August 2025 – On 6–7 August 2025, a new package of changes to currency restrictions in Ukraine came into force. The National Bank of Ukraine (the "NBU") introduced currency restrictions in February 2022, following the onset of Russia’s full-scale invasion.
Below we highlight the key changes introduced by the new amendments.
1. New opportunities for income repatriation
The NBU now allows the transfer of dividends to foreign investors that have accrued since 1 January 2023, compared to the previous rule that allowed dividends for 2024 only. However, such payments remain subject to existing requirements to make the transfer directly to the investor’s foreign account with a monthly limit of EUR 1 million (or equivalent).
Additionally, Ukrainian companies are now allowed to pay dividends to foreign investors within the "investment limit" framework. The “investment limit” was first introduced in the wave of currency reforms in May 2025 and refers to the amount of funds contributed by a foreign investor into the charter capital of a Ukrainian company on or after 12 May 2025.
2. Enabling debt-to-equity conversion
Ukrainian borrowers are now allowed to repay foreign loans early by way of a set-off for the purpose of converting debt into share capital. Previously, such conversions were blocked, as the NBU’s “Credit Agreements with Non-Residents” system did not permit registration of such changes.
By removing this regulatory barrier, the NBU opens the door for Ukrainian companies to convert debt into equity, providing them with a viable mechanism to attract additional capital from foreign investors.
3. Repayment of loans granted by lenders’ consortium including IFIs
Ukrainian borrowers are now entitled to repay loans provided by foreign bank before 20 June 2023 with participation of international financial institutions (“IFIs”) in a lending pool. However, repayment is allowed in favour of foreign banks with a credit rating of no lower than “A” (S&P/Fitch) or “A2” (Moody’s).
Under the new rules, full servicing of such loans is permitted, including repayment of principal, interest payments, and other obligations specified in the loan agreements. Additionally, the NBU has allowed cross-border payments to foreign guarantors, sureties, and insurers that secure the respective loan obligations.
In addition, the NBU has also permitted early repayment of such loans, as well as loans backed by guarantees or sureties issued by IFIs and granted by foreign states (via authorised entities or their subsidiaries), foreign banks with state ownership, or foreign export credit agencies.
4. Expanded options for hedging currency risk
The NBU continues to roll out measures to gradually and safely expand access to currency risk hedging tools for businesses. The latest changes introduce two major instruments:
- Non-deliverable forward
Banks’ clients may now enter into forward contracts without actual delivery of foreign currency funds. Previously, only deliverable forwards were allowed, meaning the physical transfer of funds in foreign currency on the settlement date. Now, when non-deliverable forwards are allowed, clients may benefit from more flexible currency risk management.
- Forwards for import hedging
Ukrainian companies and private entrepreneurs may now enter into deliverable forward contracts for buying foreign currency funds, provided the transaction is aimed at hedging currency risk under import contracts.
However, the total volume of forward contracts providing for a sale of foreign currency by a bank to clients cannot exceed the volume of the foreign currency purchased by the bank from clients under its forward purchase contracts.
5. Refunds to non-residents
The new regulations has authorised both legal entities and individuals to return funds mistakenly transferred from abroad and credited to their accounts in Ukraine starting from 7 August 2025. Banks are now required to process such refunds within three business days upon receiving a notification of the erroneous transfer from the foreign bank.
In addition, maritime agents are now permitted to return unused funds to foreign shipowners or other principals under maritime agency agreements, provided those funds were not utilised under the terms of the contract.
6. "Investment limit" equal to contributions to the Armed Forces of Ukraine
Ukrainian legal entities may now make certain cross-border currency payments in the amount of its own funds voluntarily donated to the NBU’s special account for the needs of the Armed Forces of Ukraine, starting from 7 August 2025.
Within this amount, companies are permitted to:
- repatriate dividends to foreign investors;
- pay for imports of goods delivered before 23 February 2021;
- make payments under foreign loans raised before 20 June 2023;
- finance operations of their foreign branches.
This measure both encourages businesses to support the military effort and grants socially responsible companies certain currency privileges.
Click on the image below or use the following link to read our overview in Ukrainian.