Ukraine modernises enforcement proceedings: what changes from 23 October 2026
Please confirm you are human to start the audio.
Authors
On 23 October 2026, Ukraine will enact Law No. 4833-IX, which will modernise enforcement proceedings through greater automation, expanded electronic information exchanges and greater controls over the Unified Register of Debtors. The changes will impact banks and other financial institutions, businesses dealing with debtor assets and the parties of enforcement proceedings.
Greater automation of enforcement proceedings
The law modernises and automates enforcement proceedings in the following ways:
- Automatic lifting of arrests: For enforcement claims not exceeding ten minimum wages (UAH 86,470 for 2026), once sufficient funds have been received to cover the enforceable claim and related enforcement amounts, the Automated Enforcement Proceedings System (AEPS) will generate a debt-settlement notice. That notice will serve as the basis for removing the debtor from the Unified Register of Debtors and lifting restrictions over funds, electronic money and electronically recorded securities.
- Mandatory connection for financial institutions: Banks, other financial institutions, qualifying non-bank payment service providers and electronic money issuers must connect to the electronic information exchange system between enforcement officers and banks, non-bank payment service providers and electronic money issuers within the statutory transition period (i.e. until 23 October 2026).
- Expanded electronic information exchange: The Law expands the AEPS framework for interaction between enforcement officers and public authorities, banks, other financial institutions, non-bank payment service providers and electronic money issuers.
Stronger enforcement against funds and other assets
The law includes the following provisions strengthening enforcement on funds and assets:
- Prohibition of deposit renewal: Once a bank receives an enforcement officer’s order attaching funds held in deposit accounts, the term of the deposit agreement may not be extended.
- Automated enforcement against funds and electronic money: The AEPS will be responsible for processing enforcement against funds and electronic money held in accounts and electronic wallets with banks or other financial institutions, non-bank payment service providers and electronic money issuers.
- Arrest of funds and electronic money: The arrest of a debtor's property now expressly applies to funds and electronic money. The arrest also extends to funds held in accounts, and electronic money held in e-wallets with electronic money issuers, opened after the arrest order was issued.
A stronger role for the Unified Register of Debtors
The law includes the following provisions vis-à-vis the Unified Register of Debtors:
- Asset disposals and pledges: Subject to statutory exceptions, an authorised person dealing with the disposal or pledge of an asset must refuse the relevant action where the owner is listed in the Unified Register of Debtors and notify the enforcement officer.
- Vehicle transactions: The debtor register must also be checked when a vehicle is re-registered or removed from registration. In the cases specified by law, the relevant Ministry of Internal Affairs body must refuse the registration action and notify the enforcement officer.
- Special rules for banks: The Unified Register of Debtors will not include systemically important banks with debts not exceeding UAH 50 million and other banks with debts not exceeding UAH 20 million. This exception ceases to apply if the debt remains uncollected for two months after enforcement proceedings are opened.
Additional changes
The law includes the following provisions for debtor protections and procedural changes:
- Sole residence threshold: The threshold limit for enforcement against a debtor’s sole residence and the land on which it stands has increased from 20 to 50 minimum wages (UAH 432,350 for 2026), subject to statutory exceptions.
- Reopening enforcement proceedings: A new procedure allows certain enforcement proceedings to be reopened after an enforcement document has been returned to the creditor, including on applications by the creditor, debtor or prosecutor in specified cases, or following an application or notification from a court.
The amendments are expected to make enforcement proceedings more digital and automated while strengthening the role of the Unified Register of Debtors and expanding the rules governing enforcement against funds and other assets.
For more information on this new Law in Ukraine, contact your CMS client partner or the CMS experts who contributed to this article.