NBU Continues FX Liberalisation: Key Changes for Businesses

On 10 August 2026, the National Bank of Ukraine (NBU) adopted Resolution No. 90, introducing further amendments to the foreign exchange (FX) restrictions established by NBU Resolution No. 18 dated 24 February 2022.

The amendments entered into force on 11 August 2026 and represent another step towards the gradual liberalisation of Ukraine’s FX regime.

Key takeaways

The most relevant changes for businesses include:

• an increase in the daily limit for cash withdrawals in UAH;
• an expanded list of permitted cross-border payments;
• additional opportunities to use the so-called “donation-based” FX limit;
• greater flexibility in the use of the investment FX limit by related Ukrainian companies;
• updated rules for certain transactions involving payment cards abroad; and
• an expanded list of transactions that may be carried out under existing FX exemptions.

What has changed for businesses?

1. Higher limit for cash withdrawals

The NBU has increased the daily limit for cash withdrawals in Ukrainian hryvnia from customer accounts from UAH 100,000 to UAH 200,000 per day.

Certain payments, including salary payments and other transactions expressly provided for by NBU Resolution No. 18, remain outside the scope of the general cash withdrawal limit.

2. Expanded opportunities for cross-border payments

Resolution No. 90 expands the list of transactions for which Ukrainian residents may make cross-border payments.

In particular, the amendments allow certain payments under foreign trade agreements, including payments related to penalties, fines, bonuses and reimbursement of expenses or losses, subject to the conditions and limits established by the NBU.

The list of permitted payments has also been expanded to cover certain expenses related to participation in international scientific and professional events, as well as selected transactions in the areas of innovation and defence technologies.

3. New opportunities under the “donation-based” FX limit

One of the more significant developments for Ukrainian businesses concerns the further expansion of the “donation-based” FX limit mechanism.

Under this mechanism, the amount of certain FX transactions that a company may carry out is linked to the amount of funds donated by the company for the needs of Ukraine’s defence.

Resolution No. 90 further expands the opportunities to use such a limit for specified FX transactions.

For businesses, this creates an additional mechanism for carrying out certain cross-border transactions, provided that the relevant charitable contributions are properly documented and all other NBU requirements are satisfied.

4. Investment FX limits may be used by related companies

The NBU has also introduced greater flexibility in the use of the investment FX limit.

The investment limit is linked, among other things, to funds contributed to the share capital of a Ukrainian company by a non-resident investor in foreign currency after 10 May 2025.

Resolution No. 90 allows, subject to certain conditions, a Ukrainian resident company to authorise a related Ukrainian legal entity to use part or all of its available investment FX limit.

This may be particularly relevant for corporate groups where the investment funds are contributed to one Ukrainian entity, while the relevant cross-border transactions need to be carried out by another group company.

5. Updated rules for transactions abroad

The Resolution also updates the rules governing certain transactions carried out by individuals and businesses abroad using payment cards.

The amendments affect, among other things, the applicable limits for certain transactions and the way such limits apply depending on the type of account and the nature of the transaction.

What does this mean for businesses?

Resolution No. 90 does not remove the existing FX restrictions. However, it expands the range of transactions available to Ukrainian businesses and introduces additional mechanisms for conducting cross-border payments.

The changes may be particularly relevant for companies involved in:

1. Cross-border payments Reviewing whether additional payments under foreign trade and other agreements may now be made through Ukrainian banks.
2. Corporate groups Assessing whether investment FX limits may be used more efficiently across related Ukrainian entities.
3. Investment structures Considering how the available investment FX limit may be used in connection with cross-border transactions.
4. Charitable contributions Assessing whether contributions made for Ukraine’s defence may create additional FX capacity under the “donation-based” mechanism.
5. Banking arrangements Reviewing internal procedures and supporting documentation used for cross-border and FX transactions.

Practical considerations

Businesses that regularly conduct FX or cross-border transactions should consider:

• reviewing their current cross-border payment flows;
• identifying transactions that may now fall within the expanded list of permitted operations;
• assessing the potential use of the investment or “donation-based” FX limits;
• where relevant, determining whether an available FX limit can be used by a related Ukrainian entity; and
• ensuring that the documentation supporting the economic substance and purpose of each transaction is available for the servicing bank.

Our view

Resolution No. 90 is another step towards the gradual transition from restrictive FX controls towards a more flexible FX regulatory framework in Ukraine.

For international groups operating in Ukraine, the amendments may provide additional flexibility in structuring cross-border payments, managing FX liquidity and using available regulatory exemptions.

At the same time, the ability to carry out a particular transaction should be assessed on a case-by-case basis, taking into account the transaction structure, the status of the parties, the source of funds, applicable limits and the requirements of the servicing bank.