On 10 August 2026, the National Bank of Ukraine (the "NBU") adopted NBU Board Resolution No. 90 "On Amendments to Resolution of the Board of the National Bank of Ukraine No. 18 dated 24 February 2022" (the "Resolution"). The Resolution took effect on 11 August 2026. It introduced a new limit for FX transactions by companies that support Ukraine's defence, expanded the range of permitted cross-border transfers and FX transactions for businesses and the financial sector, and eased restrictions for individuals.
- Cash withdrawal limits
The NBU raised the daily cash withdrawal limit from the equivalent of UAH 100,000 to UAH 200,000 for both hryvnia accounts and foreign currency accounts. It also raised the limit on cash withdrawals abroad from hryvnia accounts using corporate (business) electronic means of payment to UAH 140,000 per calendar month.
- FX transaction limits for businesses
The Resolution expanded the system of limits within which resident legal entities may conduct certain FX transactions. Following the latest changes, the following limits are available to businesses:
- Investment Limit – the total amount of funds in foreign currency invested by a foreign investor from abroad into Ukraine in the charter capital of the relevant resident legal entity since 12 May 2025;
- Donation Limit – the total amount of a resident legal entity's own funds in hryvnia and/or foreign currency transferred since 7 August 2025 to the NBU's special account to raise funds in support of the Armed Forces of Ukraine. It excludes funds credited to the NBU's special account in connection with the enforcement of a court decision replacing bail with a personal recognisance and/or the approval of a plea agreement in criminal proceedings;
- Additional Limit – the total amount of charitable donations in monetary form made by a resident legal entity since 10 August 2026 to support the country's defence capability and mobilisation preparedness, where the ultimate recipients are military units of the Armed Forces of Ukraine or the National Guard of Ukraine. The amount of transactions forming the Additional Limit must be supported by financial statements accompanied by an audit opinion (report) from Deloitte, PricewaterhouseCoopers, Ernst & Young or KPMG. These documents, together with documents evidencing the donations, must be submitted to the bank.
Resident legal entities may conduct certain FX transactions up to the combined amount of these three limits:
- to settle obligations to non-residents under foreign trade contracts that arose before martial law was introduced, including payments for imported goods and refunds of advance payments;
- under loans (credits) from non-residents that were granted before 20 June 2023;
- to finance foreign branches, representative offices and subdivisions established without forming a separate legal entity; and/or
- to pay dividends to a foreign investor.
Such FX transactions may be carried out solely using own funds in foreign currency (not purchased or borrowed under a loan or credit) and through a single bank.
The Resolution also permits the transfer (in whole or in part) of the right to use the Investment Limit and/or the Additional Limit, to a resident legal entity related to the holder of the relevant limit, subject to the holder's written consent and provided that both legal entities conduct their transactions through the same bank.
- Additional permitted transactions for businesses and banks
The Resolution expanded the list of exceptions to the ban on cross-border transfers. It also permitted certain transactions by the Motor (Transport) Insurance Bureau of Ukraine and the Innovation Development Fund, as well as, among others, the following:
- payments by residents to non-resident counterparties of fines, penalties and bonuses, as well as reimbursement of expenses and losses, under foreign economic contracts for the export of goods, provided that the total amount of such transfers in a calendar year does not exceed 10% of the total value of goods supplied to the non-resident under the relevant agreement after 23 February 2021;
- repayment by residents of grant funds under agreements with grantors that are foreign governments, foreign institutions with the participation of foreign states, interstate funds established by foreign countries, or a non-resident legal entity authorised to administer UN grants;
- transfers in favour of non-resident legal entities whose members (shareholders or founders) include a foreign state (other than a state carrying out armed aggression against Ukraine), under agreements covering political risks and political violence risks;
- payments abroad of up to UAH 400,000 per calendar month for goods, works and services using corporate (business) electronic means of payment from hryvnia accounts; payments using electronic means of payment from foreign currency accounts remain uncapped, except for certain categories of transactions;
- early repayment by a bank of a loan or credit from a non-resident, if the funds are used to increase the bank's charter capital; the Resolution also permits a bank to return funds to a non-resident investor if the NBU has refused to include the relevant instrument with write-down/conversion terms or subordinated debt in the bank's capital, provided that the amount returned does not exceed the funds received from that non-resident from abroad during the three months preceding the transaction;
- payment of dividends on corporate rights/shares of a company established by way of transformation less than 12 months before the relevant transaction, provided that the minimum 12-month operating-history requirement is met when the period of operation of its legal predecessor is taken into account.
- Other changes for individuals
For individuals, the NBU introduced, in particular, an aggregate monthly limit of the equivalent of UAH 200,000 per bank for purchases of non-cash foreign currency, banking metals without physical delivery, and securities of foreign issuers with delivery through Ukraine's depository system.
A monthly limit of the equivalent of UAH 200,000 applies to payments and transfers for goods, works, services and/or residential rent made from hryvnia accounts. Separate monthly limits apply to certain transactions from foreign currency accounts.
The Resolution is another step in the gradual easing of FX controls, but it does not lift the other restrictions imposed by NBU Board Resolution No. 18.
For additional information, please contact Asters' Partner Roman Stepanenko and Counsel Kateryna Oliynyk.
