National Bank of Ukraine further softens foreign exchange restrictions

On 11 August 2026, Resolution of the Board of the National Bank ("NBU") of Ukraine No. 90 dated 10 August 2026 “On Amendments to Resolution of the Board of the National Bank of Ukraine No. 18 dated 24 February 2022” (“Resolution No. 90”) entered into force.

The amendments made by Resolution No. 90 to Resolution of the Board of the NBU No. 18 dated 24 February 2022 “On the Operation of the Banking System During the Period of Martial Law” (“Resolution No. 18”) are aimed at further easing the currency restrictions applicable during martial law and affect foreign currency transactions of both individuals and legal entities.

For businesses, the key changes include:

• The introduction of a new type of limit, allowing certain foreign currency transactions to be carried out within an amount corresponding to funds directed towards supporting Ukraine’s defense capability (the “Limit”)
• The ability to use accumulated limits (the “Limit” and the “Investment Limit”) either directly by the resident legal entity or by another related to it resident legal entity
• Increased limits for transactions involving corporate electronic payment instruments and
• Other targeted relaxations of currency restrictions.

1. New "Limit" for certain foreign currency transactions

Within the new "Limit" introduced by the NBU legal entities may carry out certain foreign currency transactions that would otherwise remain restricted under Resolution No. 18.

The amount of the "Limit" equals the aggregate amount of charitable donations made in monetary form by a resident legal entity starting from 10 August 2026, where the ultimate recipients are military units of the Armed Forces of Ukraine or the National Guard of Ukraine and the donations are made for the purposes of supporting Ukraine’s defense capability and mobilization readiness in connection with the introduction of martial law.

Foreign currency transactions within the "Limit" may be carried out only if all of the following conditions are met:

• The funds used for the relevant charitable donations must not have been raised in the form of a loan or credit
• The amount of charitable donations must be confirmed by the financial statements of the resident legal entity in respect of which an audit conclusion (report) has been issued by one of the following firms, Deloitte, PricewaterhouseCoopers, Ernst & Young, KPMG
• To confirm the amount of the "Limit", the relevant financial statements, audit conclusion (report) and documents confirming the charitable donations must be submitted to the bank
• Foreign currency transactions within the "Limit" may be carried out exclusively using the legal entity’s own foreign currency funds, i.e. funds that were neither purchased nor received in the form of a loan or credit, and
• Transactions within the "Limit" must be carried out through one bank selected by the resident legal entity; Resolution No. 18 also provides for the possibility of changing such bank in accordance with the prescribed procedure.

The "Limit" may be used for the transactions specified in subparagraph 57 of paragraph 14 of Resolution No. 18, i.e. the same transactions for which the previously introduced “Investment Limit” may be used. For more details, please refer to the January 2026 EY Newsletter: National Bank of Ukraine continues its policy of stimulative liberalization of currency restrictions | EY - Ukraine

2. Use of the "Investment Limit" and the "Limit" by related parties

The NBU has allowed foreign currency transactions within the amounts of the "Investment Limit" and the "Limit" to be carried out not only by the resident legal entity that accumulated the relevant limit, but also by its related parties (within the meaning of the Tax Code of Ukraine), provided that the former gives its written consent to such use of the relevant limits and the transactions are carried out through the same bank.

In practice, this change provides greater flexibility in forming and using the relevant limits between related legal entities (within the same business group).

3. Increased limits for certain transactions of legal entities

Legal entities may now withdraw cash within the following limits:

• From hryvnia accounts in Ukraine – up to UAH 200,000 per day, compared with the previous limit of UAH 100,000
• Abroad using corporate cards linked to hryvnia accounts – up to UAH 140,000 per calendar month, compared with the previous limit of UAH 17,500 per week and
• From foreign currency accounts in Ukraine and abroad – up to the equivalent of UAH 200,000 per day, compared with the previous limit of UAH 100,000.

The limit on payments abroad for goods, works and services using corporate cards linked to hryvnia accounts has increased from UAH 150,000 to UAH 400,000 per calendar month. The ability to make equivalent payments using corporate cards linked to foreign currency accounts without a limit remains unchanged.

4. Other relaxations of currency restrictions for businesses

Resolution No. 90 also introduces a number of other changes that may be relevant to legal entities.

In particular, resident legal entities are now permitted to:

• Transfer funds abroad to pay fines, penalties and bonuses and to reimburse expenses and losses under foreign economic agreements for the export of goods; the aggregate amount of such transfers during a calendar year may not exceed 10% of the total value of goods supplied to the relevant non-resident under the relevant agreement after 23 February 2021
• Transfer funds abroad to return grant funds under agreements entered into with foreign governments, foreign institutions involving foreign-state participation, interstate funds established by foreign states, or the non-resident legal entity authorized to administer UN grants
• When repatriating dividends to foreign investors, for the purposes of the minimum 12-month period of the issuer’s activity, - include the period of activity of the issuer’s legal predecessor, where the issuer was established as a result of the legal transformation, and
• Make transfers to pay registration fees for participation in congresses, conferences and other international scientific events in an amount not exceeding the equivalent of EUR 1,000 per event.

In addition, the NBU has:

• Extended the ability of clients to purchase foreign currency for the performance of obligations under foreign currency bank loans, provided that such client is the borrower or a guarantor/surety provider of the obligations under the relevant loan agreement (paragraph 19 of Resolution No. 18)
• Expanded the range of transactions for which settlements under documentary and standby letters of credit, guarantees and counter-guarantees are permitted, by adding transactions involving the payment by a resident legal entity of registration, arbitration and court fees (subparagraph 34 of paragraph 14 of Resolution No. 18), and
• Expanded the list of risks in connection with which the relevant foreign currency transfers are permitted to include political risks and risks of political violence (subparagraph 2⁷ of paragraph 14 of Resolution No. 18).

5. Changes for individuals

Resolution No. 90 also provides for a number of relaxations of currency restrictions applicable to individuals.

In particular:

• The aggregate limit for purchases through one bank during a calendar month of non-cash foreign currency, banking metals and securities of foreign issuers has been increased from UAH 50,000 to the equivalent of UAH 200,000
• The limit on cash withdrawals from foreign currency accounts has been increased from UAH 100,000 to the equivalent of UAH 200,000 per day
• The limit on payments abroad for goods, works and services from hryvnia accounts has been increased from UAH 100,000 to the equivalent of UAH 200,000 per calendar month; rental of accommodation has been added to the permitted transactions, and payments may be made either by card or by account-to-account transfer, including via SWIFT
• An aggregate monthly limit of up to the equivalent of UAH 200,000 has been introduced for payments for goods, works and services from foreign currency accounts without the use of a payment card (for instance, using the SWIFT system), whereby settlements for goods, works and services abroad using payment cards linked to foreign currency accounts continue to be carried out without any amount limit, except for certain transactions for which special limits are established by Resolution No. 18, and
• The monthly limit of up to UAH 500,000 applicable to payments by transfer of own foreign currency from all foreign currency accounts of the individual, which earlier applied to payments for accommodation services abroad, has been extended to cover rental of accommodation.

Practical steps for companies

• Companies should consider reviewing their internal policies governing the use of corporate cards and foreign currency payments, updating operational limits in their treasury and compliance procedures and, in the case of exporters, introducing controls to monitor the 10% annual limit on payments under agreements with non-residents
• Legal entities making charitable donations to the Armed Forces of Ukraine or the National Guard of Ukraine should consider the possibility of forming, as well as, transferring and using together with related legal entities (within the same business group), the "Limit" and determine in advance the supporting documents required for this purpose.