New Criteria for Obtaining the Status of an Enterprise of Significant Importance in the Digitalization Sector

The Ukrainian Government continues to enhance the framework for identifying enterprises that ensure the uninterrupted operation of critical sectors during martial law. An important element of this process is the revision of sector-specific criteria that allow businesses to obtain the status of an enterprise of significant importance to the national economy and, subsequently, qualify for Critical Enterprise status for the purpose of reserving military-liable employees from mobilization.

To this end, the Ministry of Digital Transformation of Ukraine adopted Order No. 127 dated 23 June 2026, approving new Criteria for determining enterprises, institutions, and organisations of significant importance to the national economy in the field of digitalisation. The new Order replaces the previous Order No. 182 dated 5 December 2024 and significantly expands and clarifies the eligibility requirements.

The updated framework introduces 18 eligibility criteria, each accompanied by a clearly defined list of supporting documents required to demonstrate compliance.

The new Criteria apply to a broad range of entities operating in the digital sector, including manufacturers and suppliers of telecommunications equipment, electronic communications operators, data centers and cloud service providers, domain name and mobile number portability database administrators, contractors involved in the deployment of xPON and mobile communication networks, IT companies, cybersecurity providers, administrators of state registers, participants in Brave1 defense innovation projects, qualified trust service providers, and operators of critical digital infrastructure. For certain categories of applicants, the Criteria establish specific financial, operational, staffing, and infrastructure requirements, together with detailed documentary evidence to support compliance.