspective, the most significant change is the reinstatement of the so-called “economic” salary criteria with coefficients X2 and X3, linked to the minimum average number of employees. These criteria had been abolished in September 2025 and have now been reintroduced in an updated version. As a result, to confirm the status of an enterprise as being of significant importance to the economy, it is now necessary not only to demonstrate actual business activity, but also to ensure an appropriate payroll level and competitive official (gross) salaries for employees. According to the updated requirements, enterprises with an average number of at least 50 employees must meet a criterion whereby the average accrued salary for the last calendar month is not lower than the national average salary for the last reporting tax year multiplied by a coefficient of 2. For enterprises with an average number of at least 20 employees, a similar approach applies, but with a coefficient of 3. The regulatory wording explicitly refers to the “average accrued salary of insured persons,” i.e. gross salary accruals for employees for whom the unified social contribution is paid. The officially confirmed national average salary for the 2025 reporting tax year will be determined after the submission of tax reporting. For indicative calculations, the data of the State Statistics Service for November 2025 may currently be used, according to which the average salary amounted to UAH 27,167. Under this assumption, the minimum average monthly accrued salary required for the X2 criterion is UAH 54,334, while for the X3 criterion it is UAH 81,501. Accordingly, an enterprise with the minimum required workforce of 50 employees must ensure a monthly payroll of approximately UAH 2.72 million, while an enterprise with 20 employees must demonstrate approximately UAH 1.63 million in monthly salary accruals. As a result, the updated salary criteria effectively raise the requirements primarily for medium-sized businesses. For companies with a workforce of 20–49 employees, only the X3 option remains realistically available, and it is significantly more demanding. For enterprises with more than 50 employees, the X2 criterion appears more achievable; however, even this option will require many companies across various sectors to review their remuneration models, bonus systems, and financial planning, given that the criterion is assessed based on the indicators of the last calendar month. The Accountor Kyiv team provides comprehensive support in preparing and submitting the documentation package required to confirm or obtain the status of a critically important enterprise, taking into account the updated salary criteria.

Pavlo Kotenko

Senior Legal Advisor Accountor Kyiv

In late December 2025, the Ministry of Economy, Environment and Agriculture of Ukraine, by Order No. 3650 dated 22 December 2025, approved updated sectoral criteria for determining enterprises that are of significant importance to sectors of the national economy. The document was registered with the Ministry of Justice of Ukraine on 29 December 2025 under No. 1953/45359 and entered into force on the date of its official publication.

From a practical perspective, the most significant change is the reinstatement of the so-called “economic” salary criteria with coefficients X2 and X3, linked to the minimum average number of employees. These criteria had been abolished in September 2025 and have now been reintroduced in an updated version. As a result, to confirm the status of an enterprise as being of significant importance to the economy, it is now necessary not only to demonstrate actual business activity, but also to ensure an appropriate payroll level and competitive official (gross) salaries for employees.

According to the updated requirements, enterprises with an average number of at least 50 employees must meet a criterion whereby the average accrued salary for the last calendar month is not lower than the national average salary for the last reporting tax year multiplied by a coefficient of 2. For enterprises with an average number of at least 20 employees, a similar approach applies, but with a coefficient of 3. The regulatory wording explicitly refers to the “average accrued salary of insured persons,” i.e. gross salary accruals for employees for whom the unified social contribution is paid.

The officially confirmed national average salary for the 2025 reporting tax year will be determined after the submission of tax reporting. For indicative calculations, the data of the State Statistics Service for November 2025 may currently be used, according to which the average salary amounted to UAH 27,167. Under this assumption, the minimum average monthly accrued salary required for the X2 criterion is UAH 54,334, while for the X3 criterion it is UAH 81,501. Accordingly, an enterprise with the minimum required workforce of 50 employees must ensure a monthly payroll of approximately UAH 2.72 million, while an enterprise with 20 employees must demonstrate approximately UAH 1.63 million in monthly salary accruals.

As a result, the updated salary criteria effectively raise the requirements primarily for medium-sized businesses. For companies with a workforce of 20–49 employees, only the X3 option remains realistically available, and it is significantly more demanding. For enterprises with more than 50 employees, the X2 criterion appears more achievable; however, even this option will require many companies across various sectors to review their remuneration models, bonus systems, and financial planning, given that the criterion is assessed based on the indicators of the last calendar month.

The Accountor Kyiv team provides comprehensive support in preparing and submitting the documentation package required to confirm or obtain the status of a critically important enterprise, taking into account the updated salary criteria.