Small Farmers Face Major Hurdles Under Updated Reservation Rules
Ukraine's Cabinet of Ministers adopted Resolution No. 692 in late May, triggering a broad overhaul of the criteria that determine which businesses are deemed critical and can reserve employees from military service. Deputy Dmytro Solomchuk has warned that the new standards may be overly burdensome for small farming operations. Existing company criticality decisions and reservation rights will remain valid until their expiration, but no later than September 1, 2026.
Under the updated requirements, all enterprises—including those in the agricultural sector—must re-certify their status under the new rules by September 1, 2026. Regional military administrations have already issued preliminary versions of their local criteria. Each administration independently defines its own criticality benchmarks, which include:
- land area size;
- number of employees;
- annual revenue;
- total taxes paid per hectare.
Draft versions of the updated criteria from regional administrations must still be approved by the national government.
“We will simply lose affordable Ukrainian products on store shelves, and imports will dominate instead,” said Dmytro Solomchuk.
Solomchuk added: 'In the committee, we are waiting for consolidated proposals from the regional administrations, and we will definitely push for changes so that small farmers can obtain reservation status. Otherwise, small-scale farming will be completely knocked out.'
Operations that grow berries, vegetables, or manage orchards face the greatest risk. This indicates that the new requirements could severely harm this sector unless the specific needs of small farms are taken into account. Ensuring the new criteria are accessible and clear to all agricultural market participants is therefore essential.
Impact on Food Security
The introduction of fresh employee reservation criteria in agriculture could significantly affect small farmers, who are already grappling with numerous challenges. As competition from imported goods intensifies, maintaining domestic production is critical for the country's food security. The question of whether small agricultural producers can meet the new standards—and adapt quickly enough—has become a decisive factor in ensuring the sustainable development of Ukraine's farming sector.
The ongoing discussion surrounding the new reservation criteria has raised significant concerns among agricultural stakeholders. As the government implements these changes, many are left wondering about the clarity and accessibility of the updated standards. For further insights on the Ministry's stance regarding these new regulations affecting the agricultural sector, see our detailed coverage on the Ministry's refusal to clarify the updated criteria.