In practice, obtaining a court judgment is often only half the battle. Enforcing that judgment can prove no less challenging, particularly where the debtor has no readily identifiable assets or deliberately seeks to evade compliance.
On 23 October 2026, the majority of the provisions of Law of Ukraine No. 4833-IX entered into force, introducing a number of changes to the procedure for the compulsory enforcement of court judgments.
What exactly has changed, and what practical implications will these changes have for businesses?
We examine five significant developments that both creditors and debtors should take into account.
Enforcement Document Returned? Proceedings Can Now Be Resumed
One of the most significant developments is the introduction of a separate procedure for resuming enforcement proceedings (new Article 37-1 of the Law of Ukraine “On Enforcement Proceedings”). Previously, to pursue recovery again, a creditor had to resubmit the enforcement document and commence new proceedings.
As of 23 October 2026, the procedure has changed. A judgment creditor may now apply to resume previously commenced enforcement proceedings. In particular:
the proceedings are resumed under their original case number;
an application may be submitted not only to the enforcement officer who previously handled the proceedings, but also to another territorially competent state enforcement authority or a private enforcement officer;
where an application has been duly submitted, the enforcement officer must issue a resumption order no later than the next business day after receiving it.
What are the practical implications?
After 23 October 2026, where an enforcement document has been returned, the appropriate course is to apply for resumption of the previous proceedings rather than commencement of new ones. Otherwise, the applicant risks having its request to commence enforcement proceedings refused.
Companies holding enforcement documents that were previously returned without satisfaction should therefore check the applicable time limits for submitting those documents for enforcement and consider seeking resumption of the relevant proceedings.
Recovery from E-Wallets, Payment Accounts and Deposits: More Assets Within Reach of Enforcement Officers
Amended Article 48 of the Law of Ukraine “On Enforcement Proceedings” clarifies the rules governing enforcement against a debtor’s financial assets. The scope therefore extends beyond bank accounts to accounts maintained with non-bank payment service providers and electronic money held in electronic wallets.
How effectively these rules will operate in practice remains to be seen.
Bank deposits warrant particular attention.
Under the new rules, the fact that a debtor’s funds are held in a deposit account does not prevent enforcement against those funds.
Once a bank receives an order attaching funds held in a fixed-term deposit account, it may not extend the term of the relevant deposit agreement. The enforcement officer must send the bank a payment instruction for the compulsory debit of funds in the amount prescribed by law.
What are the practical implications?
For creditors, this provides a clearer framework for identifying and recovering financial assets, including those held outside traditional bank accounts.
Debtors, by contrast, should recognise that holding assets in deposits or using electronic payment instruments does not, in itself, protect those assets from compulsory enforcement.
Debt Paid? Asset Freezes May Be Lifted Automatically – But There Is a Catch
New Article 39-1 of the Law of Ukraine “On Enforcement Proceedings” introduces a mechanism for the automated lifting of certain asset attachments following repayment of the debt.
Previously, even after a debt had been paid in full, lifting an attachment required additional time and action by a state or private enforcement officer.
Under the new rules, where the statutory conditions are met, the Automated System of Enforcement Proceedings (ASEP) will generate a notice confirming repayment of the debt. This notice will serve as the basis for removing the relevant debtor information from the Unified Register of Debtors and lifting the attachments.
However, two important limitations apply:
• the mechanism applies only to enforcement proceedings in which the amount to be recovered does not exceed ten statutory minimum monthly wages as at 1 January of the relevant year. In 2026, the threshold is UAH 86,470;
• payment of the principal debt alone is insufficient. The relevant account of the state or private enforcement officer must receive sufficient funds to cover all amounts due in the proceedings, including the enforcement fee, costs, fines and the private enforcement officer’s remuneration.
What are the practical implications?
The new mechanism may expedite the release of frozen financial assets in proceedings involving relatively small amounts.
However, the automated procedure does not currently apply to most major commercial disputes where the amount to be recovered exceeds the statutory threshold. Accordingly, businesses should not assume that any payment of a debt will automatically result in the lifting of all attachments.
Asset Attachment as Interim Relief: Clear Rules for Enforcement
The Law of Ukraine “On Enforcement Proceedings” has also been supplemented by a new Article 62-1, which specifically regulates the compulsory enforcement of court orders granting interim relief through the attachment of a debtor’s property, funds or electronic money.
Asset attachment as an interim measure was already available under Ukrainian law. However, the enforcement of such court orders was previously governed primarily by the general rules on enforcement proceedings.
On the day enforcement proceedings are commenced, the enforcement officer must issue an attachment order and take steps to record the relevant details in the applicable registers. The enforcement proceedings are concluded once the attachment has been imposed. Importantly, the interim relief order itself does not permit the recovery of funds or the sale of the attached property.
What are the practical implications?
For businesses, the key benefit is greater legal certainty. A claimant has a clearer procedure for enforcing an asset attachment order intended to preserve the ability to enforce a future court judgment, while the debtor has greater clarity as to the limits of such proceedings.
Provide Your IBAN Before Filing a Claim
Another change directly concerns court proceedings. Requirements governing the content of statements of claim do not change often, but they did change on 24 April 2026.
In claims for the recovery of money (note: not in all types of claims), both legal entities and individuals (including individual entrepreneurs) must provide the details of their bank or payment accounts and attach evidence that the account exists. Where an individual or individual entrepreneur has no account, this must be expressly stated, together with the preferred method of receiving the funds.
Failure to provide the required account details or supporting documentation may cause the court to leave the statement of claim without further action until the deficiencies are remedied. To avoid delays, check the account details and supporting documents before filing. This is particularly important in disputes requiring a prompt judicial response.
So, what should businesses do now?
Creditors should, at a minimum, review returned enforcement documents and inform enforcement officers of any known assets of their debtors (taking into account the expanded range of assets subject to enforcement).
Debtors should be prepared for the attachment and compulsory recovery of funds held in deposits, accounts with non-bank payment institutions and electronic wallets, and should not expect attachments in high-value cases to be lifted automatically.
All claimants should update their statement-of-claim templates for monetary claims and remember to include evidence of the relevant account.
IMPACTA LAW supports clients not only during litigation but also at the judgment enforcement stage. We work to maximise the effectiveness of debt recovery and challenge both actions and omissions of enforcement officers, including where established approaches in case law create additional obstacles to effective legal protection.
We addressed one such issue in our article “Challenging an Enforcement Officer’s Actions in Consolidated Enforcement Proceedings: Is the Supreme Court’s Approach Justified?”
