The Cabinet of Ministers of Ukraine has adopted Resolution No. 1608 dated December 8, 2025, amending the criteria and procedure for defining enterprises as critically important. In addition, on December 22, 2025, the Ministry of Economy issued Order No. 3650 introducing new requirements related to land area, revenue, and other indicators that allow agricultural companies to obtain critical status, ProAgro Group reports.
One of the key changes is the increase in the minimum area of agricultural land registered to a company. From now on, an agricultural enterprise must cultivate at least 1,000 hectares to qualify as critical, compared to the previous threshold of 500 hectares. Market participants link this decision not so much to a reassessment of the role of agribusiness, but rather to an attempt to reduce the administrative burden on decision-making authorities.
Another major change is the doubling of the annual revenue threshold required for a company to be considered economically active — from UAH 20 million to UAH 40 million. This adjustment is expected to have the greatest impact on grain traders, many of whom previously obtained critical status under the former revenue criterion. Companies that failed to secure this status in 2025 will now only be able to apply based on the updated revenue indicators.
An important development is the removal of the criterion related to the amount of personal income tax paid in the previous reporting quarter. This change may negatively affect companies with large workforces, particularly elevator operators.
The Ministry of Economy has also updated general requirements for all critical enterprises. Due to the increase in the minimum wage, the minimum average salary level has been raised to UAH 21,617.50. The same level now applies as the minimum salary for reserved employees.
The ministry emphasizes that this wage level must not only be declared when obtaining critical status but also maintained throughout the entire validity period. Failure to comply may result in the loss of employee reservation rights.
Analysts note that the updated criteria may significantly narrow the range of agricultural companies eligible for critical status in 2026, especially among medium-sized businesses and trading companies.
