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Changes in currency restrictions

Tax & Legal Alert

The National Bank of Ukraine (NBU), based on the results of a survey conducted among servicing banks and in line with its Currency Restrictions Easing Strategy, has amended NBU Board Resolution No. 18 dated 24 February 2022.    

In addition to further easing measures, the NBU has tightened a number of restrictions and announced the launch of stimulating currency liberalization.   

These changes were approved by NBU Board Resolution No. 53 dated 09 May 2025 and came into effect on 10 May.

The purpose of stimulating currency liberalization is to attract additional capital into the Ukrainian economy by encouraging inflows of funds through the introduction of an investment limit. Within this limit, Ukrainian companies are allowed to carry out certain foreign currency transactions that were previously restricted. The investment limit corresponds to the amount of foreign currency contributed to a company’s authorized capital by foreign investors from abroad starting from 12 May 2025. Within this limit, companies may perform transactions primarily related to the fulfillment of “old” obligations. The list of such transactions includes:

  • Payments for imports of goods delivered before 23 February 2021 (inclusive)
  • Refunds to non-resident buyers of advance payments for goods made before 23 February 2022  
  • Fulfillment of debt obligations under the “old” external loans received before 20 June 2023  

Additionally, the investment limit also applies to the financing of foreign representative offices/branches of Ukrainian companies that exceeds a separately established limit for such purposes.

A mandatory requirement is that these transactions must be executed through a single servicing bank, which the company selects independently and can change if needed.

Key changes to currency restrictions under Resolution No. 53 include:

  • Foreign currency transfers by Ukrainian companies to fund their foreign branches/representative offices are now allowed within an annual limit of EUR 1 million. The funding must come from own funds of a company registered at least 12 months prior to the transaction. Furthermore, companies may transfer additional funds exceeding EUR 1 million per year within the total sum they transferred in 2021 for similar purposes. Up to one-quarter of the total annual amount can be transferred in a single month.
  • Legal entities of all ownership types are now allowed to make payments related to the preparation, filing, and consideration of claims in international commercial and investment arbitrations, as well as in foreign courts.
  • The NBU increased limits for corporate card payments abroad: up to UAH 17,500 for cash withdrawals from a client’s account in the national currency, and up to UAH 150,000 for payments for goods, works and services.
  • Foreign exchange transactions on a forward basis are now permitted. This easing applies to interbank currency purchases/sales for UAH (with or without delivery of foreign currency) and sales of foreign currency by clients to banks for UAH (with delivery of foreign currency).
  • The NBU has allowed the payment of consular fees to accounts of Ukrainian diplomatic missions and consular offices abroad.
  • In addition to the innovations that will promote investment in Ukraine, the regulator has also introduced a number of changes to prevent non-productive capital outflows:
    • Restrictions on payments abroad using payment cards issued by Ukrainian banks for accounts in foreign currency have been tightened. From now on, the monthly limit of UAH 500,000 previously applied to transactions under merchant category code 6513 (real estate agents and managers), is extended to codes 7299 (miscellaneous personal services (not elsewhere classified)), 7311 (advertising services), 7392 (management, consulting, and public relations services), 7399 (business services (not elsewhere classified)), 8111 (legal services and attorneys), 8931 (accounting and auditing services), 8999 (professional services (not elsewhere classified)), 9399 (public services (not elsewhere classified)).
    • Banks are prohibited from terminating currency supervision of an import transaction if a non-resident returns to an importer funds in UAH from loro account with non-resident banks.

We believe that the easing measures and stimulating currency liberalization will help support Ukrainian businesses and attract foreign capital.

We will continue to monitor changes in currency legislation during martial law and will share useful information with you.

The Deloitte overview indicated above is solely informative by nature and should not be treated as an official advice without a separate engagement of our professionals.

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