In April 2026, the National Bank of Ukraine (NBU) adopted Resolution No. 43 “On Amendments to Resolution No. 18 of 24 February 2022” (the “Resolution”), which entered into force on 25 April 2026. The amendments introduce a further targeted liberalisation of Ukraine’s foreign exchange regime, focusing on selected cross-border payments and regulatory simplifications.
The changes primarily concern defence-related enterprises, military personnel, non-resident individuals, and corporate payments to non-resident management.
- Exemptions for FX purchases by defence-related enterprises
The NBU has eased restrictions on purchase of foreign currency funds by defence-related enterprises which have their own foreign currency funds or receivables. From the date of Resolution, the requirement to use own FX funds shall not extend to:
- funds received from foreign states or their authorised agencies to finance contracts to produce military goods or dual-use goods, where the end recipients are security and defence forces; and/or
- if the purchase of foreign currency is carried out using budget funds for the performance of a state contract aimed at the production of military goods, where the end recipients are security and defence forces.
Who can benefit: Ukrainian enterprises engaged in defence-related production and supply chains under state or internationally funded contracts.
- Transfer abroad of remuneration payments to non-resident professionals
To facilitate the engagement of highly qualified non-resident professionals by Ukrainian companies, the NBU has eased certain conditions for the purchase and transfer of foreign currency.
Ukrainian legal entities are now allowed to make payments to foreign accounts of non-resident members of corporate bodies (supervisory board, board or director, executive bodies), within the amounts accrued under civil law contracts from 1 May 2026 onwards.
In addition to the above, non-resident employees are now permitted to purchase and transfer abroad foreign currency funds in the amount of remuneration payments credited to their UAH-denominated accounts with Ukrainian banks from 1 May 2026 onwards, including:
- salary and other employment-related payments received under Ukrainian labour law
- remuneration under civil law contracts
Who can benefit:
- Ukrainian companies engaging non-resident professionals, including board members or executives
- non-resident individuals receiving salary or employment-related payments in Ukraine
This exemption should generally facilitate engagement of qualified non-resident professionals by Ukrainian companies. The NBU also envisages that banks, acting as currency supervision agents, will monitor such transactions on a risk-based basis to ensure compliance with Ukrainian law, including foreign exchange regulations.
- Payments to military personnel
Military personnel who are non-residents may now transfer abroad foreign currency received as monetary allowance, subject to the following conditions:
- the funds that are credited to such individuals’ accounts from 1 May 2026 onwards may be transferred without limits
- a monthly limit of UAH 400,000 equivalent will apply to funds credited prior to 1 May 2026
In addition, NBU allowed certain payment transfers to/by military personnel of the Armed Forces of Ukraine with residency of Russian Federation or Republic of Belarus.
For the duration of martial law, the NBU also clarified the document requirements for identifying and verifying military personnel in the procedure of opening accounts with banks or non-banking payment service providers. This applies to members of the Armed Forces of Ukraine, persons conscripted to the Armed Forces of Ukraine and other military formations during a special period, as well as persons engaged in defence-related works.
- Cross-border transfers under the state support programme for Ukrainians abroad
The NBU has introduced a new permitted category of cross-border transfers – payments for implementation of the state programme aimed at supporting Ukrainians abroad and facilitation of their return to Ukraine.
Transfers in foreign currency are now permitted to be made abroad by a legal entity in which the state of Ukraine directly or indirectly holds 100% ownership, provided that such transfers are financed from the State Budget and are made for the purposes of supporting Ukrainians abroad and facilitating their return to Ukraine.
That being said, the NBU continues the gradual easing of selected foreign currency restrictions in Ukraine. At the same time, a significant number of FX restrictions remain in place, and transactions continue to be subject to ongoing regulatory oversight under the applicable framework.
For further information, please contact Asters' Partner Roman Stepanenko or Counsel Kateryna Oliynyk.
