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Business requests a two-month extension for criticality updates and existing reservations

29/ 01/ 2025
  The European Business Association is appealing to the Government of Ukraine to extend existing reservations by two months and postpone the criticality update deadline to 30 April. This request arises due to the cyberattacks at the end of 2024 and the prolonged recovery of state registers, during which the reservation system and, most importantly, the process of granting companies critical status were non-operational. Additionally, the halt in register operations led to significant delays in the approval of sectoral and regional criteria by most government authorities. As a result, a large backlog of applications for critical status has accumulated at the ministerial and local government levels. It is evident that by 28 February, the state apparatus will be unable to process all applications and grant the relevant status to all genuinely critical enterprises. Therefore, the business community is calling for an additional two-month extension of existing reservations and a postponement of the criticality update deadline to 30 April. This would help avoid overloading the already strained system and ensure the stable operation of Ukraine’s economy. Furthermore, a legal gap in the criteria and procedure for granting critical status—specifically regarding the submission of tax reports for Q4 2024—could result in a high number of rejections. Applications for critical status are submitted in January, while Q4 2024 tax reports are due in the second half of February. To address this, urgent amendments to the criteria and procedure are necessary, allowing companies to submit reports for the most recent reporting period for which the tax filing deadline has passed. Specifically, businesses should be permitted to submit reports for Q3 2024 during January and February 2025.

The European Business Association is appealing to the Government of Ukraine to extend existing reservations by two months and postpone the criticality update deadline to 30 April.

This request arises due to the cyberattacks at the end of 2024 and the prolonged recovery of state registers, during which the reservation system and, most importantly, the process of granting companies critical status were non-operational. Additionally, the halt in register operations led to significant delays in the approval of sectoral and regional criteria by most government authorities.

As a result, a large backlog of applications for critical status has accumulated at the ministerial and local government levels. It is evident that by 28 February, the state apparatus will be unable to process all applications and grant the relevant status to all genuinely critical enterprises.

Therefore, the business community is calling for an additional two-month extension of existing reservations and a postponement of the criticality update deadline to 30 April. This would help avoid overloading the already strained system and ensure the stable operation of Ukraine’s economy.

Furthermore, a legal gap in the criteria and procedure for granting critical status—specifically regarding the submission of tax reports for Q4 2024—could result in a high number of rejections. Applications for critical status are submitted in January, while Q4 2024 tax reports are due in the second half of February. To address this, urgent amendments to the criteria and procedure are necessary, allowing companies to submit reports for the most recent reporting period for which the tax filing deadline has passed. Specifically, businesses should be permitted to submit reports for Q3 2024 during January and February 2025.

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