Easing Currency Restrictions: Increased Limits, Support for Exporters and New Rules for Cross-Border Payments

On 10 August 2026, the National Bank of Ukraine (the "NBU") continued easing the currency restrictions established by Resolution No. 18 "On the Operation of the Banking System during the Period of Martial Law" dated 24 February 2022 (the "Resolution No. 18").

The amendments open up a number of new opportunities for businesses with respect to carrying out FX transactions, using corporate funds abroad and making certain cross-border payments.

Key Changes

1. Settlements with non-residents under export contracts

Residents may now make transfers to non-residents to pay fines, penalties and bonuses, as well as to reimburse costs and losses, under cross-border contracts for the export of goods. Such transfers within a calendar year may not exceed 10% of the total value of goods delivered to the relevant non-resident under the contract after 23 February 2021.

2. Other easings for businesses

In addition to the above, the NBU has introduced a number of other changes, in particular:

• Repatriation of dividends following a corporate transformation: the mandatory 12-month period of the issuer's operations now also includes the period of operations of the legal entity of which the issuer is the legal successor;

• Refunds of grant funds are now permitted where such grants were received under agreements with foreign governments, foreign state institutions, interstate funds established by foreign countries and/or legal entities administering UN grants;

• The NBU has clarified the list of persons permitted to purchase foreign currency to perform obligations under loan agreements with banks. The NBU removed the word "own" from the wording of the rule, expressly providing that this right is now available to borrowers as well as to guarantors and sureties;

• Transfers of funds to pay registration fees for participation in congresses, conferences and other international scientific events are now permitted — up to the equivalent of EUR 1,000 per event;

• Transfers of funds by the Innovation Development Fund in cases determined by a decision of the Government of Ukraine;

• Transfers of funds in favor of the U.S. International Development Finance Corporation (DFC) under agreements providing for political risk coverage.

3. Changes for the financial sector

The NBU has also introduced certain easings for financial institutions, in particular:

• The Motor (Transport) Insurance Bureau of Ukraine may now purchase foreign currency to place funds of the centralized insurance reserve fund of insurance guarantees;

• The NBU has expanded the grounds for early repayment by banks of loans received from non-residents. In addition to cases of an increase in the share capital of a foreign bank, banks are now permitted to repay loans to foreign creditors early where the regulator has refused to include the relevant subordinated debt or conversion instruments in the bank's capital. Only those funds that were received from the non-resident within the 3 months preceding the repayment date may be returned.

4. Use of FX limits by group companies

Companies may transfer the Investment Limit* and/or the Additional Limit (see point 5), in whole or in part, to other legal entities within the same group of companies. Transactions of both companies within such limit must be carried out through a single bank.

5. New limit for direct charitable contributions in support of Ukraine's defense capability

In addition to the existing "Donation Limit” **, resident legal entities are now entitled to carry out certain FX transactions in an amount equivalent to their monetary donations in favor of military units of the Armed Forces of Ukraine and the National Guard of Ukraine transferred starting from 10 August 2026 (the "Additional Limit").

In particular, the Additional Limit may be used for the repatriation of dividends, the performance of certain "old" import obligations, the repayment of "old" foreign loans and the financing of foreign representative offices. 

The regulator's key requirement: both the charitable contributions and the FX transactions within the Additional Limit must be financed exclusively out of the company's own available funds, without the use of loans, borrowings or purchased foreign currency.

To use this mechanism, a company must:

• concentrate the relevant settlements with one selected bank; and

• provide supporting documents confirming the transfer of the charitable donations, as well as financial statements confirmed by an audit opinion issued by one of the "Big Four" firms (Deloitte, PwC, E&Y or KPMG).

6. Increased limits for legal entities

The NBU has increased a number of limits applicable to transactions of legal entities, in particular:

• Cash withdrawals in hryvnia from accounts in hryvnia in Ukraine - up to UAH 200,000 per day, excluding bank fees (previously - UAH 100,000);

• Cash withdrawals abroad using hryvnia corporate cards - up to UAH 140,000 per calendar month (previously - UAH 17,500 per each seven calendar days);

• Cash withdrawals in foreign currency from FX accounts in Ukraine - up to the equivalent of UAH 200,000 per day (previously - UAH 100,000);

• Payments abroad for goods, works and services using hryvnia corporate cards - up to UAH 400,000 per calendar month across all of the client's bank accounts opened in hryvnia (previously - UAH 150,000).

At the same time, payments for goods, works and services using corporate (business) cards linked to foreign currency accounts may, as before, be made without an overall cap on the amount, except for certain transactions.

7. Changes for individuals

For individuals, the NBU has, among other things:

• Increased the limit on the purchase of foreign currency from UAH 50,000 to UAH 200,000 per calendar month with one bank, and permitted, within this limit, the purchase of non-cash bank metals and securities of foreign issuers;

• Increased the limit on cash withdrawals from FX accounts from UAH 100,000 to the equivalent of UAH 200,000 per day;

• Increased to UAH 200,000 per calendar month the limit on payments for goods, works, services and residential rent abroad from hryvnia accounts, and permitted such payments to be made not only by card but also by account-to-account transfer (including via SWIFT);

• Permitted transfers of an individual's own foreign currency from an FX account to pay for goods, works and services abroad up to the equivalent of UAH 200,000 per calendar month (including via SWIFT);

• Extended the limit of UAH 500,000 per calendar month to transfers from an FX account to pay for residential rent and accommodation services abroad (including via SWIFT).

The amendments to NBU Resolution No. 18 came into effect on 11 August 2026.