On 6 August 2025, amendments to the National Bank of Ukraine's (NBU) Resolution No.18 came into force. Approved by Resolution No.95, they introduced a new stage of foreign currency liberalisation. The changes are intended to support export-oriented enterprises, the jewellery sector, importers and to expand the possibilities for risk hedging operations and the performance of external debt obligations.
Key Changes
- Foreign Currency Hedging for Importers
The NBU has allowed Ukrainian businesses to purchase foreign currency under forward contracts for the purpose of hedging, i.e., protecting against exchange rate risks related to the import of goods, works, services, and intellectual property objects.
What does this mean?
Resident legal entities and individual entrepreneurs may now:
- enter into forward contracts with banks for the purchase of foreign currency with future delivery
- use such currency exclusively to pay for import contracts
- protect themselves against potential currency fluctuations and lock in the exchange rate in advance
What are the conditions?
- forward purchases are permitted only for commercial import operations, which involve further sale or compensated transfer of the imported goods/services
- banks may sell currency under forward contracts only if the total volume of such sales does not exceed the volume of forward purchases of currency by the bank from clients
- physical delivery of currency is mandatory – speculative operations without delivery are prohibited
Why is this important?
This step enables Ukrainian companies to:
- plan foreign currency expenditures and avoid losses due to exchange rate fluctuations
- improve predictability in conducting foreign economic activity
- use financial instruments that are already common practice internationally
The introduction of forward hedging is a significant change in the currency regulation system, balancing exchange market control with business needs for risk management tools.
- Improved Conditions for Repayment of Debts to Foreign Creditors
Foreign currency transfers are now permitted for the following purposes:
- repayment of obligations to foreign banks with a high credit rating (rated “A” or higher)
- servicing of loans in which international financial institutions (IFIs) participate
- settlement of obligations towards a guarantor / insurer / surety, who has fulfilled the debt on behalf of the resident borrower
In all these cases, the use of foreign currency is limited to the resident's own funds (not purchased on the interbank market).
These changes aim to create more predictable conditions for international lending and enhance Ukraine's investment attractiveness.
- Currency Transfers to Strengthen Trust in Ukrainian Companies
The NBU has expanded the list of foreign currency transfer operations abroad aimed at enhancing transparency, predictability and contractual discipline of Ukrainian entities in their dealings with non-residents. In particular:
Return of erroneously credited foreign currency funds. Banks may return mistakenly transferred foreign currency funds if a respective notification from the non-resident bank is received no later than three business days after the transfer.
This reduces the risk of technical errors in international settlements, which is essential for maintaining the business reputation of Ukrainian residents.
Return of unused funds by maritime agents. Ukrainian maritime agents are allowed to transfer back unused foreign currency funds received from non-resident shipowners or other principals under maritime agency agreements. This sends a clear signal to foreign partners regarding the stability and reliability of Ukraine’s port-related operations, even during wartime.
- Incentive-Based Currency Liberalisation: New Opportunities for Business
Within the framework of the previously launched incentive-based currency liberalisation, the NBU continues to expand opportunities for the legal outflow of capital related to investment and charitable activity.
Repatriation of Dividends for 2023. Residents are now allowed to transfer foreign currency to pay dividends to non-residents for the results of 2023, provided that such transfers are carried out within the general monthly limit of EUR 1 million (or equivalent). This enables businesses to partially repatriate profits earned from 1 January 2023 onward (previously allowed only for profits from 2024).
Preferential Currency Transfers for Businesses Supporting the Armed Forces of Ukraine (AFU). Companies that have transferred funds (starting from 7 August 2025) to NBU’s special account in support of the AFU are allowed to carry out additional foreign currency transfers, within the amount of their contribution, for the following purposes:
- settlement by the resident of import contracts for goods delivered before 23 February 2021
- return to a non-resident of advance payments received by the resident before 23 February 2022, under sale-purchase agreements for goods not (or partially) delivered from Ukraine
- servicing of loans obtained before 20 June 2023 from a non-resident under a signed loan agreement
- financing of resident’s expenses for maintaining branches, representative offices, or other separate subdivisions abroad (without legal entity status)
- repatriation of dividends to non-residents on shares or corporate rights
This initiative motivates businesses to take socially significant actions.
Conversion of External Debt into Equity. The NBU has introduced the possibility to reduce the maturity of external loan obligations in case of their conversion into the resident's share capital.
Banks are now authorised to record such transactions in the Automated Information System “Loan Agreements with Non-Residents”. This paves the way to debt restructuring through capitalisation rather than repayment.
- Permission to Purchase Banking Metals for the Jewellery Sector
The NBU has expanded opportunities for businesses operating in the retail trade of jewellery by allowing the purchase of banking metals via bank transfer without delivery.
Who can benefit?
Legal entities and individual entrepreneurs engaged in the retail trade of jewellery.
Eligibility conditions:
- the volume of banking metals purchased must not exceed 1/12 of the total annual volume of jewellery sold in the retail trade sector in 2021, expressed in UAH
- transactions may be conducted only through one authorised bank selected by the client (with a possibility of switching upon written request).
For the first purchase, it is necessary to submit a contract with a jewellery manufacturer providing for the transfer of banking metals to such manufacturer.
For subsequent purchases, additionally a document confirming the actual transfer of banking metals to the jewellery manufacturer in an amount not less than the volume previously purchased in the prior calendar month.
Other documents confirming the grounds for the purchase must also be submitted to the bank upon request.
What are the benefits for business?
- renewal of the regular supply of raw materials for jewellery production that requires banking metals (such as gold, silver)
- stability of production processes in a sector with export potential and added value
- transparent and controlled mechanism for purchasing precious metals, helping prevent speculative transactions
The NBU maintains safeguards in the form of documentation confirming the volume and purpose of the metals purchased, supporting legitimate businesses without exerting pressure on the foreign exchange market.
By Roman Stepanenko, Partner, and Kateryna Oliynyk, Counsel, Asters
