The National Bank of Ukraine has approved the list of significant financial companies: what this means for the companies in the list and what actions they should take next

On 21 January 2026 the National Bank of Ukraine (hereinafter the “NBU” or “Regulator”) approved for the first time the list of significant financial companies, comprising 53 non‑bank financial institutions (including microfinance, leasing, factoring and state financial institutions). The list was formed based on the criteria set out in the Regulation on the criteria for determining the significance of a financial company, approved by the NBU in late August 2025.

The financial companies acquired the status of significance as of the date on which the NBU published the list.

Why this matters for the market

The introduction of the “significant financial company” status marks another step by the NBU towards a risk‑based supervisory approach and further alignment of the non‑bank financial sector with bank‑level regulatory standards.

Significance is determined not only by the scale of a company’s business (≥1% of total assets), but also by:

• its systemic role within a financial group (as the group’s responsible entity);
• participation in state or municipal programmes;
• the level of risks posed to consumers of financial services;
• a comprehensive assessment of the company’s performance indicators.

The new obligations for significant companies include, in particular:

• eveloping a 3.5‑year business plan;
• enhanced NBU oversight of the sources of funds used to form (or increase) the share capital of significant companies, as well as enhanced scrutiny of the fit and proper status of their new owners and managers;
• additional requirements for corporate governance and internal control;
• regular self‑assessment of risks and corresponding adjustments to business planning.
  

Deadlines

A financial company is required, from the date on which the NBU publishes the information on its designation as a significant financial company and no later than 1 July of the same year, to bring its business in compliance with the requirements for significant companies set forth in:

• the Regulation on the requirements for the corporate governance system and the internal control system of a financial company, and
• the Regulation on the authorisation of financial service providers and the conditions for carrying out financial service activities.

Please note! A significant financial company must develop and submit its business plan to the NBU by 1 June.

Given the scope of the new requirements, the time available for both formal and practical implementation is limited. We therefore recommend not postponing compliance preparations until the last moment.

From the experience: for many companies, this will require far more than “cosmetic” adjustments – it will mean revision of the business model, strengthening the riskmanagement framework, additional compliance procedures and engagement with the NBU.

If your company is already on the list, or you expect to fall within scope based on the criteria defined by the NBU, now is the right time to:

✔️ conduct gap-analysis;
✔️ update or develop a business plan in line with NBU requirements;
✔️ allocate the necessary resources and time to bring your operations into compliance to the additional NBU requirements;  

Нow can PwC Legal Ukraine help?

PwC Legal Ukraine has extensive experience supporting clients through authorisation, licensing and supervisory processes with the National Bank of Ukraine – including the preparation of business plans for financial and payment institutions in line with NBU requirements, as well as conducting regulatory gap analyses.

We would be happy to discuss your specific situation in more detail.