Cabinet Resolution No. 692 of 30.05.2026 and Ministry of Economy order No. 6954 reset the critical-enterprise and reservation system. Guides written before June are partly out of date — here are the key changes.
What Diia City is and who really benefits
Diia City is a special legal and tax regime for IT. A resident pays preferential taxes on its specialists' compensation and chooses how its profits are taxed, while the team gets access to gig contracts and other tools borrowed from Anglo-Saxon law.
The recommended vehicle is an LLC that is not VAT-registered. There is only one entry condition: matching qualifying activity codes (KVED) and a qualifying-income share of at least 90%.
The regime works best for companies with 9+ specialists and a predictable payroll. Smaller teams can still join, but the economics need a case-by-case calculation — fixed costs (audit, critical-enterprise status) weigh more per head.
Qualifying activities
Status is granted for specific activities. The list is wider than "classic development" — it covers games, IT education, cybersecurity, virtual assets, esports and robotics.
Show the full list of qualifying activities ▸
- Computer programming, IT consulting, and computer equipment management.
- Publishing of computer games and other software.
- Providing software products (including games) online, web app delivery services, distribution of software copies in electronic form, including elements, updates and feature extensions.
- IT education: higher, professional pre-higher and vocational education (computer science, information systems, engineering, cybersecurity, data science), plus digital-literacy, business-analysis, QA, system-administration, project-management and technical-writing training.
- Data processing and related activities (excluding infrastructure provision and hosting), web-portal operations.
- R&D in ICT.
- Marketing campaigns and advertising using software developed with the resident's involvement; organising esports competitions, teams, centres, clubs and broadcast studios.
- Services related to virtual assets; cybersecurity of systems, products and information.
- Designing and implementing measures and products to prevent cyber incidents, defend against attacks, remediate consequences and restore system resilience.
- Processing and analysing data on cyber incidents, identifying preconditions and issuing recommendations.
- Planning and designing integrated computer systems for protected information processing.
- Cybersecurity consulting on client communication systems and software; operation and maintenance of relevant equipment and software.
- R&D in cybersecurity; design, research and testing of robotics technologies, devices and systems with computerised control.
Requirements to keep meeting every month
On top of the 90% qualifying-income share, a resident must meet two headcount-and-pay conditions:
- Headcount: at least 9 employees and/or gig contractors (monthly average).
- Average compensation: at least the equivalent of €1,200 per engaged person at the NBU rate as of the 1st of the month. This is an average: some can be at €2,000, some at €800.
Startup exemptions
Companies founded no more than 24 months ago (including newly created ones) can skip the headcount requirement if annual revenue stays under 1,167 minimum wages — about UAH 10,091,049 in 2026.
If a company joined Diia City as a startup, it can skip the salary and average-headcount criteria until 31 December of the year following the year status was granted. After that — general rules.
Labour taxation: 13% instead of 45%
For the resident's specialists (both gig contractors and employees) the preferential rates are:
- PIT — 5% on income.
- Military levy — 5% on income.
- Unified Social Contribution — 22% of the minimum wage, i.e. a flat UAH 1,902.34 in 2026, regardless of the compensation amount.
Preferential rates apply only if the salary requirement is met. If the salary is accrued lower, the standard rates kick in (around 45% in total), and the employer covers the difference. That is why monitoring compensation is the foundation of the regime's economics.
VAT: the regime does not exempt automatically
A common misconception is that a Diia City resident does not deal with VAT. That is wrong. There is no automatic VAT exemption tied to the status. If taxable supplies exceed UAH 1,000,000 per year and the customers are Ukrainian residents, you must register as a VAT payer on the standard basis.
That is why the revenue model and customer mix should be designed before you start — they affect both pricing and the choice of profit-tax regime.
Separate resident reporting
On top of ordinary LLC reporting, a Diia City resident files:
- Initial compliance report — for the first three months of residency. Filed within 6 months starting from the month following status acquisition.
- Annual compliance report — no later than 1 June of the year following the reporting year. An independent auditor's report on the compliance report is attached.
Critical-enterprise status and reservation under the 2026 rules
This is where 2026 changed the most. There are two layers: reservation itself (the resident quota) and critical-enterprise status, without which reservation does not work.
Who and how many can be reserved
- Founders — no cap on numbers. If three people founded the company, all three are reserved, even if they are not on the payroll.
- Employees — up to 50% of the total number of those liable for military service.
Critical-enterprise status: updated criteria
Previously, simply being a Diia City resident covered one of the critical-enterprise criteria. From 02.06.2026 that is no longer enough. You also need to:
- confirm an average remuneration of €1,200+ per engaged person over the last 6 months (via the Consolidated Report);
- have no debt on USC or taxes;
- meet the reserved-employee salary floor of UAH 25,941 (3 minimum wages), in force from 01.09.2026 (before that date, the benchmark is UAH 21,617.50);
- for startups — additionally confirm income / investment of at least €20,000 (sales of services or goods, royalties, investments, grants).
What it costs to launch and run
Indicative project costs:
| Item | Timing | Cost, UAH |
|---|---|---|
| LLC registration via Diia.Business (KVED, share capital, e-signature registration, residency application) | 1 day + up to 3 days for status | 5,250 |
| Accounting support on the general system at the workload described | monthly | 18,000 – 24,000 |
| Audit for the annual compliance report (company with low document volume) | annually | from 70,000 |
| Audit-process support (documents, schedules, organisation) | annually | from 15,000 |
| Obtaining / renewing critical-enterprise status, legal documents | as needed | separately |
Two annual budget scenarios
Timeline: from LLC to reserved team
Online via Diia.Business using the owner's e-signature. Legal address provided by the client. The state service is free.
The application is filed together with registration. Then a bank account is opened and the director gets e-signature keys.
Building the team, keeping the 90% qualifying-income share and the average remuneration.
Confirming compensation ≥ €1,200, no debt, salary floor. Renewed annually.
Founders — no cap, employees — up to 50% of those liable for military service.
FAQ
Can we reserve employees right after registration?+
No. Reservation is only possible after obtaining critical-enterprise status, which realistically takes 2–4 months from registration. Founders are reserved within the resident quota, but also only after critical-enterprise status.
Is just being a Diia City resident enough for critical-enterprise status?+
From 02.06.2026 — no. On top of the status, you must confirm an average remuneration of €1,200+ for 6 months, no debt and compliance with the reserved-employee salary floor (UAH 25,941 from 01.09.2026).
How much tax do you pay on payroll under Diia City?+
5% PIT + 5% military levy on compensation, plus USC at 22% of the minimum wage (a flat UAH 1,902.34). Total burden — around 13% versus 45% outside the regime.
Does Diia City exempt you from VAT?+
No. Exceeding UAH 1,000,000 in taxable supplies to Ukrainian-resident customers triggers mandatory VAT registration on the general basis.
What happens to old critical-enterprise statuses in autumn?+
All previously granted statuses terminate on 1 September 2026. Re-confirmation under the new criteria is required — otherwise employee reservation is automatically cancelled.
This material is informational and reflects the state of the law as of 29 June 2026 (including Cabinet Resolution No. 692 of 30.05.2026 and Ministry of Economy order No. 6954 of 24.06.2026). It is not individual tax or legal advice — decisions should be made after calculations for the specific company.