The National Bank of Ukraine (the "NBU") has given the green light to open banking in Ukraine by adopting the relevant Regulation on Open Banking in Ukraine by Resolution of the NBU Board No. 80 on 25 July 2025 (the "Regulation"). Thus, the NBU has taken the final steps towards implementing the provisions of EU Directive 2015/2366 (PSD2) on payment services and Chapter 4 "Procedure for gaining access to user accounts by payment service providers (open banking)" of Section IV of the Law of Ukraine "On Payment Services".
The concept of open banking was approved by the NBU back in 2023, outlining directions for development, a roadmap and main requirements for the implementation of open banking in Ukraine, and since then has been actively discussed between the NBU and the business and fintech community.
What is open banking?
Open banking means a structured and secure data exchange between payment service providers for the purpose of providing services such as initiating payment transactions and providing information from accounts to the users by third-party payment service providers. In fact, this means that banks/other institutions where users hold accounts can provide access to certain data of such users to third-party market participants (fintech companies, application developers, etc.) in order to expand the range and improve the quality of services. The key requirements for open banking are:
- data exchange via specialised interfaces (APIs)
- user consent, as well as user permission to disclose information containing banking secrecy, business secrecy, and payment service provider secrecy
What does the Open Banking Regulation provide for?
The Regulation in particular defines:
- the participants in open banking:
- account servicing payment service providers (banks where users' accounts are opened; non-bank payment service providers where users' payment accounts are opened)
- third-party payment service providers (payment initiation service providers; account information service providers)
- technological operators of payment services that have obtained the right to provide services within the framework of open banking
- users
- the procedure and conditions for provision of access to user accounts opened with account servicing payment service providers to third-party payment service providers
- principles of interaction between open banking participants
- conditions for the provision of non-financial payment services (namely, initiation of payment transactions or provision of account information) to users by third-party payment service providers
- procedure for granting and withdrawing user consent
- principles of use and classification of application programming interfaces (APIs) used in open banking:
- basic interfaces that are publicly available and free of charge and contain a defined standard set of user data. The use of basic interface does not require the conclusion of contracts between account servicing payment service providers and third-party service providers
- commercial interfaces, which may be subject to a fee and contain a larger set of data than basic interfaces (e.g., obtaining complete information about transactions for a specific account/all accounts; obtaining a list of accounts with the balance on a specific date; notifications about certain types/amounts of transactions on accounts); the use of commercial interface is based on an agreement between the above parties
The Regulation, except for certain provisions, came into force on 1 August 2025 and provides for a five-month term for payment service providers to bring their activities into compliance with its requirements.
In addition to the Regulation, on 25 July 2025, the NBU Board also adopted Resolution No. 81 "On Approval of the Regulation on the Procedure for Authorising the Activities of Non-Financial Payment Service Providers and Approval of Amendments to the Regulation on the Registration of Payment Systems, Participants in Payment Systems and Technological Operators of Payment Services" and Resolution No. 82 "On Approval of the Regulation on the Use of Electronic Trust Services During the Provision of Access by Payment Service Providers to the Accounts of Payment Service Users", which also came into force on 1 August 2025.
What to expect from the launch of open banking?
The adoption of the regulatory framework for open banking is expected to have a significant positive effect on users, fintech companies and start-ups, as well as banks and other payment service providers. On the one hand, it will create robust competition in the payment market, and on the other, it will ensure a secure and diverse financial and digital environment. Experts realistically estimate that the active launch of the open banking market is expected by the end of 2026 and will primarily depend on banks' infrastructure readiness to provide access to their APIs, as well as users' interest in new fintech solutions.
It is expected that users will have a wider range of tools to manage their accounts and related data, including analysing their expenses, planning their budget, comprehensively assessing their resources and debts, having information compiled from various banks/institutions, and receiving recommendations and credit or investment products based on the analysis of such data. Open banking will also enable businesses to assess their economic efficiency and cash flow management and will facilitate the automation of accounting and financial processes.
The fintech sector will receive a significant boost to the creation of new digital services and payment products, given its access to a large pool of user data, and the ability to analyse it in targeted or aggregated form to create new platforms and business models.
Open banking for banks provides, in particular, the opportunity to obtain structured information about customers regarding their creditworthiness for adequate assessment of credit risks, attracting new customers through cooperation with developers of new financial services, as well as monetisation through the transfer of certain data to such developers for analysis and creation of new products.
At the global level, the launch of open banking will ensure compliance with the requirements for Ukraine's accession to Single Euro Payments Area (SEPA) and accession to the European Union.
By Iryna Pokanay, Partner, and Inna Bondarenko, Senior Associate, Asters
