Annex D. Regulatory Frameworks, Security and Compliance
D3. Currency limits and restrictions
D3. Currency limits and restrictions
Since the introduction of martial law in February 2022, Ukraine has operated a temporary system of foreign exchange controls aimed at safeguarding financial stability. Importantly for investors, the National Bank of Ukraine (NBU) has been consistently and gradually easing these restrictions, with a clear policy focus on restoring normal cross‑border capital flows as macroeconomic conditions allow.
General Approach
Foreign exchange regulation in Ukraine is currently based on a managed liberalization model. Cross‑border payments are permitted where they support legitimate business activity, foreign investment, external financing, and international trade, subject to defined safeguards. The regulatory framework remains transparent and rule‑based, with updates implemented through NBU resolutions to reflect improving market conditions.
Dividend Repatriation
Ukraine allows the repatriation of dividends to foreign investors accrued from business activity starting from January 1, 2023. These payments are permitted within established monthly limits (currently set at EUR 1 million per month per issuer, though subject to progressive expansion by the NBU). This mechanism applies to both direct and portfolio investors and is intended to reinforce investor confidence while maintaining foreign exchange market balance.
Additionally, simplified procedures exist for the repatriation of funds related to new foreign equity contributions, providing additional flexibility for those increasing their investment presence in Ukraine.
Cross‑Border Loans and Financing
Foreign loans remain a vital financing tool for Ukrainian businesses. Current regulations differentiate between "historic" debt and new financing:
New Loans: Broader repayment and servicing options are available for financing received after June 20, 2023.
International Support: Loans supported by international financial institutions (IFIs) such as the EBRD, export credit agencies (ECAs), or highly-rated foreign banks enjoy significant exemptions, allowing for more flexible interest and principal repayments.
Debt Servicing: The NBU has introduced a framework that allows companies to service external debt more effectively, especially where repayment is linked to new foreign capital inflows.
Trade Settlements and Operational Payments
The NBU continues to normalize import and export settlements. While standard time limits for settlements (currently 180 days) generally apply to prevent capital flight, targeted exemptions exist for essential trade operations and the return of pre-war advance payments. Furthermore, the process for returning mistakenly credited foreign funds has been simplified, reducing operational risks for foreign counterparties.
Currency Risk Management
Recent regulatory changes have expanded the availability of FX forward instruments for businesses. This allows companies to hedge currency risks related to imports and other commercial transactions, aligning Ukrainian practice more closely with international standards and improving predictability for investors operating in multiple currencies.
Latest Liberalization Package (effective 11 August 2026) – what it means for investors
NBU Board Resolution No. 90 dated 10 August 2026 (amending Resolution No. 18) further widens cross-border payment capacity for foreign-owned businesses:
Contractual payments to non-residents: exporters may now pay penalties, late-payment interest, bonuses and certain compensations to foreign counterparties (within a 10% cap) — removing a long-standing obstacle to applying standard commercial terms in supply and offtake contracts with international partners.
Additional transfer allowance ("stimulating liberalization"): a supplementary cross-border transfer limit formed, in particular, on the basis of qualifying charitable donations — an extra lawful channel for transferring funds abroad above the standard caps.
Direction of travel: the package confirms the NBU's staged roadmap towards free movement of capital — the key signal for investors planning market entry, financing and exit.
Outlook for Investors
Foreign exchange restrictions in Ukraine are temporary, adaptive, and subject to a publicly stated "Roadmap of Monetary Policy Liberalization." For foreign investors, the current framework already enables: