Beginning 14 January 2026, the National Bank of Ukraine (NBU) announced a further stage of currency liberalisation and a more granular approach to foreign exchange (FX) controls. These changes signal a measured transition from emergency restrictions towards a more calibrated, risk‑based regime intended to support external stability while facilitating legitimate cross‑border activity and investment.

Context and objectives

Since the outset of martial law, Ukraine has operated a temporary FX regime designed to safeguard financial stability, manage wartime pressures on reserves, and deter illicit flows. The latest policy steps continue the NBU’s path of easing, with an emphasis on predictability and targeted opening.

The stated objectives include simplifying bona fide current‑account transactions, enabling the orderly servicing of external obligations, and gradually restoring market instruments that help residents hedge currency risk, all while preserving macro‑financial resilience.

New loan incentive limit

The NBU introduced a new “loan incentive limit” to increase flexibility for Ukrainian companies in managing funds raised from abroad and to create a regulatory basis for restructuring “old” external loans, thereby facilitating new funding for the economy.

The size of the loan limit equals the amount of funds received under a cross-border loan in foreign currency to the company’s account in a Ukrainian bank after 1 January 2026.

Transactions allowed within the loan limit:

  • repayment of “old” loans (i.e. obtained before 20 June 2023) and the payment of interest on them;
  • settlements for imports of goods delivered before 23 February 2021;
  • refunds to a non-resident buyer of prepayment for goods made before 23 February 2022;
  • financing of the company’s own foreign branches or offices (above the established limit);
  • repayment of dividend (above the established limit).

Specific features of the “loan” limit:

  • upon repayment of the principal of the attracted loan, the maximum amount available under the “loan” limit is reduced accordingly;
  • after conducting operations within the “loan” limit, transfers from Ukraine to repay the principal of the attracted loan are limited to the outstanding loan amount minus the amount of operations performed within the limit;
  • FX transactions within the “loan” limitare carried out at the servicing bank where the company received the attracted credit.

Other parameters of these loans must meet the general conditions for “new” foreign borrowings under NBU Board Resolution No. 18 of 24 February 2022 (as amended), in particular:

  • maximum interest rate of 12% per annum;
  • early repayments under the loan are prohibited;
  • the resident borrower may pay interest (including using purchased foreign currency);
  • repayment of principal is allowed (within the remaining cap of the “loan” limit) using the company’s own foreign currency and, starting from the second year after the loan disbursement, also using purchased foreign currency.

Transfers for consumer refunds by Ukrainian sellers or manufacturers

Ukrainian sellers or manufacturers may transfer foreign currency to accounts of individuals in foreign banks to refund payments for returned or undelivered goods, subject to the following conditions:

  • the refund is made to the individual consumer’s account from which the payment for the goods was made;
  • the refund amount, in the payment currency, must not exceed the purchase price of the goods;
  • the seller or manufacturer makes the refund in the manner and within the time limits provided by the Law of Ukraine “On Consumer Rights Protection.”

Clarifications to FX regulation (settlement deadlines for exports)

The NBU introduced the following measures:

  • requirements on settlement deadlines do not apply to goods exported under a foreign economic contract whose receivable has been assigned to JSC “Export Credit Agency” (ECA), up to the amount of insurance indemnity paid by the ECA to the exporter. This supports the ECA’s core mandate of promoting exports of Ukrainian-origin goods, works and services.
  • export of insurance services has been removed from the list of operations to which settlement deadline requirements apply, aligning FX regulation of insurance with that for other financial services, which are not subject to settlement deadlines.

NBU eases currency restrictions for Defence City residents

Effective 31 December 2025, amendments to NBU Resolution No. 18 (Resolution No. 166 dated 30 December 2025) came into force, aimed at supporting the defence-industrial complex.

The purpose of these changes is to create favourable conditions for the operation of the defence industry within the Defence City legal regime and to strengthen Ukraine’s defence capability.

The changes introduced include:

  • Placement of funds in accounts of Defence City residents
  • Permitted placement of targeted financing received under grant, loan, or credit agreements from foreign export credit agencies, foreign states, and international organisations; and
  • Funds must be used for the development of defence technologies, production of defence and dual-use goods and services, as well as for the purchase or creation of equipment.

Foreign exchange transactions based on individual NBU permits

  • Allowed upon requests from the Ministry of Defence of Ukraine for Defence City residents;
  • Transactions may involve the implementation of international interagency agreements or acquisition of equity stakes in the authorised capital of non-resident legal entities; and
  • Permits are granted subject to maintaining the stability of the Ukrainian currency (Hryvnia, UAH) and alignment with the strategy for easing currency restrictions.

Practical implications and looking ahead

Businesses engaged in cross‑border trade and financing should find it incrementally easier to execute legitimate payments supported by underlying contracts. For borrowers with external indebtedness, there is a stronger policy signal towards allowing orderly servicing of loans, subject to the applicable limits and verification procedures. Corporations should also anticipate gradual improvements in access to hedging instruments as the authorities restore market depth and liquidity step by step.

Banks will play an enhanced gatekeeper role. The burden of due diligence, verification of economic purpose, and monitoring of payment flows remains central to the framework’s risk‑based design.

The NBU’s measured liberalisation underscores a policy preference for stability and transparency over abrupt deregulation. Further easing will likely remain contingent on the macro‑financial backdrop, reserve dynamics and the robustness of bank‑level controls. Market participants that invest early in documentation quality, compliance alignment and operational readiness will be best placed to benefit from the added flexibility as the regime evolves through 2026.