The NBU eased existing currency restrictions and continued to implement its strategy of stimulating currency liberalisation in order to support the Ukrainian economy.
1. Introduction of a “loan” limit. Starting from 1 January 2026, additional conditions have been created for restructuring “old” external borrowings of Ukrainian residents. Thus, the amount of the “loan” limit will be equal to the amount of funds received as a loan from abroad in foreign currency to the company’s account in a Ukrainian bank after 1 January 2026. Businesses may carry out the following transactions for the amount of such a limit received:
- payments for import of goods delivered before 23 February 2021 (inclusive);
- refunds of advance payments received before 23 February 2022;
- dividend payments;
- fulfilment of obligations under loan commitments created before 20 June 2023;
- financing by a resident of the costs for maintaining its branches, representative offices and other separate divisions without creating a legal entity abroad.
It should be noted that all borrowings taken into account for the purposes of the “loan” limit are subject to the general conditions for obtaining loans after 20 June 2023 (at the same time, the international financial organisation should not be a creditor, guarantor or surety for the relevant loan), and after transactions within the specified limit have been carried out, the transfer of funds from Ukraine to repay the principal amount of the loan is limited to the amount of the debt, reduced by the amount of transactions carried out within the limit.
2. Changes in the list of transactions to which settlement deadlines apply. The NBU has included insurance services in the list of services to the export of which the existing settlement deadlines do not apply, harmonising their regulation with other financial services.
Additionally, the settlement deadlines now also do not apply to the goods exported under a foreign economic contract, the right to claim under which has been transferred to EKA on the basis of an insurance contract for the amount of insurance compensation paid by EKA to the exporter of the goods.
3. Benefits for foreign exchange transactions by residents of Defence City. Starting from 31 December 2025, for the purposes of acquiring foreign currency for making cross payments, the funds of Defence City residents placed in their accounts as targeted financing and received on the basis of agreements with foreign export credit agencies, foreign states, international (intergovernmental) organisations and used for the development, manufacture and purchase of goods and the provision of services in the relevant areas are not taken into account.
Separately, for the residents of Defence City, the possibility of obtaining permission in case of the need to make specific cross-border transactions from Ukraine as individual transactions has been introduced.
4. Transactions involving refunds by Ukrainian businesses to consumers for the undelivered goods. The NBU has allowed Ukrainian sellers to refund consumers for the undelivered goods to the account from which payment was made (including foreign accounts) in the currency of payment and in amounts not exceeding the cost of the goods at the time of the purchase.
Our services
KPMG Law Ukraine has a team of qualified specialists with extensive experience in supporting clients on currency control issues and currency restrictions in Ukraine, including the following services:
- advising on all aspects of currency supervision, as well as targeted advice analysing situational specifics
- drafting and preparing necessary documents
- participating in negotiations with servicing banks and counterparties
- structuring operational activity and transactions to take into consideration effective restrictions
- representing clients in disputes with regulatory authorities regarding currency regulation issues.
