Starting 10 May 2025, the National Bank of Ukraine will implement a stimulating FX liberalization policy. The NBU’s goal is to facilitate the inflow of additional capital into Ukraine’s economy through incentives embedded in the policy of easing FX restrictions.
In addition, other changes to the existing FX restrictions will come into effect on 10 May. Some of these restrictions will be eased to support Ukrainian businesses. At the same time, a number of restrictions will be tightened to prevent unproductive capital outflows abroad.
FX liberalization with a stimulating effect
Ukrainian enterprises will be allowed to conduct some FX transactions exceeding the currently restricted amounts within the established investment limit. This limit will equal the amount of FX funds attracted from 12 May 2025 into the authorized capital of these enterprises from foreign investors abroad. These transactions include:
- making payments for the import of goods that were delivered on and before 23 February 2021
- refunding to a non-resident buyer advance payments for goods that were prepaid before 23 February 2022
- fulfilling debt obligations under "old" external loans received before 20 June 2023
- funding their own foreign standalone units (above the established separate limit for funding such representative offices).
Such transactions shall be conducted through one bank (chosen by the enterprise). There is also a possibility to change the servicing bank.
As of 1 April 2025, the total debt on the principal amount of external unsecured loans of Ukrainian businesses stands at nearly USD 14 billion, while the amount of interest arrears exceeds USD 7 billion. Debt principal has increased by almost USD 2 billion since the full-scale invasion. The interest arrears have also risen by about USD 2 billion. Existing currency regulations allow only partial fulfillment of obligations under "old" external loans received before 20 June 2023. It is allowed to make interest payments, but not before the deadlines specified in the loan agreement, and provided that there was no overdue debt under the loan agreement as of 24 February 2022.
In addition, according to a survey of servicing banks conducted by the NBU last year, Ukrainian companies reported the need to pay USD 3.2 billion for the import of goods delivered before 23 February 2021. Such transactions are currently prohibited by currency regulations.
Under current conditions, the NBU cannot authorize the payment of these obligations in full, as it would have significant implications for the sustainability of the FX market and international reserves. At the same time, companies will be allowed to make such payments if they attract new foreign capital to Ukraine (within the amount of funds raised), as such transactions will have no negative impact the FX market.
Liberalization measures in a number of other areas
First, the NBU has eased restrictions on financing foreign representative offices of Ukrainian companies.
The NBU has expanded the ability of resident legal persons to transfer funds into the accounts of their subsidiaries abroad using their own foreign currency. The annual limit for such transactions has been set at an equivalent of EUR 1 million. The period of operation of such companies from the date of state registration to the date of the transaction shall be at least 12 months.
The NBU has also retained the possibility for Ukrainian companies to make additional transfers (above said limit) within the total amount of funds actually transferred by these companies in 2021 to maintain the operation of their foreign branches.
The easing of the relevant restriction will not affect Ukraine’s FX market, as such transfers will only be allowed at the expense of the company’s own foreign currency. At the same time, Ukrainian enterprises will be able to enhance their efforts to promote their products in foreign markets. In the long term, the introduced changes will contribute to the growth in the country’s export potential by expanding cooperation between Ukrainian businesses and foreign partners and increasing trade turnover.
Second, the NBU has authorized payments related to court procedures regarding the non-fulfillment of conditions by non-residents under import and export contracts.
The approved decisions allow legal persons of all forms of ownership to purchase foreign currency and transfer it abroad to pay for registration, arbitration, court fees, and cover other expenses during enforcement proceedings related to non-fulfillment of conditions by non-residents under import and export contracts.
According to the findings of the customer survey conducted by banks this year, the impact on the FX market will not be significant. On the other hand, businesses will have the opportunity to protect their property and other rights and interests in foreign jurisdictions in a timely and appropriate manner when resolving issues related to the return of FX earnings under export contracts or prepayments under import contracts.
Third, the NBU has increased the limits for corporate card transactions abroad.
In line with the stages set out in the Roadmap for Easing FX Restrictions, the NBU has increased the limits for transactions conducted by legal persons using corporate electronic means of payment (corporate cards) abroad, specifically:
- from (the equivalent of) UAH 12,500 to UAH 17,500 for cash withdrawals from the customer’s account in the domestic currency
- from (the equivalent of) UAH 100,000 to UAH 150,000 for transactions to pay for goods, works, and services.
The increase in limits will not significantly affect Ukraine’s FX market, as stronger demand for foreign currency under corporate card transactions will likely be offset by decreased demand for transactions through other, less convenient channels.
Fourth, the NBU has authorized FX transactions on forward terms.
The NBU has started implementing measures from the Concept Note on Defining Approaches, Conditions, and Timelines for Restoring the Functionality of the Foreign Exchange Derivatives Market prepared as part of the fulfillment of obligations under the IMF program. Specifically, the NBU will authorize the following transactions on forward terms:
- purchases and sales of foreign currency for hryvnias (with or without FX delivery) between banks
- sales of foreign currency by customers to banks for hryvnias (with FX delivery).
The impact of such forward FX transactions between banks on the overall situation in the FX market is expected to be minimal, while customer transactions to sell foreign currency on forward terms will only bring the FX supply closer in time.
Fifth, the NBU has authorized payments of consular fees into accounts of Ukrainian diplomatic missions and consulates abroad.
As part of the changes introduced for the launch of the e-Consul portal, the NBU has regulated the possibility for Ukrainians to pay consular fees from accounts opened with Ukrainian banks and into accounts of Ukraine’s diplomatic missions and consulates abroad.
Additionally, specific provisions have been clarified to simplify access to banking services for military personnel.
The NBU has adopted a simplified procedure for opening any type of account for military personnel, not just current accounts for receiving salaries. Furthermore, the NBU has expanded the options for non-resident military personnel who serve in the Armed Forces of Ukraine or the National Guard of Ukraine to access banking services.
Some provisions to tighten FX restrictions will help prevent unproductive capital outflows from Ukraine
The first area is currency supervision over settlement deadlines for some import transactions.
To prevent the outflow of foreign currency from Ukraine, the NBU is introducing clarifying amendments to the procedure for completing currency supervision. Specifically, the NBU has prohibited banks from completing currency supervision over import transactions when funds are returned by a non-resident to an importer in hryvnias from the correspondent accounts of non-resident banks.
The second area is individuals’ FX transfers abroad.
The NBU has expanded the range of transactions that are subject to the monthly limit of UAH 500,000 for settlements abroad using payment cards issued by Ukrainian banks for FX accounts, by applying the limit to transactions under the following merchant codes:
- 7299 Miscellaneous Personal Services (not defined elsewhere)
- 7311 Advertising Services
- 7392 Consulting, Management and Public Relations Services
- 7399 Business Services (not defined elsewhere)
- 8111 Attorneys, Legal Services
- 8931 Accounting, Auditing, and Bookkeeping Services
- 8999 Professional Services (not defined elsewhere)
- 9399 Miscellaneous Services (not defined elsewhere).
As revealed by an analysis conducted after introducing, on 10 September 2024, a similar limit on transactions with real estate agents and managers abroad, settlements under real estate transactions started to be conducted using various other merchant codes. The updated restriction takes into account the findings of this analysis. The established limit will help prevent attempts to circumvent restrictions on the relevant transactions and avoid significant capital outflows from Ukraine.
These and other changes were introduced by NBU Board Resolution No. 53 On Amendments to NBU Board Resolution No. 18 dated 24 February 2022 dated 9 May 2022 and will come into force on 10 May 2025.