Ukraine introduces nuanced regulation of FX rules

On 9 May 2025, the National Bank of Ukraine (NBU) announced a significant easing of wartime currency control restrictions, introducing a more flexible and investment-oriented regulatory approach. The changes, formalised through amendments to NBU Board Resolution No. 18 (dated 24 February 2022), came into force on 10 May 2025.

The newly adopted measures mark a shift toward what the NBU terms "stimulative currency liberalisation." The aim is to support Ukraine’s economic resilience and recovery while safeguarding the country’s financial stability by curbing unproductive capital outflows.

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Key Changes Supporting Investment

From 12 May 2025, Ukrainian companies will be able to carry out specific foreign exchange (FX) transactions beyond standard limits, based on the amount of foreign investment in their share capital. These transactions include:

• Settlements for goods and services imported prior to 23 February 2021;
• Refunds of prepayments made by non-residents before 23 February 2022;
• Repayment of principal and interest on legacy cross-border loans issued before 20 June 2023;
• Financing of foreign branches and representative offices, beyond existing limits.

Companies that have been in operation for at least 12 months may transfer up to EUR 1 million annually to their foreign branches and representative offices. Transfers beyond this cap are allowed if they do not exceed actual 2021 levels.

Legal entities may also purchase and transfer foreign currency to pay registration, arbitration, court, and enforcement-related costs in disputes with foreign counterparts.

Increased Transaction Limits

The NBU raised cross-border corporate card transaction limits:

• Cash withdrawals: increased from UAH 12,500 to UAH 17,500 (or the equivalent in other currencies);
• Goods and services payments: increased from UAH 100,000 to UAH 150,000 (equivalent).

The central bank also approved new FX forward operations, allowing:

• Interbank forward FX transactions (with or without delivery);
• Client-initiated FX sales to banks under forward terms.

Further, consular fee payments can now be made directly from Ukrainian bank accounts, and military personnel are allowed to open all types of bank accounts via a simplified procedure.

Measures to Prevent Capital Flight

Alongside liberalisation, the NBU reinforced oversight to close loopholes that enabled capital outflow. Notably, FX monitoring may no longer be closed if a refund for an import transaction is made by a foreign supplier in UAH via a non-resident bank’s loro account.

Additionally, the NBU extended the monthly cap of UAH 500,000 for FX card transactions abroad to a wider range of service categories, including:

• Advertising, legal, accounting, consulting, auditing, and other professional services.

These adjustments aim to close previous gaps in capital control enforcement.

Outlook

The NBU expects the new framework to stimulate investment, enhance the FX market, and support overall macroeconomic stability. Analysts view this more tailored approach to currency regulation as a positive step in balancing economic needs with financial safeguards.

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For further information on these developments, members are encouraged to contact CMS Ukraine:

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

Kateryna Chechulina – Counsel, Kyiv
📞 +380 44 391 3377
📧 kateryna.chechulina@cms-cmno.com

Yaroslav Pavliuk – Associate, Kyiv
📞 +380 44 391 3377
📧 yaroslav.pavliuk@cms-cmno.com

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