Why the National Bank Is Changing the Rules
The National Bank of Ukraine (NBU) has launched a package of “stimulating currency-liberalisation” measures designed to draw new foreign capital into the country while easing the multi-billion-dollar FX debt overhang that weighs on Ukrainian companies.
The Core Idea: An “Investment Limit”
From 12 November 2025 every dollar or euro that a non-resident investor contributes to a company’s statutory capital counts toward an investment limit. Inside that limit the firm gains permission to perform FX transfers that have been largely forbidden since the start of Russia’s full-scale invasion.
Four Legacy Debts That Can Now Be Paid
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Import arrears on goods delivered before 23 February 2021
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Undelivered-goods prepayments made to non-residents before 23 February 2022
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“Old” external loans contracted before 20 June 2023
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Funding of foreign representative offices within new NBU caps
All transactions must run through a single Ukrainian bank selected by the company.
Why It Matters
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Ukraine’s corporate sector owes roughly US $21 billion on long-dated foreign loans and US $3.2 billion on unresolved import contracts.
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Allowing repayments only when matched by fresh equity inflows ensures the FX market does not face one-sided capital outflows.
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The mechanism gives global investors confidence that profits and debt service can legally leave the country, a key hurdle to re-entering Ukraine during wartime.
Additional FX Liberalisation Steps
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Higher limits on corporate card withdrawals abroad
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Permission to pay shipping fees to foreign carriers under import-export contracts
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Green light for forward FX contracts, helping businesses hedge currency risk
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Simplified payment of consular fees at border crossings
Closing the Loopholes
To protect the hryvnia and prevent capital-flight schemes, the NBU simultaneously:
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Banned banks from ending FX supervision of import contracts once hryvnia payments are booked
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Extended the existing UAH 500,000 monthly card limit for overseas spending to a wider list of merchant codes, cutting off back-door FX transfers
Bottom Line
The new investment-for-currency swap gives foreign partners a clear incentive to inject fresh capital, while Ukrainian firms finally gain a pathway to settle frozen hard-currency obligations. If adopted at scale, the policy could relieve pressure on the FX market and accelerate Ukraine’s post-war recovery.
