In July 2026, the National Bank of Ukraine (NBU) carried out a major update of the regulatory framework governing the financial system amid the ongoing war. The regulator focused on two seemingly opposite vectors: tightening the fight against financial schemes and simplifying procedures for ordinary clients. Experts note that these steps are aimed at harmonizing the Ukrainian banking system with European standards while maintaining stability in the face of war-related risks.
Fighting "wrappings" and shadow schemes
One of the key areas of change was increased attention to financial monitoring. In July, the NBU issued a special letter drawing banks' attention to specific schemes used to evade taxes and launder income from the "grey" zone. These are the so-called "wrappings" and "counter-flows" — manipulations often used to create fictitious tax credits.
It is important to note that the regulator is not introducing mass restrictions for all clients. As Dilyara Mustafaeva, Head of the Analytical Department of CEIP "Financial Pulse," explained, the new recommendations require banks to assess not individual payments, but a combination of factors. The decisive factor remains the correspondence of financial activity to the client's actual business operations. This means that control will become more targeted and specific, focusing on suspicious combinations of signs rather than formal indicators.
Simplification of identification and accessibility of services
Alongside strengthening control over businesses, the NBU has significantly simplified procedures for individuals. According to Resolution No. 81, banks are now authorized to assist clients with identification and verification procedures if they cannot do so themselves due to physical or other objective reasons. This is particularly relevant in wartime conditions, when people may be in combat zones or have health limitations.
"The general logic of the July changes is quite clear: control must be strengthened where there are justified risks of using the banking system in illegal schemes, but become simpler and more accessible where a person faces physical, territorial, or other objective obstacles," noted Dilyara Mustafaeva. This approach allows the NBU to balance between financial security and inclusivity, bringing the Ukrainian model closer to the European one.
Update of banking supervision and reporting
Financial monitoring was just one of three key areas of change. By Resolution No. 77, the NBU updated the procedure for assessing bank stability and improved risk-oriented banking supervision (SREP). This will allow the regulator to more effectively monitor risks and ensure the stability of the banking system.
In addition, by Resolution No. 75, the regulator extended the test period for calculating the minimum size of exposures weighted by credit risk. Banks will submit reports under the new rules from November 1, 2026, instead of the previously planned August 1. This decision will give banks additional time to adapt to new requirements and prepare the necessary systems.
Foreign exchange regulation and business support
Special attention was paid to foreign exchange regulation and the work of banks under martial law. By Resolution No. 79, the NBU allowed Ukrainian postal operators, express carriers, and international logistics companies to transfer currency abroad to pay customs duties, taxes, and fees related to the delivery of parcels to European Union countries. This is an important decision to support foreign economic activity and logistics.
Also, by Resolutions No. 78 and No. 80, the regulator clarified the rules for assessing the financial condition of borrowers, updated the procedure for determining territories where banks may temporarily suspend the operation of certain departments, and relaxed requirements for accounting non-core assets when calculating bank capital. These measures are designed to prevent circumstances caused by the war from artificially worsening the regulatory indicators of banks.
Contradictory data
Despite the generally positive assessment of the changes by experts, there are disagreements within the financial community regarding some aspects of the reforms. In particular, the Minister of Finance of Ukraine, Serhiy Marchenko (the source mentions Hetsmanets, but in the context of 2026, this could be a typo or a name change), stated that new financial monitoring rules for politically exposed persons (PEPs) may not work due to the NBU's position. This creates uncertainty regarding how effectively measures to combat corruption and money laundering will be implemented.
On the one hand, the NBU emphasizes that its goal is to create a transparent and stable financial system in line with European standards. On the other hand, critics point out that some measures may be insufficiently strict or, conversely, excessively bureaucratic. These contradictions require further monitoring and analysis by the regulator and the public.
