Ministry of Finance Updates the Criteria for Determining Enterprises of Significant Importance to the National Economy

On 23 June 2026, the Ministry of Finance of Ukraine adopted Order No. 335 approving new Criteria for determining enterprises, institutions, and organizations of significant importance to the national economy. The new Order is intended to replace the current Order No. 649 dated 18 December 2024 and aims to further improve the mechanism for identifying entities whose activities are essential to the national economy during a special period. Although Order No. 335 has already been registered with the Ministry of Justice of Ukraine, it has not yet entered into force.

The updated Criteria introduce several important amendments, particularly for audit firms and providers of legal and consulting services. One of the key changes is the strengthening of documentary evidence requirements. In particular, applicants will, in certain cases, be required to submit a confirmation letter from the recipient of their services (referred to in the Order as the "relevant enterprise") or from a competent public authority confirming the significance of the applicant's activities.

Given that the Order has already completed state registration and is expected to become effective shortly, businesses should proactively review the updated requirements and prepare the necessary supporting documentation. Early preparation will facilitate timely compliance with the new Criteria once they are officially published and enter into force.