FX Liberalization Measures Affecting Cross‑Border Trade Operations

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FX Liberalization Measures Affecting Cross‑Border Trade Operations

The National Bank of Ukraine has introduced additional FX liberalization measures and clarified certain aspects of currency regulation and supervision, aimed at supporting domestic businesses, consumers, and exporters

23.01.2026

Clarification of FX regulation
and settlement deadlines for exports

To implement Ordinance of the Cabinet of Ministers of Ukraine No. 1209 dated 5 November 2025, the The National Bank of Ukraine (NBU) has clarified the application of currency supervision rules on settlement deadlines for certain export transactions.

In particular:

settlement deadline requirements do not apply to goods exported under a foreign economic agreement where the right of claim has been transferred to Export Credit Agency PrJSC (ECA) in the amount of insurance indemnity paid by the ECA to the exporter; this measure is aimed at facilitating exports of Ukrainian goods, works, and services;
export of insurance services has been excluded from the list of transactions subject to settlement deadline requirements, thereby aligning the FX regulation of insurance services with that applicable to other financial services, which are not subject to such deadlines.

Refunds to individuals for returned or undelivered goods

The NBU has permitted domestic sellers and manufacturers to transfer foreign currency to individuals’ accounts with foreign banks for the purpose of refunding payments for returned or undelivered goods.

Such transfers are allowed subject to the following conditions:

funds must be refunded to the consumer’s account from which payment for the goods was originally made;
the refund amount in the relevant currency must not exceed the value of the goods at the time of purchase;
refunds must be made in accordance with the procedure and within the time limits established by the Law of Ukraine “On Consumer Rights Protection.”

Such transfers are allowed subject to the following conditions:

funds must be refunded to the consumer’s account from which payment for the goods was originally made;
the refund amount in the relevant currency must not exceed the value of the goods at the time of purchase;
refunds must be made in accordance with the procedure and within the time limits established by the Law of Ukraine “On Consumer Rights Protection.”