From January 14, 2026, the National Bank of Ukraine introduced another package of FX easing measures for businesses. The centerpiece is a new incentive borrowing limit that links permitted outward FX operations to fresh foreign loan inflows credited to Ukrainian bank accounts after January 1, 2026.
For investors and corporate operators, the changes matter because they create a clearer regulatory path to refinance old external debt, close long outstanding trade obligations, and improve export related risk management without abruptly lifting wartime controls.
What changed in practice
The new borrowing limit equals the amount of foreign currency received under a foreign loan or credit and credited to a company account at a Ukrainian bank after January 1, 2026. Within that limit, a company may carry out a set of previously constrained operations tied to legacy obligations and selected liberalization tools.
- Repay older external loans and credits obtained before June 20, 2023, and pay interest on them
- Settle for imports delivered before February 23, 2021
- Return a nonresident buyer prepayment for goods paid before February 23, 2022
- Finance overseas branches above the baseline cap
- Repatriate dividends above the baseline cap
The NBU also allowed domestic sellers and manufacturers to refund consumers to their foreign bank accounts in FX for returned or undelivered goods, provided the refund goes to the same account used for payment and does not exceed the original purchase value. In export supervision, the NBU clarified that settlement deadlines do not apply to insured export receivables assigned to Ukraines Export Credit Agency within the scope of the compensation, and removed export insurance services from the list subject to such deadlines.
Why it matters for investors and corporates
The borrowing limit is built as a pro inflow mechanism: it encourages bringing new external funding into Ukraine while enabling cleaner restructuring of legacy debt positions. This can improve lender comfort, reduce default risk for borrowers with historical obligations, and make capital structure planning more predictable.
The export clarifications are also material: using ECA insurance and assignment mechanisms can reduce working capital pressure for exporters and improve bankability of contracts, especially when settlement deadlines previously created compliance friction.
Risks and compliance points to watch
Eligibility and execution details remain strict. The related loan parameters must align with the wartime FX framework, including restrictions on early payments and a cap on interest rate levels. Operationally, transactions under the borrowing limit are tied to the bank where the company received the loan, and limit capacity adjusts as principal is repaid.
For deal teams, the practical takeaway is to structure funding, treasury flows, and documentation so that FX permissions are an output of verified inflows rather than a separate exception process.
