Finance legal services 

Obtaining a financial institution licence involves meeting the Regulator's requirements for the relevant type of institution, preparing a comprehensive document package, and completing the authorisation procedure. The licensing process is lengthy, resource-intensive, and requires specialised expertise.

PwC Legal provides full legal support for banks and financial institutions throughout the licensing process, including financial legislation advisory, development of internal policies, and regulatory compliance. To discuss your licensing needs, reach out to our team using the contact form below.

Under Ukrainian law, the following types of financial services require licensing:

1. Insurance
2. Lending and provision of bank metals as credit
3. Acceptance of repayable deposits and bank metals
4. Financial leasing
5. Factoring
6. Issuance of guarantees
7. Foreign currency trading
8. Financial payment services (account opening, maintenance and closure; payment instrument issuance and/or acquiring; funds transfers without opening an account; electronic money issuance)
9. Professional activities on capital markets:
   • Trading in financial instruments (brokerage, dealing, investment advisory, etc.)
   • Organisation of financial instrument trading
   • Clearing
   • Depository activities
   • Asset management for institutional investors
   • Property management for financing construction and/or real estate transactions
   • Administration of non-state pension funds

Our banking and financial law team regularly advises clients on licensing requirements across all of these categories. To find out which licence applies to your business, speak with our team using the contact form below.

The Law of Ukraine "On Financial Services and Financial Companies" designates two regulators: the National Bank of Ukraine (NBU) and the National Securities and Stock Market Commission (NSSMC).

The NBU regulates most types of financial services, including banks, insurers, payment institutions, financial companies, and pawnshops. The NSSMC, in turn, regulates financial institutions engaged in professional activities on capital markets.

Not sure which regulator oversees your business? We'd be happy to discuss your specific situation.

The required documents depend on the type of financial institution and the relevant financial service, but typically include:

• Statutory documents;
• Business plan;
• Transparent ownership structure;
• Proof of legal capital formation;
• Professional suitability and reputation of owners and management;
• Internal policies for proper provision of financial services (including service rules, internal control, AML/CFT documentation).

We can help you prepare a complete document package that meets the Regulator's requirements.

Typically, obtaining a financial institution licence takes no less than six months and includes:

• Preparatory work and assembly of the required document package — several months;
• Review of the document package by the Regulator — the standard NBU review period is three months (60 business days).

However, legislation grants the Regulator considerable authority to suspend or extend the review timeline. In practice, actual review periods tend to significantly exceed the statutory standards. We help financial institutions prepare their document packages on time and to the required standard, minimising the risk of delays.

Requirements depend on the type of financial institution, but typically include:

• Statutory and equity capital exceeding the legally prescribed minimums;
• Transparent ownership structure;
• Lawfulness of sources of funds used to form capital;
• Impeccable business reputation of owners and management;
• Sufficient professional qualifications of management;
• Business plan and internal documents meeting established requirements;
• Sound corporate governance, internal control, and risk management systems;
• Robust AML/CFT framework;
• Compliance with the Regulator's prudential ratios;
• Consumer protection and market conduct compliance.

Meeting all of these requirements simultaneously can be challenging. Our team has hands-on experience guiding financial institutions through the full registration process — let us know how we can help.

It is essential to carefully analyse the reasons for refusal and address each one before resubmitting. In our experience, the most common grounds for rejection relate to insufficient proof of the lawfulness of capital sources, ownership structure transparency, or gaps in internal documentation.

We provide legal support at every stage of the NBU's review process, including analysis of the reasons for refusal, preparation of an updated document package, and ongoing communication with the Regulator until authorisation is obtained.

The licensing process involves multiple regulatory checkpoints, and issues at any stage can lead to delays or rejection. The most common risks include:

• Insufficient documentary proof of the lawfulness of owners' sources of funds for capital formation;
• Indications of a questionable business reputation of owners or management;
• Failure to meet prudential requirements;
• Enforcement measures for AML/CFT violations;
• Poorly developed business plan;
• Internal documents not meeting specific legislative requirements.

Early-stage advisory can help identify and mitigate these risks well before the application is filed.

Yes, we provide legal support at all stages, including document review and regulatory compliance.

We are ready to begin immediately after agreeing terms, completing risk management procedures, and signing contract documents.

Yes, we offer ongoing legal support for financial institutions, covering internal controls and risk management, AML/CFT compliance, cybersecurity, consumer protection, and personal data protection.

Our banking and financial law team has deep expertise in the key regulations governing the financial sector and is ready to help your organisation maintain full compliance with Ukrainian and international requirements. Contact us to discuss how we can support your business on an ongoing basis.