Ministry of Digital Transformation Working on an Alternative Employee Reservation Process for Companies with Foreign Directors

Currently, only the head of a critically important enterprise can submit data for reserving conscripted employees. However, foreign nationals serving as directors do not have access to this function, as it requires logging in through the “Diia” portal.

To address this, the Ministry of Digital Transformation is working on an alternative mechanism allowing such companies to submit reservation data to the state authority that designated them as critically important. That authority, in turn, would enter the information into “Diia” on the company's behalf.

This option is already available for certain types of entities (e.g., international technical assistance projects, employees of specialized UN agencies, members of supervisory boards, etc.). The Ministry aims to make this mechanism available to other enterprises that lack the technical capability to use the online service.

These developments were announced during a general meeting of the European Business Association with representatives from the Ministry of Defense of Ukraine, the Ministry of Economy of Ukraine, and the Ministry of Digital Transformation, held on May 15, according to the EBA.

Other topics discussed at the meeting included:

• Inclusion of mobilized employees (post-April 18, 2024) in the overall count of conscripts. Testing for this feature in the “Oberih” system is ongoing, with implementation expected in the coming weeks.
• Issues with reservation cancellations in “Diia”, where the reservation status in the “Reserv+” app can disappear unexpectedly. Employers can detect this through the military register. The Ministry of Defense is working on implementing push notifications indicating the reason for cancellation in “Reserv+.”
• Re-reservation period: The proposal to reduce the re-reservation window from 72 to 24 hours was not supported by the Ministry of Economy, Ministry of Defense, or the General Staff due to potential abuse. However, the business community suggested allowing companies to apply for renewal of existing reservations in advance (e.g., one month before expiration).
• Automation of deferments for scientific and academic personnel. The Ministry of Defense confirmed that work is already underway on this issue, and updates will follow.
• Monitoring of critically important enterprises: Government agencies will gradually conduct systematic reviews to verify companies’ compliance with critical status criteria. No fixed deadlines for these reviews have been set.
• Income calculation issues: It was clarified that total employee income includes sick leave payments, vacation pay, and other compensations. Payments from other months will be considered on a case-by-case basis.
• Digitalization of company reporting: All basic military registration records already exist in the “Oberih” and other state registers. Full digitalization of reporting processes to reduce administrative burden remains a separate area requiring further development.
• Automatic deferments for employees raising three children, including cases where some children are not biological (e.g., spouse’s children from a previous marriage), are being considered.
• Lack of accountability for delays in critical enterprise status decisions: Currently, review timelines are only indicative, and there is no liability for officials who miss them. Authorities note that delays are mostly due to poor-quality documentation submitted by companies (e.g., incomplete reporting, insufficient company information).
• Issues with outdated data in the “Oberih” register, which reflects in “Diia”: Sometimes information on dismissed employees remains in the system for months. Employees are advised to manually update their employment data through the “Reserv+” app.