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      On 27 August 2025, the NBU approved criteria for determining the significance of financial companies. The introduced changes stipulated the grounds for identifying those companies involved in financial sector activities which would be considered the most significant for the market and consumers in terms of the criteria of scale, role, or risks.

      A financial company being designated as “significant” does not require the company itself to take any additional steps to obtain such status, as the NBU independently determines such significance for a period of one year based on an annual assessment of compliance with the established criteria.

      A company is considered significant if it meets at least one of the following criteria:

      • the value of the financial company’s performance indicator is at least five, calculated based on the sum of specified indicators according to the NBU “Regulations on the criteria for determining the significance of a financial company”
      • the share of assets and off-balance liabilities is at least 1% of the total volume of assets and off-balance liabilities for all financial companies as of the assessment date (excluding companies in which 50% or more of the company’s shares/interests are owned by the state)
      • the financial company is the responsible entity for a financial group recognised by the NBU as being among the “medium-sized” and “large” groups of companies for which regulation and supervision are carried out by the NBU
      • the financial company has a consumer rights violation risk level of “high” or “very high” (as determined by the NBU)
      • the financial company provides financial services to a defined group of beneficiaries within the framework of state or local self-government programmes which stipulate the specific conditions for providing financial services.

      Having the status of a significant financial company is a signal for the application of enhanced regulatory requirements and more intensive supervision. As a general rule, a “significant” company is required to bring its activities into compliance with the specified requirements by 1 July of the year in which the NBU discloses information on recognising such financial company as significant. This process involves:

      • developing and submitting a 3.5‑year development plan to the NBU (with such a plan developed by 1 June of the relevant year) and conducting an annual assessment of the implementation of this plan, with updates for the next 3.5 years
      • enhancing corporate governance and internal risk control systems by establishing clear rules on how to conduct an overall risk assessment, perform self-assessment of risk, and report on risks
      • conducting its own self-assessment of risk
      • verifying persons who have actually acquired or increased a qualifying holding in said significant company, etc.

      A significant financial company must notify the NBU of bringing its activities into compliance with the established requirements no later than 15 July of the relevant year.

      Furthermore, financial companies recognised as significant by the NBU should also understand that failure to comply with the established requirements will be regarded as a violation of the law, giving the NBU grounds to apply measures of influence as provided for by the relevant legislation

      Our services

      KPMG Law Ukraine has a team of highly qualified specialists and extensive experience in advising and supporting clients in the financial sector, including in matters regarding regulatory compliance. This includes the following services:

      • legal diagnostics regarding company compliance with the criteria for significant financial companies
      • advising on all regulatory matters related to the activities of financial companies, including significant companies
      • design and/or enhancement of company risk management systems in accordance with NBU requirements
      • preparation and/or review of internal documents (policies, procedures, regulations) necessary to bring activities into compliance with the requirements applicable to significant financial companies, or for the potential acquisition of the status of a significant financial company
      • legal and organisational support in interactions with the NBU.
      Bogdan Shyshkovskyi

      Director, Legal Services, Tax & Legal

      KPMG in Ukraine

      Vladyslav Fisun

      Manager, Banking and Financial Law, Corporate Law and M&A, Legal Advisory, Tax & Legal

      KPMG in Ukraine

      Our professionals work with subject matter experts to deliver tailored and insightful legal advice to each of our clients.