Changes to currency restrictions

Considering business feedback and the overall impact of currency restrictions on the economy, the National Bank of Ukraine (NBU) has introduced new easing measures. These include an extended period for dividend repatriation, expanded list of transactions allowed within the investment limit and additional incentives for businesses that provide financial support to the Armed Forces of Ukraine.

NBU Resolution No. 18 dated 24 February 2022 has been amended accordingly by NBU Resolution No. 95 dated 5 August 2025.

Most provisions of NBU Resolution No. 95 came into effect on 6 August. The key changes include:

• Extended dividend repatriation period: dividends may now be transferred abroad if accrued from 1 January 2023 (previously: from 1 January 2024), while the monthly limit of EUR 1 million remains in place.
• Shortening of external loan terms: permitted where a resident borrower’s debt is offset against a non-resident’s obligation to increase a resident’s authorized capital (debt-to-equity conversion). Loan terms may be shortened in the NBU’s electronic system AIS “Loan agreements with non-residents” upon providing documents confirming the state registration of the capital increase.
• Loan repayment to highly rated foreign banks: residents may now repay loans obtained from non-resident foreign banks rated at least “A” (Standard & Poor or Fitch Ratings) or “A2” (Moody’s Investors Service), provided that a part of the loan is extended by an IFO.
• Transfers to non-resident guarantors/sureties/insurers: allowed to satisfy the recourse claims of non-resident guarantors, sureties (pledgors), insurers if they have discharged a resident’s obligations under the abovementioned agreements. Transfers may only be made from the resident’s own funds in foreign currency.
• Return of erroneously transferred funds: permitted for foreign currency funds credited to client accounts from 7 August 2025. The funds will be returned within three business days after the bank receives the relevant notice from the non-resident bank.
• Forward purchases of foreign currency: residents (both legal entities and individual entrepreneurs) may now buy foreign currency from banks on forward terms with underlying asset delivery to hedge the FX-risk of merchandise imports. However, banks may perform such transactions only within the amount of foreign currency they have purchased on forward terms from other clients (both with and without the delivery of the underlying asset).
• Purchase of bank metals in the jewelry sector – jewelry business may buy bank metals for cashless hryvnias to further transfer these metals to jewelry manufacturers, subject to a number of conditions.

In addition, the NBU has provided for changes in the stimulating currency liberalization launched in May 2025 and introducing the investment limit equal to the amount of foreign currency funds contributed to a company’s authorized capital by foreign investors from abroad from 12 May 2025. To recap, Ukrainian companies may – within the investment limit – carry out certain currency transactions above established limits, including:

• 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;
• Financing their own foreign representative offices/branches in excess of the limit separately established for such financing.

Among the new changes, in the first place, the list of permitted currency transactions beyond existing restrictions but within the investment limit has been expanded to include repatriation of dividends.

Secondly, resident legal entities have been allowed to make the abovementioned cross-border transfers (including repatriation of dividends) in excess of the established caps, yet within the amount transferred by them to the NBU’s special account for raising funds (in national or foreign currency) to support the Armed Forces of Ukraine, from 7 August 2025. Thus, the NBU stimulates business that contributes to strengthening the country’s defense capability.

We believe that these measures aim to stimulate foreign investment, increase the currency flexibility of Ukrainian business, and strengthen the country’s defense capability through economic incentives.

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

We invite you to read our brochure on currency regulation in Ukraine.

_{Comments provided by Deloitte experts herein are for information purpose only and should not be used by taxpayers without an in-depth expert analysis on a case-by-case basis.}

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