In April 2026, at the Ukraine and EU Business Forum in Brussels, the Ukrainian robotics manufacturer Tencore and the French firm Shark Robotics announced a joint venture under the Build with Ukraine initiative. Two entities were described: one in France for the development and manufacture of defence robotics, and one in Ukraine set up as an industrial and service hub for maintenance, personnel training and the progressive localisation of components.
APEX AV has no involvement in this project. We are not advising either company, we have no commercial relationship with them, and nothing here draws on private information. Everything below comes from the public announcements. We are writing about it because the structure they described is an unusually clear illustration of a problem we see repeatedly, and because a company reading their own plans in it may recognise something useful.
The reason this particular shape is instructive is simple. A maintenance, training and localisation hub has almost no value in its buildings. Its value is a small number of people who can service a platform, train an operator, and qualify a local supplier. Every human resources decision in a business like that is a business continuity decision, and in Ukraine in 2026 one of them has a deadline attached.
The deadline nobody scheduled around
Reservation from mobilisation is the mechanism that keeps a military-liable specialist at a workbench rather than at a front. It runs through critical-enterprise status, and the rules were rewritten this year.
Cabinet of Ministers Resolution 692 of 30 May 2026 took effect on 2 June and made substantial changes to both the reservation procedure and the criteria for critical-enterprise status. It altered how the reservation quota is calculated, how part-time employees and employees holding other deferments are counted towards it, and how exceeding the reservation limit is controlled. Resolution 862 amended it further over the summer.
Two consequences matter more than the rest.
Existing critical-enterprise decisions run only until 1 September 2026 at the latest. A status granted earlier in the year does not simply continue. It has to be obtained again under the new criteria.
The salary floor for a reserved employee rises to three minimum wages on 1 September 2026, which at the 2026 minimum wage of UAH 8,647 means UAH 25,941 per month. It has to be met in every month of the reporting quarter. An average across the quarter does not save a month that fell below the line.
For a new joint venture this is not a background regulatory detail. A company that incorporates in the autumn, hires a dozen technicians, and then applies for critical status is applying under criteria that changed twelve weeks earlier, with a salary structure that was probably designed against the old floor. The people it most needs to keep are the ones the rules are hardest on.
The classification question, and why the usual answer is about to stop working
The standard shortcut for a new foreign-backed operation in Ukraine is to engage engineers as private entrepreneurs, ФОП, rather than employ them. It is faster, it is cheaper on paper, and it is extremely common.
For a service hub it is also the wrong answer, and the margin for error is narrowing.
Draft Labour Code bill No. 14386 was registered in the Verkhovna Rada on 15 January 2026. It sets out eight indicators of an employment relationship, and where five or more are present, employment is presumed regardless of what the contract says. A technician who works fixed hours, in your workshop, on your equipment, under your supervisor, to your schedule, exclusively for you, for a fixed monthly sum does not score five. He scores nearly all of them.
The Code enters into force six months after martial law ends or is cancelled, so no date is fixed. That is not a reason to defer the decision. A structure built now will still be running when the trigger arrives, and the exposure is calculated on the arrangement as it actually operated.
The current penalty for admitting someone to work without a written contract and the notification filed to the tax authority before they start is ten minimum wages per person, UAH 86,470. A repeat inside two years is thirty, UAH 259,410. Those are per person, not per inspection.
There is a second reason to employ rather than contract in this specific sector, and it has nothing to do with fines. Reservation applies to employees. A ФОП is not an employee of yours, and cannot be reserved by you. Engaging your scarcest engineers as contractors quietly removes the only lawful mechanism you have for keeping them.
Seconded staff from the European side
When French engineers spend time at a Ukrainian hub, the arrangement needs to be one of three things, chosen deliberately and documented:
- employed locally by the Ukrainian entity,
- employed abroad and assigned under a written secondment agreement, or
- genuinely providing independent services.
The choice drives work permit treatment, tax residence, social security coverage, health and safety responsibility, and intellectual property ownership. It also drives permanent establishment risk for the French entity, which is the one that tends to surface late and expensively.
The failure mode is not choosing. Someone flies in repeatedly, stays a few weeks at a time, is paid from France, works under Ukrainian management, and nobody writes down what the relationship is. Two years later a tax authority forms its own view.
The payroll mechanics, briefly
For ordinary Ukrainian employees in 2026:
| Item | Rate |
|---|---|
| Personal income tax | 18%, withheld |
| Military levy | 5%, withheld |
| Unified social contribution | 22%, employer cost, not deducted from pay |
| Minimum monthly social contribution | UAH 1,902.34, being 22% of the UAH 8,647 minimum wage |
An employee therefore receives roughly 77% of gross before any other deduction, and the employer’s direct cost is roughly gross plus 22%.
Two operational points matter more than the rates, because they are where foreign-owned entities actually get caught.
Salary must be paid at least twice a month, with no more than sixteen calendar days between payments. A single monthly pay run, which is what most European group payroll calendars assume, is not compliant. This is not a formality anyone waives because the parent company finds it inconvenient.
Minimum annual leave is 24 calendar days. Group policies written around 20 or 25 working days do not map cleanly, and the difference shows up in accruals and in final settlements.
The data question a French parent cannot assume away
Payroll and HR files in this kind of business will contain passport data, tax numbers, bank details, military registration information, absence and health data, and possibly background screening results. Ukrainian personal data law governs how that is processed, and the Ukrainian entity remains responsible for it.
The specific risk in a joint venture is cross-border access. A group HR platform administered from France, with French managers able to open Ukrainian employee records, is a data transfer whether or not anyone described it that way. It needs a lawful basis, defined access roles, retention rules and controls, decided before the system is switched on rather than after.
The related trap is assuming a European HRIS can simply be extended eastwards. It cannot produce Ukrainian statutory reporting, it will not hold the personnel documents an inspection asks for, and it usually cannot generate the payroll evidence that a critical-enterprise application depends on.
What we would sequence first
If we were setting up an operation of this shape, in this order:
- Decide the employment architecture before anyone is hired. Local employees, secondments, and genuine contractors, named individually rather than as a policy.
- Model the salary structure against UAH 25,941 per person per month, not against the market rate for the role. If reservation matters to the business, the reservation floor is a design input, not an outcome.
- Apply for critical-enterprise status early, under the current criteria, and treat the payroll evidence it requires as a monthly deliverable rather than an annual scramble.
- Put the internal document set in place before the first appointment, including the order on principal activity, which has to exist before there is a director to sign it.
- Write down the cross-border data arrangement before the group system is connected.
- Review payroll, military registration and reservation together, monthly. Separating them is how a company discovers in October that a September salary decision cost it an engineer.
A closing thought
The interesting thing about the Shark Robotics and Tencore structure is that it makes the dependency visible. A hub whose product is maintenance and training cannot lose its technicians and continue. That puts payroll, of all functions, on the critical path of an industrial partnership between two countries.
Most companies discover that relationship the other way round, after the fact. It is considerably cheaper to notice it at the start.
Sources
The joint venture announcement, in the partners’ own words and in independent coverage:
- Shark Robotics, company announcement (English)
- Militarnyi (English)
- Оборонка (Mezha) (українською)
- dev.ua (українською)
APEX AV is a Ukrainian payroll and HR administration company. We have no affiliation with Tencore, Shark Robotics, or the joint venture described here, and this article is commentary on publicly announced information. It is general information rather than legal advice, and the rules described change frequently. Anyone making decisions on these points should take Ukrainian legal advice on their own facts.
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