Extension of criticality approval deadlines
Member of Parliament Yaroslav Zheleznyak expressed concern regarding the consequences of the final version of Cabinet of Ministers Resolution No. 1328. In his assessment, the introduced new procedure could significantly complicate business operations. Specifically, the MP noted that the approval of enterprise criticality, including for drone and ammunition manufacturers, could take up to a month and a half. This significantly exceeds the previous deadline of 10 working days.
Changes to draft exemption rules and lack of criteria
Zheleznyak drew attention to the fact that current draft exemption limits covering more than 50% of employees will remain in force no longer than until 8 December. After this period expires, enterprises will have to provide justification that the loss of specific employees poses a threat to the state's defence capability or economy. The MP emphasised that clear criteria for such justification are not defined in the document.
Risks of corrupt pressure through monitoring
The MP expressed separate reservations regarding the mechanism for monitoring military-liable employees. This function is to be performed by the Coordination Centre with the participation of law enforcement agencies. Zheleznyak believes that such a system could create conditions for corrupt pressure on enterprises. The MP also criticised the dependence of decision-making on the Coordination Centre and the uncertainty regarding business representation in its composition.
Exceptions for officials and quota differences
The text of the resolution provides exceptions for certain officials. Although a draft exemption quota of 95% is established for enterprises in the defence-industrial complex and energy sectors, some officials are allowed to exempt employees from conscription out of turn, without approval through the Coordination Centre. For the head of the body exercising oversight of audit activities, full, i.e. 100%, exemption from conscription is provided for.
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