Booking reworked: will business turn into mini-TCK?

The government of Serhiy Koretskyi, which has been in power for just over 100 days, has taken on the heavy burden of improving mobilization. The government first set out to put the booking of critical-business employees in order. The need for such steps is explained by the faint hopes for a quick peace, and by the fact that the aggressor country, according to Ukrainian intelligence, continues to ramp up its mobilization efforts, including by using foreign mercenaries (for example, allied North Korea plans to send an additional 10 thousand soldiers to the front). According to MP and member of the defense committee Fedir Venislavskyi, the size of the occupation army on Ukrainian territory is currently about 750 thousand people.

In September the new minister of economy, Oleksandr Kravchenko, published interesting figures: in Ukraine the number of people booked from mobilization reaches 1,4 million. This number exceeds the number of people already serving in the Defense Forces. Moreover, according to government sources, the monthly “army” of the booked is steadily growing — on average by 25 thousand people. This gives reasonable grounds to suspect that booking is being abused, and that such necessary mobilization resources are hidden here.

As a result, on 23 October the Cabinet of Ministers issued Resolution No.1328 on certain issues of organizing the booking of those liable for military service for the period of mobilization and wartime. According to it, businesses have until 8 December to rebook under the new rules. The main arbiter in determining the true criticality of enterprises becomes the Coordination Center for organizing the booking of those liable for military service. This structure has the status of a temporary consultative-advisory body to the Cabinet, with two leaders (the co-chairs are the deputy ministers of economy and defense), as well as representatives of various ministries and law enforcement agencies (a total of 18 officials).

“Glavkom” examined the nuances of the new booking procedure developed by the Koretskyi government and the principles of the social contract that the new prime minister proposes the state make with business.

How it all began

At the beginning of the year the number of people booked in Ukraine was slightly more than 1 million. Since January this indicator showed significant dynamics, and this caused concern in the new government team.

In a conversation with “Glavkom,” MP from European Solidarity and member of the parliamentary committee on national security, defense and intelligence Iryna Friz describes the situation like this: The Commander-in-Chief began to incline the government to decide to “cut” the sectors that had the right to 100% booking, namely the defense-industrial and fuel-energy complexes. And the government began to implement those decisions.

“If you take the entire booking structure, the defense-industrial sector accounts for only 10% of all booking in the country! Instead, the largest share of booked people is held, for example, by the manufacturing industry (the MP did not disclose the exact figure to “Glavkom”). When I asked directly why booking should be limited for an industry that is directly responsible for state security, none of the government officials gave a comprehensive answer,” the opposition member complained.

However, it is very difficult to refute the government’s arguments and the facts of booking abuse. In Kyiv, for example, it is not hard to meet barbers or fitness trainers who are… booked at a defense or IT enterprise. Those liable for military service are indeed fictitiously employed in such companies through connections or bribes.

Another trigger that prompted the authorities to change the rules was numerous scandals over booking granted to media personalities. The latest example: former minister of defense Mykhailo Fedorov was booked by the charity organization “East Europe Fund” just days after his scandalous resignation. This case has already attracted the attention of a parliamentary Temporary Investigative Commission.

It is worth recalling that in the summer of 2026 the predecessor of Serhiy Koretskyi, Prime Minister Yulia Svyrydenko, also changed the approach to business booking. Back then they based it on wage level — three minimum wages (25 941 UAH). At the same time, the wage threshold of 2,5 minimum wages (21 618 UAH) was retained for enterprises in areas of active combat and occupied territories.

The previous government also clarified that part-time employees among those liable for military service are counted when determining a booking quota only at one place of work.

Furthermore, the past Cabinet determined that exceeding the booking limit is grounds for canceling the criticality status.

The new Cabinet Resolution No.1328 does not abolish the previously established filters and the wage threshold for those wishing to be booked. In particular, seven criteria of criticality remain in force: amount of taxes and fees paid – over 1,5 million euros during the reporting calendar year; volume of foreign currency receipts – more than 32 million euros per year; strategic importance for the state; significant importance for the industry or community; absence of arrears on the Unified Social Contribution; wage level; resident status of “Diia.City.” Meeting three of the seven gives an enterprise grounds to receive critical status.

Along with this, a collegial body appeared in the form of the Coordination Center for organizing the booking of those liable for military service. “The Svyrydenko government relied on formal indicators that are checked automatically (wages, taxes, limits, ‘Diia’). The Koretskyi government adds a collegial filter to them and shifts the decision center from the Ministry of Defense to the Ministry of Economy. The idea of balancing mobilization and the economy is sound. But the body that effectively decides whether a business will have booking should have not an advisory but an authoritative status: with responsibility for decisions, a transparent methodology and the ability to appeal. Otherwise the risks of queues, manual management and opacity will outweigh the benefits,” says lawyer Dmytro Buzanov, who assessed the booking innovations for “Glavkom.”

Iryna Friz also points to another mobilization-related moment — experimental military contracts with terms of service from 6 to 24 months, introduced on the basis of the Cabinet resolution of 12 June No.768. Since 15 June it has been possible to sign new infantry-assault, combat or basic military service contracts with the Armed Forces of Ukraine and other components of the Defense Forces. After the expiration of these contracts, deferrals from conscription for mobilization are provided — at least six months.

At the same time, the MP emphasized, deferral issues from mobilization are regulated not by government resolutions but by laws adopted by the Verkhovna Rada. “None of these contracts, to which the government ties the advertised deferral, was brought into compliance with current mobilization legislation. This means that those who sign these various forms of fixed-term contracts are not currently guaranteed a deferral,” the politician explained.

Koretskyi’s Coordination Center instead of Shmyhal’s Interagency Group?

Now a few words about the Coordination Center for organizing the booking of those liable for military service, whose creation provoked heated discussions.

The body includes the deputy ministers of defense, economy, digital transformation, internal affairs, restoration and infrastructure, agricultural policy; the deputy chief of the General Staff; the heads of the State Border Guard Service, the National Police, the Pension Fund, State Labor Service; representatives of the central directorate of the SBU, the Foreign Intelligence Service, the Main Intelligence Directorate of the Ministry of Defense; representatives of the Cabinet’s state secretary, the Ministry of Energy and the Ministry of Economy.

The deputy head of the Office of the President also holds a separate position in the Coordination Center.

Personal composition of the Coordination Center for organizing the booking of those liable for military service, formed by Serhiy Koretskyi’s Cabinet

As Glavkom noted, government resolution No.1328, in addition to the Coordination Center, also mentions the Interagency Working Group on conscription of those liable for military service during mobilization and on developing capabilities for recruiting foreigners and stateless persons for military service under contract. An organization with that cumbersome name appeared in June 2024 with the blessing of Denys Shmyhal’s Cabinet; Shmyhal is now First Vice Prime Minister — Minister of Energy.

Denys Shmyhal’s Interagency Working Group of the Cabinet, which dealt with various aspects of mobilization, including booking

“The Coordination Center does not duplicate the Interagency Working Group but takes over its booking function. The main legal flaw is that the real influence of the Center no longer corresponds to its advisory status,” states lawyer Dmytro Buzanov. “At the level of authority there is no duplication: the working group retains conscription and recruiting foreigners, while booking moves to the Center.”

What exactly changes with the appearance of the Coordination Center? First, before the adoption of Resolution No.1328, ministries and regional administrations approved sectoral criteria in agreement with the Ministry of Economy and the Ministry of Defense. Now this can only be done after coordination with the Coordination Center.

Second, the determination of the status of a critically important enterprise. Under the new rules, the body to which the enterprise applied has seven working days to consider it, after which it appeals to the Coordination Center. The Center provides recommendations within one month, and in urgent cases within seven working days. After that the body makes a decision “taking into account the Center’s recommendations” within three working days.

Third, booking over the limit (over 50% for everyone and over 95% for the defense industry and energy). Previously proposals went to the Ministry of Defense, and the Ministry made decisions based on proposals of the Interagency Working Group. Now proposals are submitted to the Coordination Center, and decisions are made taking its recommendations into account.

Fourth, the Coordination Center may recommend depriving an enterprise of critically important status, including on the basis of an appeal from law enforcement agencies. In addition, a separate ground for refusing an increase in booking has appeared: two or more documented violations of military record-keeping rules by a manager within 12 months or bringing him to administrative liability.

“The logic of the changes is clear. Until now the defense bloc acted as the sieve of booking: the Interagency Working Group is chaired by the defense minister. In the Coordination Center there are two co-chairs — the deputy minister of economy and the deputy minister of defense. Meetings are held only with the participation of both, and in the case of an equal split of votes a decision is adopted only when both co-chairs support it. Thus an institutional parity between the interests of the army and the economy is embedded. The composition also includes those who have the data: the Ministry of Digital Transformation, the Pension Fund, State Labor Service. The center should check the lists of employees-candidates for booking through Oberih, the Pension Fund portal and Diia,” added lawyer Buzanov.

MP Iryna Friz, however, believes the Interagency Working Group was created to develop changes to current legislation. And the Coordination Center was created to give approvals for receiving critical status. “This is ‘ticketing,’ if you will. It is a bureaucratic superstructure (the Coordination Center — ‘Glavkom’) that contains significant corruption risks,” the opposition member criticizes the new temporary consultative-advisory body attached to the Cabinet.

Social contract: farmers are already frightened

The informational support for the extremely complex topic of booking was taken up personally by Prime Minister Serhiy Koretskyi. Already after the controversial Resolution No.1328 appeared, the prime minister, speaking at the Kyiv International Economic Forum, announced a new social contract. The authorities promised to draft all changes by 1 December.

After the booking change, Prime Minister Serhiy Koretskyi proposed that business conclude a new social contract

photo: rada.gov.ua

“And now the most important thing I address to enterprises, business, the economic sector: we need to jointly come up with a new social model, where, let everyone be fully booked, but enterprises provide a predictable mobilization of people into the army. This is an idealistic model. If such a solution could be found, the need to look for people on the streets would disappear. And if business, an entrepreneur, manager, leader takes on such an obligation — then nothing else is needed, this is a new social contract. But not thinking and not preparing for this is a super strategic mistake,” Koretskyi explained.

On the one hand, the prime minister’s idea of one hundred percent booking may seem attractive. After five years of a large-scale war, business faces a significant labor shortage. On the other hand, after the prime minister’s statement, managers of enterprises that so far have booked up to 50% of their employees and with whom “Glavkom” spoke do not feel eager to turn into “mini TCKs” to “decide people’s fates.”

“Three government sources told me: book 100%. But you must within a year send 10-15% of liable employees to the army. And I, as a business owner, decide who to send and who not. If I don’t fulfill the so-called ‘social contract,’ I will face an administrative protocol for violating military record-keeping. After a second such violation the enterprise loses critically important status and, accordingly, booking is annulled,” reasons the owner of a medium-sized agroholding in a conversation with “Glavkom.”

As “Glavkom” learned, on 28 October a meeting between agribusiness representatives and Prime Minister Koretskyi took place. Farmers expressed disagreement with government Resolution No.1328 and asked the prime minister to take their wishes into account. In response Koretskyi proposed creating a working group together with business to develop additional proposals regarding booking.

And already on 29 October 35 representatives of business associations held the first online meeting within the working group initiated by the prime minister. “So far there is little detail. By 1 December the Cabinet plans to introduce changes to the booking resolution. Then we’ll see what changes,” a meeting participant from the business side told “Glavkom.”

Budanov’s lifeline

A rational initiative from the Office of the President could have reduced the temperature of the booking debate. In early May the head of the Office, Kyrylo Budanov, held a meeting with leaders of the Defense Forces and MPs. In particular, the discussion concerned attracting foreigners and stateless persons to military service under contract in the ranks of the Armed Forces of Ukraine and the National Guard.

According to a Glavkom source in the Verkhovna Rada, the authorities planned to recruit up to 5 thousand foreigners per month into the military.

At that meeting a task was also set to create a structural recruiting unit at the Ministry of Defense; to present a program for developing the system of attracting foreigners and stateless persons to military service; and to draft necessary changes to the laws. The new unit was supposed to accompany foreign servicemen throughout their service period.

Kyrylo Budanov (center) holds a meeting with military officials and MPs from the defense committee (Servant of the People MP Fedir Venislavskyi on the left)

photo from the president’s website

In a conversation with “Glavkom,” Servant of the People MP and participant in Budanov’s May meeting Fedir Venislavskyi admitted: the deadline to create the recruiting unit at the Ministry of Defense has been missed. This was influenced by the rotation of the defense ministers (14 July saw the dismissal of Mykhailo Fedorov. His successor Yevhen Khmara began full ministerial duties on 19 August).

“I recently met with Minister Khmara. I reminded him of the May meeting at the Office of the President and the decisions to create the department for recruiting foreigners. It has not yet been implemented. The defense minister assured that the issue is in the process of being resolved,” the politician said.

According to Venislavskyi, a number of problems related to the support of foreigners during military service in Ukraine also remain unresolved. These concern their social and legal protection, payment of compensation, etc.

“At the legislative level an algorithm is being developed so that the legal status of foreign servicemembers and Ukrainian servicemembers would be practically identical with all the relevant social guarantees,” added the Servant of the People MP.

Fedir Venislavskyi also noted that the vast majority of foreigners who currently volunteer and are integrated by military units come from South America. If recruiting foreigners is confined solely to the Ministry of Defense, then it will be necessary to involve a significant number of officer and NCO personnel who freely speak Spanish, the MP is convinced. So far this issue also remains unresolved.

“I visit South America once every three months. There are many willing volunteers ready to fight for Ukraine. I have also been to Nigeria, where the Ukrainian consul reported a queue of volunteers, but we have an unresolved issue with the timely processing of permits. Unfortunately, our authorities are not working on this at scale,” the agribusinessman with whom “Glavkom” spoke states.

He confirms that officials are actively probing the idea that businesses, which are interested in one hundred percent booking of their employees, would take on the task of recruiting foreigners. The “fair social contract” would look like this: Ukrainian business earns money, which it spends on bringing in foreign mercenaries and subsequently paying taxes that will go toward servicemembers’ salaries. Or the business suspends operations and goes to the war,” the entrepreneur explained the difficult choice.

Vitalii Taranenko, “Glavkom”