On 9 May 2025, the National Bank of Ukraine (NBU) introduced several critical changes to the martial law-related currency control restrictions that amend NBU Board Resolution No. 18 dated 24 February 2022 “On the Operation of the Banking System under Martial Law”. The changes became effective on 10 May 2025.
Incentives for investments
According to the NBU, the goal of the changes is to shift to a policy of “stimulative currency liberalisation” aimed at supporting Ukraine’s economy while simultaneously preventing “unproductive” capital outflow.
The changes allow Ukrainian companies to carry out certain FX transactions beyond the existing limits, within a special investment limit equal to the amount of foreign investment in their share capital from 12 May 2025 onwards. The permitted transactions include:
- settlements for import of goods and services made before 23 February 2021;
- refunding of prepayments made by non-residents before 23 February 2022;
- repayment of principal and interest under legacy cross-border loans provided before 20 June 2023;
- financing of foreign branches and representative offices (above the standard limit).
Ukrainian companies may transfer up to EUR 1 million annually in foreign currency to their foreign branches and representative offices, provided that the company has been operating for at least 12 months. Transfers beyond this limit may be made if the companies do not exceed the actual amount transferred in 2021.
Legal entities may purchase and transfer foreign currency to cover registration, arbitration, court fees and enforcement expenses arising from disputes with non-resident counterparties under import/export contracts.
The NBU raised the limits for cross-border corporate card transactions:
- cash withdrawal: from UAH 12,500 to UAH 17,500 (or the equivalent of these amounts);
- payments for goods/services: from UAH 100,000 to UAH 150,000 (equivalent).
The NBU authorised certain FX forward operations, including:
- interbank forward FX transactions (with or without delivery);
- FX sale by clients to banks under forward terms.
The NBU allowed consular fee payments directly from Ukrainian bank accounts and military personnel to open all types of bank accounts under simplified procedures.
Enhanced scrutiny
At the same time, the NBU imposed restrictions to close existing loopholes and prevent the outflows of capital.
The banks may not close FX monitoring of import transactions where refunds are made by a foreign supplier in UAH via loro (correspondent) accounts of non-resident banks.
The NBU extended the UAH 500,000 monthly cap for card-based FX transactions abroad to a broader range of services with the following merchant category codes:
- 7299 – Various Personal Services (not defined in other categories);
- 7311 – Advertising Services;
- 7392 – Management, Consulting and Public Relations;
- 7399 – Business Services (not defined in other categories);
- 8111 – Legal Services and Attorneys;
- 8931 – Accounting and Auditing services;
- 8999 – Professional Services (not defined in other categories);
- 9399 – Public Services (not defined in other categories). This category captures services such as consulting, legal, accounting, advertising, and others not previously restricted, closing loopholes used to bypass capital controls.
The NBU states that these changes are expected to stimulate investment, support business operations, and strengthen the FX market, ensuring macroeconomic stability while enabling gradual liberalisation. According to analysts, the NBU’s shift to a more tailored and nuanced approach to currency control restrictions is likely to have a positive effect.
