CMS Expert Guide to Crypto Regulation in Ukraine

Disclaimer: This chapter was last updated on 16 June 2025 and does not reflect any subsequent developments. The information provided is intended for general informational purposes and should not be construed as legal advice.

As of today, Ukraine is in the process of developing a legal framework to regulate cryptoassets, with the aim of introducing comprehensive laws and regulations to address the evolving digital asset landscape. Key legislative elements include: 

1. The Law of Ukraine on Virtual Assets (Law No. 2074) – this law, further referred to as the “Law”, has already been adopted by the Parliament of Ukraine but is not yet in force. It will come into effect once relevant regulatory acts are passed to amend the tax legislation, specifying how transactions involving virtual assets will be taxed.

2. EU MiCA (Markets in Crypto-assets) Regulation – Ukraine is aligning its regulatory approach with the EU’s Markets in Crypto-assets (MiCA) Regulation, which came into effect in the EU on 30 December 2024. This alignment, as detailed in more detail in section 2 below, reflects Ukraine’s commitment to harmonising with European standards for crypto-asset regulation. 

3. The Tax Code is expected to be amended to implement the aforementioned Law, contingent upon the adoption of certain draft laws, including potentially draft law No. 10225 “On Amendments to the Tax Code of Ukraine and Other Legislative Acts of Ukraine Regarding Regulation of Turnover of Virtual Assets in Ukraine” (hereinafter referred to as the “Draft Law”) from the National Securities and Stock Market Commission or any alternative versions thereof.

The National Securities and Stock Market Commission has developed the Draft Law based on the MiCA. 

The Law provides for the creation of new business opportunities related to the turnover of virtual assets, which may be provided by both resident and non-resident companies, subject to obtaining a permit from the National Securities and Stock Market Commission.

Such services include:

1. storage and/or administration of virtual assets or virtual asset keys;
2. provision of services for the exchange of virtual assets for other virtual assets and currency values;
3. provision of virtual asset transfer services; and
4. provision of intermediary services related to virtual assets. 

It is important to note that a separate permit is issued for each of the four types of services listed above. At the same time, companies are not prohibited from carrying out several types of activities at once, provided that they have a separate permit for each of these types of services. 

The applicant (a person who plans to carry out the activities of a provider of services related to the turnover of virtual assets) must meet the requirements set out in the Law. The Law also states that the provider of services related to the turnover of virtual assets cannot be companies  which are in some way connected with the aggressor state or the occupying state (registered in the territory of such states, controlled by residents of such states, having founders (participants) or ultimate beneficial owners resident in such states, etc.)

As referenced above, the Law establishes the following types of services related to the circulation of virtual assets:

1. storage and/or administration of virtual assets or virtual asset keys;
2. provision of services for the exchange of virtual assets for other virtual assets and currency values;
3. provision of virtual asset transfer services; and
4. provision of intermediary services related to virtual assets. 

Offshore companies that provide cryptocurrency services to Ukrainian clients should comply with Ukrainian and European standards to avoid restrictions and sanctions, especially given Ukraine's commitment to EU integration. Anti-money laundering (AML), counter-terrorist financing (CTF) and proliferation financing (PF) requirements must be met. This includes financial monitoring and customer identification. 

It should be noted that Ukraine plans to introduce a tax regime for cryptocurrencies, which will apply to income from transactions involving virtual assets. 

According to the Law, a service provider may be a foreign legal entity participating in the virtual asset market, provided it operates as a service provider under the laws of its home country. Its activities must also comply with the procedure and conditions set by the National Securities and Stock Market Commission, in line with the requirements and restrictions set out in the Law.

The National Securities and Stock Market Commission shall decide to issue or refuse to issue a permit for the provision of services related to the turnover of virtual assets within 30 days from the date of receipt of the application and the requested documents. 

The permit to conduct a certain type of activity of a provider of services related to the turnover of virtual assets is valid for one year.

According to the Law, the cost of the permit depends on the specific service that a company plans to provide and the status of the company obtaining the permit (resident or non-resident). 

The permit fees for residents of Ukraine are as follows:

1. for issuance of a permit for storage or administration of virtual assets or virtual asset keys – approximately EUR 2,850;
2. for issuing a permit for the exchange of virtual assets – approximately EUR 1,800;
3. for issuing a permit for the transfer of virtual assets – approximately EUR 1,800; and
4. for issuing a permit for the provision of intermediary services related to the turnover of virtual assets – approximately EUR 1,400. 

The fee for issuing a permit for non-residents of Ukraine is as follows:

1. for issuance of a permit for storage or administration of virtual assets or virtual asset keys – approximately EUR 14,000;
2. for issuing a permit for the exchange of virtual assets – approximately EUR 9,000;
3. for issuing a permit for the transfer of virtual assets – EUR 9,000; and
4. for issuing a permit for the provision of intermediary services related to the turnover of virtual assets – EUR 7,000.

As of today, companies are unable to obtain a permit from the National Securities and Stock Market Commission for providing services related to the turnover of virtual assets, as the Law has not yet come into force. Consequently, there are no statistics available that would allow us to assess the probability of success in obtaining a licence.

The Law introduces requirements for the authorised capital of companies for each type of service related to the turnover of virtual assets. 

1. Services for the storage or administration of virtual assets or virtual asset keys:

The size of the authorised capital for residents of Ukraine - providers of services for the storage or administration of virtual assets or virtual asset keys must be at least approximately EUR 25,000. The amount of the authorised capital for non-residents of Ukraine - providers of services for the storage or administration of virtual assets or virtual asset keys must be at least approximately EUR 125,000.

2. Virtual asset exchange services:

The minimum authorised capital for Ukrainian resident providers of virtual asset exchange services is approximately EUR 12,500. For non-resident providers, the required minimum is approximately EUR 62,000.

3. Virtual asset transfer services:

The authorised capital for Ukrainian resident providers of virtual asset transfer services must be at least approximately EUR 12,500. For non-resident providers, the minimum authorised capital is approximately EUR 62,000. 

4. Intermediary services related to virtual assets:

The authorised capital for Ukrainian resident providers of intermediary services related to virtual assets should be at least approximately EUR 12,500. For non-resident providers, the minimum authorised capital must be approximately EUR 62,000. 

In addition, if a company plans to provide services related to the turnover of virtual assets backed by currency values, it should consider that only a financial institution can carry out such activities. In this case, it is necessary to obtain a licence from the National Bank of Ukraine.