Changes in Foreign Exchange Regulation: The NBU Introduces Incentivizing Currency Liberalization
As of 10 May 2025, the National Bank of Ukraine (the "NBU") introduced a number of changes to foreign exchange regulation framework. According to the NBU, the changes are aimed at facilitating the inflow of additional capital into the Ukrainian economy and are part of the so-called incentivizing currency liberalisation. Along with the currency easing, the NBU also introduced a number of additional restrictions.
Introduction of the investment limit concept
The NBU has granted permission to resident legal entities to conduct certain foreign exchange transactions in favour of non-residents within the so-called investment limit, i.e. to the extent of funds invested in the resident's charter capital by foreign investors in Ukraine from abroad (starting from 12 May 2025).
Within the scope of the investment limit, resident legal entities are now allowed to:
- repay debts under foreign economic agreements for the import of goods, works, and services where such imports occurred before 23 February 2021 (inclusive);
- return advance payments under a foreign economic agreement to non-residents received before 23 February 2021 (inclusive);
- fulfil obligations under a loan received (in full or in part) by such resident from a non-resident under a loan agreement before 20 June 2023 (inclusive);
- finance the costs of maintaining branches, representative offices and other separate subdivisions of such resident without establishing a legal entity abroad.
A condition for making these transfers is that the servicing bank must receive a confirmation of the actual investment and registration of the formation (increase) of the resident's charter capital as of the date of the relevant transaction.
Permission to purchase foreign currency to replenish DSRA accounts
The NBU has allowed resident entities to purchase foreign currency for the purpose of fulfilling financing agreement obligations to maintain a minimum balance on the bank accounts (the so-called debt service reserve accounts or DSRA). For the time being, such transactions are permitted only for a limited list of qualifying loans and credit facilities*. The amount of funds placed on such DSRA accounts will not be taken into account when calculating the limit for purchasing foreign currency for a bank client, as required by paragraph 1214 of Resolution No. 18.
Narrowing the grounds for completion of foreign exchange supervision over import transactions
The NBU has prohibited banks from concluding foreign exchange supervision over import transactions where a non-resident returns funds to the importer in hryvnia (UAH) from non-resident banks' loro accounts. Now, the completion of FX supervision in cases of full or partial return of prepaid funds is permitted only if those funds are returned (transferred) from abroad to Ukraine in foreign currency.
According to the NBU, this change is aimed at preventing the withdrawal of foreign currency from Ukraine and eliminating market practices used to circumvent FX restrictions.
Expanded possibilities for financing foreign subdivisions
The NBU has set a new annual limit of EUR 1,000,000 (or equivalent in another foreign currency) for financing foreign branches and representative offices of resident legal entities. Beyond this threshold, financing may still be carried out in accordance with the amounts transferred by the resident for the maintenance of such units in 2021.
A new mandatory condition is that the resident entity must have been operating for at least 12 months at the time of the transaction.
Expanding opportunities for residents to pay registration, court and arbitration fees
Previously, payment of registration, court, and arbitration fees in foreign currency was allowed only for certain residents - such as state-owned enterprises, business companies with 100% state-owned shares and legal entities under state defence contracts. Pursuant to the amendments, the NBU lifted the restrictions and allowed all resident legal entities to make such payments.
Additionally, residents are now allowed to pay consular fees to accounts of Ukrainian diplomatic and consular missions abroad.
Increased limit for cash withdrawals and payments abroad using corporate cards
The NBU has set an increased limit for cash withdrawals abroad from corporate cards in the amount of UAH 17,500 for every seven calendar days. The limit for withdrawals from personal cards remained unchanged at UAH 12,500 for every seven calendar days.
The limit for payments abroad using corporate cards has been increased to UAH 150,000 equivalent per calendar month from all accounts of such a bank client opened in the national currency. At the same time, this limit will not apply to certain categories of persons, as before (international cargo transportation, international sports competitions and some others). The limit for personal cards remained unchanged (UAH 100,000 in the equivalent per calendar month).
Foreign currency transactions by individuals
The limit within which individuals are allowed to make settlements in foreign currency (i.e. UAH 500,000 per calendar month) has been extended to new merchant category codes (MCC codes), in addition to code 6513 (real estate agents):
- 7299, 7311, 7392, 7399 (Advertising, consulting, management, PR services, and other business/personal services)
- 8111 (Legal services)
- 8931 (Accounting, audit, and tax services)
- 8999, 9399 (Other professional and governmental services)
This monthly limit will apply cumulatively across all the listed MCC codes.
Expanding opportunities for banks to carry out foreign exchange forward transactions
Banks are allowed to carry out forward transactions with other banks for the purchase and sale of foreign currency (with or without delivery of foreign currency), as well as with clients for the sale of foreign currency by clients (with delivery of foreign currency).
Additional easing of banking servicing for military personnel
According to the amendments, in order to open a deposit account, a military person will only need to conclude a relevant agreement and will not be required to submit an application.
The NBU has also permitted withdrawal transactions from accounts of individuals - residents of the Russian Federation/Republic of Belarus who are performing military service in the Armed Forces of Ukraine or the National Guard of Ukraine (or have performed such service and were discharged during martial law).
These changes were introduced by the NBU Resolution No. 53 dated May 9, 2025, “On Amendments to the Resolution of the Board of the National Bank of Ukraine No. 18 dated February 24, 2022.”
The review was prepared by INTEGRITES Banking and Finance team
* Qualified loans and credit facilities mean loans and credit facilities (in whole or in part) provided with the participation (by way of guarantee, surety) of an IFI or with the participation (by way of lending, insurance, guarantee, surety) of a foreign export credit agency/foreign state through its authorised person/foreign entity whose participants (shareholders) include a foreign state or a foreign bank [provided that a foreign state is a participant (shareholder) of this bank.
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