The NBU continues easing currency restrictions

The National Bank of Ukraine (the “NBU”) introduced currency regulation changes according to its Board’s Resolutions # 2 and # 3 dated 13 January 2026. Below are highlighted the key new developments for business:

Stimulative currency liberalisation:

• The new “loan” limit has been introduced with its amount being equal to the total foreign currency funds received to the company's account with a Ukrainian bank on the new loan/borrowing from a non-resident after 1 January 2026.
• Within the “loan” limit, it is permitted to (i) repay “old” loans/borrowings received before 20 June 2023 and pay interest on them; (ii) make settlements for imported goods delivered before 23 February 2021; (iii) return prepayments to non-resident buyers for goods paid before 23 February 2022; (iv) provide financing to foreign standalone units, and (v) repatriate dividends beyond the established limits.

Easing of currency restrictions:

• Ukrainian sellers and manufacturers can transfer foreign currency to individuals’ accounts with foreign banks to reimburse returned/undelivered goods (providing that the reimbursement is made to the same account from which the payment for goods was made and in the amount not exceeding the cost of goods).
• Currency supervision over export transactions has been clarified:
  • the deadline requirements for settlements are not applied to goods for which the right of claim has been transferred to PJSC Export Credit Agency (ECA) within the limit of insurance indemnity paid;
  • the export of insurance services has been removed from the list of transactions subject to the deadline requirements. From now on, all services, other than the transportation ones, are exempt from the deadline requirements for settlements.