Ukraine’s currency liberalisation expected to bring business stability and confidence

On 5 August 2025, the Board of the National Bank of Ukraine (NBU) adopted Regulation No. 95, marking the next stage in Ukraine’s wartime currency liberalisation. 

The adopted measures expand business opportunities without significantly increasing demand for foreign currency at the local FX market, while supporting investor confidence and compliance with Ukraine’s commitments under International Monetary Fund (IMF) programmes. 

This long-awaited package of FX liberalisation measures includes important changes for resident businesses and non-resident investors in the economy of Ukraine.

Repatriation of 2023 dividends permitted

The Regulation states that businesses can now repatriate dividends distributed from profits earned in 2023, within the existing general monthly limit of EUR 1 million per legal entity. This extends the previous cut-off date of 1 January 2024 to 1 January 2023.

According to the NBU, this measure is not expected to generate material FX demand due to the monthly cap and will help improve trust among foreign investors. Additionally, repatriated funds can be used abroad for other corporate purposes, including debt servicing.

Expanded access to FX hedging instruments

The Regulation enhances access to currency derivatives, continuing the roadmap laid out in the NBU’s Concept Paper under the IMF programme.

• Businesses can now enter into non-deliverable forward contracts with banks to sell foreign currency for UAH.
•  Residents (legal entities and individual entrepreneurs) are also permitted to purchase foreign currency under deliverable forward contracts to hedge FX risks related to import transactions.

Banks may only perform these forward purchases within the volume of foreign currency sold to them under other forward contracts, ensuring no added pressure at the local FX market.

Increased trust in Ukrainian entities through FX transfer adjustments

The Regulation enables:

• legal entities and individuals to return erroneously credited foreign currency funds received from abroad. The return request must be filed within three business days from notification of the erroneous transfer.
• resident maritime agents to return unused foreign currency funds received from non-resident shipowners or trustees. This facilitates fulfilment of contractual obligations without affecting FX market stability.

Support measures for the domestic jewellery sector

To support Ukraine’s jewellery industry and formalise the market, the NBU now allows legal entities and entrepreneurs engaged in jewellery retail to purchase banking metals in cashless UAH, under the following specific conditions:

• the monthly volume of purchases must not exceed 1/12 of the entity’s 2021 annual retail turnover of jewellery;
• the purchase must be supported by an agreement with a jewellery producer and documentation proving prior delivery of banking metals.

This measure is expected to stimulate domestic production while limiting shadow market activity.

Unified rules for syndicated loans involving IFIs

The Regulation aligns FX rules for syndicated loans involving international financial institutions (IFI). Resident borrowers may now service and repay such loans not only to IFIs, but also to other lenders within the syndicate, provided those lenders are top-tier foreign banks with ratings of “A” or higher.
Additionally, the Regulation permits FX transfers from Ukraine to satisfy recourse claims of foreign guarantors, sureties or insurers who have fulfilled obligations on behalf of Ukrainian borrowers.

Further incentives for investment and defence support

The NBU continues its approach of incentivised currency liberalisation:

• The list of transactions permitted beyond the investment limit is expanded to include dividend repatriation. The investment limit is defined as the amount contributed by foreign investors to the share capital of a Ukrainian enterprise in foreign currency from 12 May 2025 onwards.
• Legal entities that contribute funds to the NBU’s special account in support of the Armed Forces of Ukraine can now make certain FX transfers exceeding general restrictions. These include:
  • Settlements for goods imported before 23 February 2021;
  • Refunds to non-residents for prepayments received before 23 February 2022;
  • Debt servicing under external loans received before 20 June 2023;
  • Maintenance of foreign branches and offices;
  • Repatriation of dividends to non-residents.

These FX transfers may only be conducted using the business’s own currency funds.

• Conditions are also introduced to allow conversion of external debt into share capital contributions from non-residents. Banks will be able to reflect these conversions as a reduction in the term of external liabilities in the “Credit Agreements with Non-Residents” database.

The adopted measures reflect the NBU’s continued commitment to maintaining FX market stability while unlocking opportunities for businesses to attract investment, hedge risks, and meet international obligations. The Regulation is another step towards a gradual return to a liberalised currency regime, balancing macroeconomic resilience with private sector flexibility.

Most of the provisions entered into force on 6 August 2025. The permission to return erroneously received foreign currency from abroad became effective on 7 August 2025.

For more information on currency controls and Ukraine’s financial sector, contact your CMS client partner or CMS Ukraine experts Ihor Olekhov, Kateryna Chechulina.