EBA calls on the Government to ensure continuous re-booking of employees of critical enterprises

27/ 11/ 2025

The European Business Association has appealed to the Government of Ukraine to improve the procedure for re-booking conscription-liable employees for enterprises with critical-importance status. Business proposes enabling the re-booking of conscription-liable employees with a valid deferment on a continuous basis, or reducing the technical re-booking interval to three hours from the moment an application is submitted. This would allow re-booking to take place immediately after a decision is made confirming an enterprise’s “critical importance” status. Current provisions of the Resolution of the Cabinet of Ministers of Ukraine No. 76 establish a 72-hour period for automatically transferring an employee to the special military register, and the same mechanism applies to repeated bookings. Business representatives note that many companies will see the bookings of their employees automatically expire once their current critical-importance status ends. For a significant number of companies, this date falls in early December 2025. Even after receiving an order confirming their critical-importance status, companies currently have no technical possibility to re-book their employees in advance for the new validity period. As a result, enterprises are effectively forced to wait until existing deferments expire, creating a gap during which key employees may be mobilised. Consequently, enterprises risk losing essential staff, including drivers and technical specialists who support the uninterrupted operation of critical infrastructure such as electricity supply, mobile communications, and more. Businesses report multiple instances where booked employees received call-up notices the very next day after their current booking expired. It is worth noting that the ЕВА fully supports the need to maintain a balance between mobilisation requirements and ensuring the stable functioning of the economy during martial law. At the same time, the business community emphasises that such staffing uncertainty may lead to disruptions in enterprise operations and a decline in tax revenues. In view of this, business proposes introducing a mechanism for continuous re-booking - that is, the ability to extend employees’ bookings without waiting 72 hours and before existing deferments expire. One of the solutions proposed by the ЕВА is to reduce the technical re-booking interval to three hours from the moment an enterprise submits its application. To implement these solutions, the European Business Association is appealing to: 1. The Ministry of Economy, Environment and Agriculture of Ukraine, requesting the preparation and introduction of the relevant amendments to Cabinet Resolution No. 76. 2. The Ministry of Digital Transformation of Ukraine, requesting the technical implementation of automatic continuous re-booking. A corresponding letter has already been sent to the Prime Minister of Ukraine, Yuliia Svyrydenko, the First Deputy Prime Minister — Minister of Digital Transformation of Ukraine, Mykhailo Fedorov, and the Minister of Economy, Environment and Agriculture of Ukraine, Oleksii Sobolev.

Current provisions of the Resolution of the Cabinet of Ministers of Ukraine No. 76 establish a 72-hour period for automatically transferring an employee to the special military register, and the same mechanism applies to repeated bookings.

Business representatives note that many companies will see the bookings of their employees automatically expire once their current critical-importance status ends. For a significant number of companies, this date falls in early December 2025.

Even after receiving an order confirming their critical-importance status, companies currently have no technical possibility to re-book their employees in advance for the new validity period. As a result, enterprises are effectively forced to wait until existing deferments expire, creating a gap during which key employees may be mobilised.

Consequently, enterprises risk losing essential staff, including drivers and technical specialists who support the uninterrupted operation of critical infrastructure such as electricity supply, mobile communications, and more. Businesses report multiple instances where booked employees received call-up notices the very next day after their current booking expired.

It is worth noting that the ЕВА fully supports the need to maintain a balance between mobilisation requirements and ensuring the stable functioning of the economy during martial law. At the same time, the business community emphasises that such staffing uncertainty may lead to disruptions in enterprise operations and a decline in tax revenues.

In view of this, business proposes introducing a mechanism for continuous re-booking – that is, the ability to extend employees’ bookings without waiting 72 hours and before existing deferments expire. One of the solutions proposed by the ЕВА is to reduce the technical re-booking interval to three hours from the moment an enterprise submits its application.

To implement these solutions, the European Business Association is appealing to:

1. The Ministry of Economy, Environment and Agriculture of Ukraine, requesting the preparation and introduction of the relevant amendments to Cabinet Resolution No. 76.

2. The Ministry of Digital Transformation of Ukraine, requesting the technical implementation of automatic continuous re-booking.

A corresponding letter has already been sent to the Prime Minister of Ukraine, Yuliia Svyrydenko, the First Deputy Prime Minister — Minister of Digital Transformation of Ukraine, Mykhailo Fedorov, and the Minister of Economy, Environment and Agriculture of Ukraine, Oleksii Sobolev.