NBU Releases Draft Regulation on Open Banking – CMS Ukraine Comments

News from our member CMS Ukraine

On 1 May 2025, the National Bank of Ukraine (NBU) released a long-anticipated draft Regulation on Open Banking for public consultation. Set to take effect on 1 August 2025, the new Regulation represents a significant step forward in modernising Ukraine’s financial services sector and aligning with global digital banking standards.

A New Chapter in Ukraine’s Financial Innovation

The concept of open banking was first introduced in Ukraine in 2023 under the revised Law of Ukraine “On Payment Services”. The newly published draft Regulation now proposes a full-fledged legal and technical framework to support secure data sharing between banks and authorised third-party providers (TPPs), with user consent at its core.

This marks a transformational moment for Ukraine’s digital financial ecosystem, enabling TPPs to access account data and initiate payments via standardised digital interfaces, known as specialised interfaces.

Key Provisions

According to CMS Ukraine, the draft Regulation clearly defines the roles and responsibilities of the main participants in the open banking ecosystem:

• Account Servicing Payment Service Providers (ASPSPs): Including banks and non-bank PSPs;
• Third-party PSPs offering non-financial payment services;
• Payment Service Technology Operators;
• End users of payment services.

The draft Regulation sets out:

• Access rules for TPPs and the requirements for obtaining and managing user consent;
• Two interface types: basic (mandatory and free) and commercial (fee-based);
• Real-time access obligations for ASPSPs;
• Security standards, including robust authentication and the use of qualified electronic trust services.

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Compliance Requirements

The Regulation imposes extensive compliance obligations on both ASPSPs and TPPs, including:

• Ensuring secure and uninterrupted access via the specialised interfaces;
• Monitoring for unauthorised or fraudulent activities;
• Retaining user interaction and transaction data for a minimum of five years;
• Reporting to the NBU;
• Implementing internal protocols for incident response and compensation.

What’s Next

As highlighted by CMS Ukraine, the introduction of open banking is expected to significantly enhance innovation, competitiveness, and consumer rights in the Ukrainian financial sector.

Stakeholders are invited to submit their comments and suggestions to the NBU as it finalises the Regulation before its planned implementation in August.

For more information, please contact CMS Ukraine:

Ihor Olekhov
Partner, Kyiv
📞 +380 44 391 3377
📧 ihor.olekhov@cms-cmno.com

Bohdan Ilchenko
Senior Associate, Kyiv
📞 +380 44 391 3377
📧 bohdan.ilchenko@cms-cmno.com

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