NBU expanded opportunities for non-bank payment service providers

From 17 September 2026, the National Bank of Ukraine (NBU) enabled non-bank payment service providers, including payment institutions and financial institutions authorised to provide payment services (NBPSPs) to carry out a number of foreign exchange transactions through UAH-denominated payment accounts, in particular making payments abroad within the applicable limit and crediting international transfers made through SWIFT and international card payment systems.

• Payments for goods, works and services abroad using a card linked to a payment account held with an NBPSP are permitted up to an aggregate monthly limit equivalent to UAH 200,000 across all of the user’s hryvnia-denominated payment accounts held with NBPSPs.

• Funds received under international transfers initiated abroad in a foreign currency, including through SWIFT or payment systems, may be credited to a hryvnia-denominated account following conversion.

• payments from non-resident individuals for goods and services supplied in Ukraine, including card and transfer-based payment scenarios, may be credited to business accounts.

The purpose of the changes is to support the further development of the payment services market by expanding the range of services offered by NBPSPs in Ukraine and the functionality of their users’ payment accounts, as well as creating a level playing field for NBPSPs and banks. 

The changes are provided for by:

• Resolution No. 104 dated 15 September 2026 ‘On Approval of Amendments to the Regulation on the Procedure for Issuing Licences to Conduct Foreign Exchange Transactions’;

• Resolution No. 105 dated 15 September 2026 ‘On Amendments to Resolution No. 18 of the Board of the National Bank of Ukraine dated 24 February 2022’;

• Resolution No. 106 dated 15 September 2026 ‘On Amendments to the Regulation on Transactions involving Currency Valuables’. 

The above resolutions came into force on 17 September 2026.

For NBPSPs, the amendments create new opportunities to broaden their service offering and better serve customers who require cross-border payment functionality. To carry out the relevant foreign exchange transactions, an NBPSP must obtain an NBU licence to conduct such transactions (or expand the scope of foreign exchange transactions covered by its existing licence) and review its internal processes. 

Implementing the new requirements requires comprehensive preparation – from structuring the business model and developing business plans to completing licensing procedures with the NBU. The PwC Ukraine team has extensive experience advising financial institutions on a wide range of regulatory matters and liaising with the NBU. We are ready to support companies at every stage: