New Booking Rules: Zheleznyak Criticized the Timelines and Exceptions for Approving Criticality

People's Deputy Yaroslav Zheleznyak stated that obtaining the status of a critically important enterprise can take up to one and a half months. The final changes to the booking rules, in his assessment, create risks of delays and opaque decisions. This was reported by Yaroslav Zheleznyak on the Iron MP channel.

Timelines for Determining the Criticality of Enterprises: What Changed in October 2026

The Deputy analyzed the Cabinet Order No. 1328 dated October 23. According to him, instead of the previous ten working days, the procedure includes three consecutive stages:

• up to seven working days for the authorized body to review documents;
• up to one calendar month for recommendations from the Coordination Center;
• up to three working days for the final decision.

In total, this may take about one and a half months. This concerns the approval of the enterprise's status, which affects the possibility of booking, rather than the timeline for processing each employee through Diya.

At the same time, the government provided for expedited consideration. Upon a justified request from a government body, the Coordination Center should provide recommendations within seven working days. Thus, one and a half months is an estimate of the maximum duration of the standard procedure, not a mandatory waiting period for everyone.

A separate risk Zheleznyak associates with old decisions of the Ministry of Defense regarding increased booking limits. For decisions made before the Cabinet Order dated December 8, 2025, No. 1608 came into effect, a deadline for validity is set: December 8, 2026. This restriction applies to a specified category of decisions, not all current bookings.

Booking Criteria and Appointment Exceptions: Zheleznyak's Claims in 2026

According to the Deputy, enterprises will have to further justify what harm the reduction of their operations due to personnel mobilization will cause. He believes that insufficient specificity of indicators leaves room for subjective assessments during the application of criteria for the criticality of enterprises.

Zheleznyak also drew attention to a separate norm for the head of the entity authorized to exercise public oversight over audit activities. The Deputy criticized the inclusion of this position in the list of full booking in the context of restrictions for enterprises.

His claims about corruption risks are an assessment of possible consequences. He did not mention any specific proven cases of abuse under the new procedure in the given speech.

For employers, the practical conclusion is the need to separately check the timeline for criticality status, the timeline for the decision on increased quotas, and the timelines for employee delays. These dates may not coincide. And the application of booking rules for the defense industry requires consideration of the specific grounds on which the enterprise obtained its status.