EBA сalls for dialogue on potential changes to employee reservation procedures

20/ 10/ 2026

The European Business Association has sent an official letter to the President, the Prime Minister, the Minister of Economy and Environment, and the Minister of Defence of Ukraine, highlighting the risks associated with a possible tightening of restrictions on employee reservation procedures. Ensuring the country’s defence capabilities is an unquestionable priority. At the same time, tax revenues from businesses are one of the key sources of funding for the security and defence sectors. The business community therefore emphasises the need to maintain a balance between national security requirements and economic resilience. The Association also points out that companies have recently undergone a demanding process of reconfirming their critical enterprise status under updated requirements, while some businesses have increased official salaries to meet the established criteria. Introducing further changes without proper consultation would create an additional regulatory burden and undermine the predictability of government policy. According to business representatives, tighter restrictions could lead to the loss of key specialists, disruptions to production processes and supply chains, reduced tax revenues, and diminished capacity in the defence industrial sector. In view of these risks, the European Business Association calls on the government to ensure policy predictability in employee reservation procedures, refrain from introducing substantial changes without prior dialogue with businesses, and assess their potential impact. Key proposals include involving the business community in the development of policy decisions; establishing a transparent mechanism for considering applications from businesses; ensuring balanced representation of security and defence authorities and relevant ministries in the decision-making process; and providing a level playing field for compliant employers without excessive administrative burdens or unnecessary bureaucracy. The Association stands ready to contribute to the development of balanced solutions that take national security requirements into account while helping to preserve Ukraine’s economic stability.

Ensuring the country’s defence capabilities is an unquestionable priority. At the same time, tax revenues from businesses are one of the key sources of funding for the security and defence sectors. The business community therefore emphasises the need to maintain a balance between national security requirements and economic resilience.

The Association also points out that companies have recently undergone a demanding process of reconfirming their critical enterprise status under updated requirements, while some businesses have increased official salaries to meet the established criteria. Introducing further changes without proper consultation would create an additional regulatory burden and undermine the predictability of government policy.

According to business representatives, tighter restrictions could lead to the loss of key specialists, disruptions to production processes and supply chains, reduced tax revenues, and diminished capacity in the defence industrial sector.

In view of these risks, the European Business Association calls on the government to ensure policy predictability in employee reservation procedures, refrain from introducing substantial changes without prior dialogue with businesses, and assess their potential impact.

Key proposals include involving the business community in the development of policy decisions; establishing a transparent mechanism for considering applications from businesses; ensuring balanced representation of security and defence authorities and relevant ministries in the decision-making process; and providing a level playing field for compliant employers without excessive administrative burdens or unnecessary bureaucracy.

The Association stands ready to contribute to the development of balanced solutions that take national security requirements into account while helping to preserve Ukraine’s economic stability.