The NBU introduces stimulating currency liberalization and eases some currency restrictions

The National Bank of Ukraine (hereinafter “NBU”), by its Resolution of the Board of the National Bank of Ukraine No. 53 dated May 9, 2025, "On Amendments to the Resolution of the Board of the National Bank of Ukraine No. 18 dated February 24, 2022," introduces a number of changes in the currency control regulation. Below are the key changes that will affect business operations:

Stimulating currency liberalization

From May 12, legal entities will have the opportunity to carry out operations that were previously prohibited. In particular, Ukrainian companies will be able to:

• make payments for the import of goods, the supply of which was carried out before February 23, 2021 (inclusive);
• return advance payments for goods to a non-resident buyer that were paid before February 23, 2022;
• fulfil debt obligations under an "old" loans received from non-residents before June 20, 2023.

Ukrainian companies will be able to carry out these operations exclusively within the amount of foreign currency attracted to its charter capital from a non-resident starting from May 12, 2025.

We understand that for some Ukrainian companies, such an additional tool for settling their debt obligations with non-residents may be more attractive than executing an offset of counter homogeneous claims (the so-called "debt-into-equity"), which is currently often used by Ukrainian business to settle their debt obligations with non-residents.

Easing of currency restrictions

The NBU has also introduced a number of relaxations regarding existing currency control restrictions, which may be relevant for a number of Ukrainian companies.

In particular, the NBU has expanded the possibility for legal entities to transfer their own foreign currency abroad to finance their separate divisions abroad (within the basic limit of EUR 1 million per year).

This limit may be exceeded within:

• the amount of funds sent by this legal entity during 2021 to finance its separate divisions;
• the amount attracted to the charter capital from a non-resident starting from May 12, 2025.

Also, starting from May 10, 2025, legal entities can carry out operations to pay court costs and expenses for enforcement proceedings in connection with non-compliance with the terms of import and export contracts without restrictions (before May 10, such operations were allowed only to state-owned companies and private companies in the case of purchasing defense goods).

In addition, the NBU has increased the limits on payments from corporate cards abroad and allowed "forward" currency transactions (including transactions for the sale of foreign currency by bank customers on "forward" terms).

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If you have any questions, please contact our specialists, Vadym Romaniuk, Head of Banking and Finance Law Practice, and Mykhailo Franchuk, Senior Specialist of the Practice.