23.01.2026
What is the loan limit?
The loan limit (in Ukrainian – "позиковий ліміт") is a new mechanism operating in parallel with the existing so-called investment limit, but without the requirement to inject funds into the authorized capital of a resident company. It applies to cross-border loans received by resident borrowers (legal entities) and is intended to stimulate new foreign funding inflows into Ukraine.
Key features of the loan limit
From 14 January 2026 legacy loans (i.e., loans received before 20 June 2023, or “old” loans) may be repaid in an extended volume - up to the amount of new funds which are provided as loans by foreign lenders. The amount of the loan limit equals the volume of foreign currency funds received under a loan from abroad, and credited to the resident borrower’s account with a Ukrainian bank after 1 January 2026 (hereinafter the “new loan”).
Permitted transactions within the loan limit
Within the loan limit, resident businesses may carry out transactions allowed under the National Bank's stimulating FX liberalization framework, including:
repayment of “old” loans (received before 20 June 2023) and payment of interest thereon;
settlements for the import of goods delivered on or before 23 February 2021;
refunds to non resident buyers of advance payments for goods prepaid before 23 February 2022;
financing of own foreign divisions/representative offices above the established limit;
repatriation of dividends above the established limit.
It is important to note that repayment of the new loan is permitted only to the extent that the loan proceeds remain unapplied after the resident has actually used such proceeds for the permitted purposes listed above.
Important conditions
Under the relevant loan agreement, no international financial institution may act as lender, guarantor, or surety.
Operations must be conducted through one and the same servicing bank.
Additionally, under the relevant loan agreement, the maximum interest rate must not exceed the statutory limit of 12% per annum, as well as other statutory restrictions with respect to loan provision and repayment shall be complied with (e.g. the ban on accelerated prepayment).
Key takeaways
In substance, the loan limit creates a new refinancing option for older cross border debt, directly linked to fresh foreign funding.
Borrowers may decide how to allocate the loan limit - either:
to repay a legacy debt, or
to repay the new loan granted after 1 January 2026.
The amounts of outstanding indebtedness under both are to be closely calculated and monitored by the resident’s servicing bank.
Through this mechanism, the National Bank clearly encourages new money inflows into Ukraine while gradually easing restrictions on historic cross border liabilities.
Dr. Oleh Zahnitko
Olena Savchuk
Yuriy Korchev