For organizations that train operators of unmanned systems for the needs of the security and defense forces of Ukraine, legislation provides a separate basis for obtaining the status of a critically important organization. Such status makes it possible to reserve liable-for-military-service employees within the established limit. In this article, we will consider what requirements apply to such organizations and how to prepare for submitting an application.

Who may obtain the status

Pursuant to Cabinet of Ministers Resolution No. 76, the Ministry of Defense may designate as critically important for meeting the needs of the Armed Forces and other military formations those enterprises, institutions, and organizations that carry out training, retraining, and advanced training of external pilots (operators) of unmanned systems and external crews in the interests of the security and defense forces of Ukraine. The form of ownership is irrelevant: it may be a company, a charitable foundation, or a public organization.

Resolution No. 76 does not expressly define the presence of a school certificate under CMU Resolution No. 1129 as a separate condition for this criterion. At the same time, certification of the school is strong evidence that the organization is entitled to carry out the relevant training and in fact conducts such activities.

The key criterion is the volume of training

During the last 12 months prior to the date of application, the organization must have trained, for each employee it proposes to reserve:

• not less than 100 UAV pilots of classes I and II, including FPV, or

• not less than 200 UAV pilots of class I “micro” (except FPV).

These categories are counted under different standards, so the record of graduates should be maintained separately by class. It is also important to confirm that the training was carried out specifically in the interests of the security and defense forces of Ukraine. Therefore, it is advisable to compile an evidentiary base for each training cohort: requests, referrals, letters from military units or other bodies of the security and defense sector, documents confirming completion of training, and issued certificates.

How many instructors may be reserved

The number of employees that may be reserved depends not only on the total number of graduates, but also on the category of trained pilots. For example, if over the last 12 months the school trained 360 UAV pilots of classes I–II, for whom the standard of 100 persons per one liable-for-military-service employee applies, the training volume allows the organization to claim reservation of three employees. To reserve four employees, at least 400 such graduates are required.

If the school trains UAV pilots of class I “micro” (except FPV), a different standard applies: 200 trained pilots per one liable-for-military-service employee.

Compliance with the criterion must also be monitored after the status is obtained. The Ministry of Defense has the right to verify whether the organization continues to meet the established requirements. If, during such verification, the training volume for the relevant 12-month period no longer supports the declared number of employees for reservation, this may lead to a revision of the reservation limit or the criticality status.

Salary of the employee being reserved

Separate from the training volume criterion, the requirements directly applicable to reserving an employee must also be taken into account.

As a general rule, a liable-for-military-service employee of a critically important organization who is included in the reservation list must be accrued a monthly salary of not less than three minimum wages during the deferment period. In 2026, this amounts to UAH 25,941 per month. For certain categories of employers, legislation provides exceptions.

Therefore, before submitting for reservation, it is advisable to check the structure of employment relations and the amount of salary accrued to each employee planned for reservation.

Employment relations

In practice, many schools provide training free of charge, and instructors work as volunteers or under civil-law contracts. Volunteering or a civil-law contract in itself does not create the employment relations required to reserve a person as an employee of a critically important organization. Therefore, instructors intended for reservation must be properly engaged in employment relations with the organization.

How to submit an application

The organization applies to the Ministry of Defense with justification of compliance with the criterion. Since legislation does not establish a standardized form of justification for this type of application, the evidentiary base is of key importance: calculation of the number of trained pilots over the last 12 months, documents confirming the categories of trained operators, proof that the training was conducted in the interests of the security and defense forces, as well as documents concerning the organization itself and its activities. The status of a critically important organization is acquired from the date of issuance by the Ministry of Defense of the relevant order. After the organization is included in the Unified List of reserved liable-for-military-service employees, reservation is carried out through the Diia Portal within the limit established for the organization. The status must be confirmed at least once a year.

Legal support for criticality for UAV schools

The Digilaw legal team supports training centers at all stages:

• assessment of compliance with the criterion and calculation of the reservation limit

• analysis of instructor engagement and salary requirements

• preparation of justification and document package for the Ministry of Defense

• support during review of the application

• support for employee reservation and annual confirmation of status

If your school trains drone operators and wants to retain instructors, start with a legal assessment. It will show how many people may be reserved and what needs to be prepared for submission.