The National Bank of Ukraine Revised the Issuance and Circulation of Electronic Money


From 1 October 2022, the National Bank of Ukraine updated the procedure for issuing and payment operations with electronic money, in particular, opening and servicing electronic wallets [1].

Electronic money is records on the electronic means of payment: (i) payment cards, which contain data in electronic form about the account; or (ii) applications to which an electronic wallet is linked and which are accepted as a means of payment for goods and services. 

On the other hand, electronic money should not be completely equated with digital money, since the latter is an electronic form of the hryvnia, which in its essence is very similar to the already existing cashless form of the hryvnia on bank cards and accounts, but such hryvnias are issued exclusively by the NBU. Such money may be known to the public under the name "e-hryvnia". 

The NBU adopted a new procedure within the framework of the implementation of the recently restated  Law of Ukraine "On Payment Services", which entered into force in August of this year and approved, among other things, the basic provisions on electronic money. The main difference between the new law and the previous one is the possibility of issuing electronic money not only by banks, but also by non-bank providers of payment services: electronic money institutions, payment fintechs, postal operators and state authorities [2].   Also, the new law regulated the right of users in Ukraine to use electronic money denominated in foreign currency, issued offshore. 

The procedure of the NBU has now established uniform requirements for: 

  • issuance of electronic money;
  • servicing electronic wallets and execution of payment transactions with electronic money by providers of payment services;
  • accounting of funds received by an issuer for issuing electronic money from consumers or users;
  • commercial agents (in addition to the existing regulation [3] );
  • agreement between an issuer and a consumer (user).

For the time being operations on the issuance and distribution of electronic money, replenishment of electronic wallets with electronic money are suspended [4] , in accordance with the restriction established by the NBU on 24 February 2022.


[1] Resolution of the Board of the NBU No. 210 of 29 September 2022 "On approval of the Regulation on issuing electronic money and carrying out payment transactions with it"

[2] Part 1 of Article 57 of the Law of Ukraine "On Payment Services"

[3] See. also Resolution of the Board of the NBU No. 168 of 2 August 2022 "On Approval of the Regulation on Engaging Commercial Agents for the Provision of Financial Payment Services"

[4] Resolution of the Board of the National Bank of Ukraine No. 18 of 24 February 2022 "On the Banking System Operation during Martial Law" (as amended)