April 2026
The National Securities and Stock Market Commission (NSSMC) adopted Decision No. 09/21/4168/K03 of 16 April 2026, which introduces additional restrictions on transactions involving Ukraine’s government bonds during martial law. The Decision comes into force on 16 May 2026.
The document is aimed at strengthening control over the circulation of government debt instruments and preventing the outflow of foreign currency assets from Ukraine
NEW REGULATORY REQUIREMENTS
Mandatory Delivery‑versus‑Payment (DVP) Settlement
Once the Decision enters into force, investment firms will be able to buy and sell Ukrainian government Eurobonds (including under swap arrangements) only where transactions are settled on a delivery‑versus‑payment (DVP) basis.
DVP settlement must be facilitated through a central counterparty (CCP) performing clearing services. In this structure, the CCP steps in as the counterparty to both sides of the transaction, assuming the corresponding rights and obligations. As a result, bilateral settlement arrangements outside the CCP framework will no longer be permitted.
National Bank of Ukraine Oversight of Depository Operations
Depository institutions may carry out any book‑entry operations involving the transfer of government bonds, as well as rights to or under such bonds, only upon receipt of an instruction or notification from the NBU.
This change effectively introduces centralised regulatory oversight over all depository movements involving government Eurobonds during the period of martial law
Ban on Removing Government Bonds from the Depository System
The Decision expressly prohibits bondholders from taking any actions that would result in government bonds being withdrawn from the securities depository accounting system.
In parallel, depository institutions are prohibited from processing any write‑off or similar entries that would lead to the removal of such bonds from the depository system, even where such actions are initiated by the bondholders themselves.
SUMMARY
The requirements set out above do not apply to banks’ transactions acting in its own name and on its own account.
Investment firms are required to bring unfulfilled contracts into compliance with the new requirements through the Central Securities Depository prior to the settlement of such contracts. This applies to all outstanding obligations in force as at the date of entry into force of the Decision.
