Recent changes
- Resolution No. 105: currency operations through non-bank payment providers; card payment limits abroad clarified
- Resolution No. 90: cash up to UAH 200,000 a day, corporate cards abroad up to UAH 400,000 a month, export contract penalties up to 10 % a year, new Charity limit, transfer of the Investment limit within a group, conference fees up to EUR 1,000
- Resolution No. 43: salaries of non-residents and remuneration of non-resident board members abroad from 01.05.2026
- Resolution No. 35: a separate settlement regime for the United States–Ukraine Reconstruction Investment Fund and DFC Ukraine Subsoil, LLC (para. 6-3)
- Resolution No. 2: the Loan limit, a new loan from a non-resident unlocks payments on legacy debts and dividends
- Resolution No. 166: individual NBU permissions for Defence City residents on a Ministry of Defence request, for operations under international interdepartmental agreements and for acquiring stakes in non-residents (sub-para. 6-1)
- Resolution No. 95: the Donation limit (transfers to the NBU special account for the Armed Forces from 07.08.2025), return of mistaken transfers, loans from “A”-rated banks
- Resolution No. 53: the Investment limit, share capital investments from 12.05.2025 unlock legacy debts and dividends; branches abroad up to EUR 1 million a year
- Resolution No. 56: dividends for periods from 2023 allowed up to EUR 1 million a month (from 13.05.2024), membership fees, leasing and rent
For a fifth year, the cross-border payments of Ukrainian business have been governed by a single document: Resolution No. 18 of the NBU Board of 24.02.2022 “On the operation of the banking system during martial law”. It prohibits currency transfers abroad and the purchase of currency except for the operations on its list, and these are the currency restrictions that business knows as “Resolution 18”. The National Bank of Ukraine (NBU) rewrites that list almost every month: as of 7 November 2026 the version in force on the Rada site is dated 17.09.2026, following Resolution No. 105 of 15.09.2026, the latest amendment as of that date. This page turns the list into a table of the 34 operations that companies and foreign investors need most often, from paying for imports to repatriating dividends and repaying loans: what is allowed (12), what is allowed with conditions or limits (18) and what is not on the list (4). Each row links to the point of the Resolution in the current version on the Verkhovna Rada site and to the resolution that last amended it.
Before you plan a payment
- Whatever is not on the list is prohibited. Para. 14 of the Resolution is drafted as a ban on cross-border transfers with exceptions; para. 12 likewise bans the purchase of currency except for the listed cases, and currency may be bought for permitted transfers only under para. 12(4). If your operation is not on the para. 14 list (the table shows only the most common ones), the bank will not process it, even if it is lawful in peacetime.
- Legal basis. The Resolution was issued under Article 7 of the Law on the National Bank of Ukraine. During martial law other NBU acts apply only insofar as they do not contradict the Resolution (para. 21), so the general rules of Regulation No. 5 (for example, the 365-day settlement deadline) give way to it.
- There is no mandatory sale of export receipts. Resolution No. 18 contains no such requirement (we checked the full text of the version in force as of 7 November 2026), and Regulation No. 5 has not provided for one since 2019. Export receipts must arrive on the resident’s account in a Ukrainian bank within the settlement deadline (para. 14-4), but they need not be sold.
- In our view, “goods” here includes services. The Currency Law refers to the Law on Foreign Economic Activity, where goods are products, works, services, intellectual property rights and other non-property rights. In our view, payments for imported services, works and licences therefore follow the same row as goods.
- Four “pocket” limits open what is closed. Legacy loan debts, legacy imports, advances received before 23.02.2022 and dividends above EUR 1 million may be paid within the amounts that the company or its group has brought into Ukraine: foreign investments in share capital since 12.05.2025 (the Investment limit), transfers to the NBU special account for the Armed Forces since 07.08.2025 (the Donation limit), donations to military units since 10.08.2026 (the Charity limit) and new loans from non-residents from 2026 (the Loan limit). See the separate section below.
- The dates in the conditions matter. 23.02.2021 (delivery under imports), 23.02.2022 (advances), 01.01.2023 (dividends), 20.06.2023 (loans) and 01.01.2026 (the Loan limit) divide operations into “old” and “new”. Before promising a partner a payment, check which side of the date your contract falls on.
- The bank checks the documents. A transfer goes through only on documents confirming the basis of the operation (currency supervision under Regulation No. 8); most limit-based operations go through one chosen bank, and a change of bank requires a written request. Bought currency must be used within two business days (para. 12-9); the purchase application contains an instruction to the bank to sell any unused currency (para. 44 of Section IV of Regulation No. 5).
- The list does not replace sanctions screening. An operation permitted by the Resolution still passes the bank’s check of the counterparty under the Law on Sanctions and anti-money-laundering review; if the counterparty or its owner is on a sanctions list, the transfer will not go through whatever the point of the Resolution.
- The Resolution changes often. The date in the “Last amended” column shows when the NBU last touched the relevant point. We check the page against the current version on the Rada site; if your payment is near the edge of a condition, check the point via the link on the day of payment.
Table: 34 business operations with non-residents
Operations are grouped by subject; the “Basis” column gives the point and sub-point of Resolution No. 18 in its current version; “Last amended” is the NBU resolution that last changed that point, linked to its record on the Rada site.
How to read: “yes” — the operation is on the list of permitted operations without material restrictions; “with conditions” — permitted on the conditions or within the limits in the “Conditions” column; “no” — the operation is not on the list (only an individual NBU permission is possible) or is expressly prohibited. Amounts in hryvnia and euro are as in the Resolution; equivalents are calculated at the official rate on the day of the operation.
- Before you plan a payment
- Table of operations (34)
- The four “pocket” limits
- What is not here
- How we can help
Trade with non-residents
| Operation | Allowed | Conditions and limits | Basis in Resolution No. 18 | Last amended |
|---|---|---|---|---|
| Payment for imported goods, works, services and IP rights | yes | Delivery (provision) after 23.02.2021; includes fines, penalties, bonuses and reimbursement of costs under the contract. Buying currency for such payments is allowed (para. 12(4)). Goods paid in advance must be delivered within 180 days (para. 14-2). In our view, “goods” here has the meaning given by the Law on Foreign Economic Activity: products, works, services and intellectual property rights. | para. 14(2) | Resolution No. 4 (of 13.01.2025) |
| Payment for imports delivered before 23.02.2021 (legacy debts) | with conditions | Only within the “pockets”: the Investment limit (sub-para. 57), the Donation limit (62), the Charity limit (62-1) or the Loan limit (41-1), see the rows below; or where a foreign export credit agency or foreign state took part in the transaction, up to 10 % per month of the debt overdue as at 01.11.2024 (sub-para. 2, paragraphs 4–5). | para. 14(2), (41-1), (57), (62), (62-1) | Resolution No. 90 (of 10.08.2026) |
| Refund of an advance to a non-resident for undelivered goods | with conditions | Yes, where the advance was received on an account in Ukraine after 23.02.2022 and the resident failed to perform the contract (sub-para. 2-3). Advances received on or before 23.02.2022 may be refunded only within the Investment, Donation, Charity or Loan limit (sub-para. 57). | para. 14(2-3), (57) | Resolution No. 90 (of 10.08.2026) |
| Fines, penalties, bonuses and reimbursements under an export contract | with conditions | Up to 10 % per calendar year of the value of goods delivered to the non-resident under that contract after 23.02.2021. | para. 14(65) | Resolution No. 90 (of 10.08.2026) |
| Payments under leasing and rental agreements | yes | For legal entities and sole traders, with no cap on the amount. | para. 14(24) | Resolution No. 56 (of 03.05.2024) |
| Remitting proceeds to a non-resident principal (commission, agency or mandate agreement) | yes | Proceeds from sales since 24.02.2022 of goods, works or services of the non-resident principal. | para. 14(31) | Resolution No. 56 (of 03.05.2024) |
| Return of funds credited by mistake | yes | Funds credited since 07.08.2025; up to the amount credited by mistake; within three business days of the non-resident bank’s notice. | para. 14(61) | Resolution No. 95 (of 05.08.2025) |
| Repayment of a grant to the grantor | yes | Repayment under the grant agreement: to foreign governments, foreign institutions with state participation, intergovernmental funds set up by foreign countries, or a non-resident legal entity authorised to administer UN grants. | para. 14(25-1) | Resolution No. 90 (of 10.08.2026) |
Investment and dividends
| Operation | Allowed | Conditions and limits | Basis in Resolution No. 18 | Last amended |
|---|---|---|---|---|
| Dividends to a foreign investor | with conditions | Since 13.05.2024. Dividends for periods starting 01.01.2023 (not out of retained earnings of earlier periods or reserve capital); up to EUR 1,000,000 per calendar month per issuer through the NBU “E-limits” system; the issuer has operated for at least 12 months (after a conversion, the predecessor’s period counts); the investor has held the shares for at least 6 months; the issuer itself remits to the investor’s account abroad or via the depository system. The limit is tracked in the NBU “E-limits” system: the issuer’s bank sends a request, the NBU confirms the operation automatically if it is within the limit, and the bank makes the transfer no later than the next business day (paras 95 and 97 to 106 of Regulation No. 5). Currency may be bought for the payment. | para. 14(46) | Resolution No. 90 (of 10.08.2026) |
| Dividends above EUR 1 million a month | with conditions | Within the Investment limit, the foreign investments in share capital received from abroad since 12.05.2025 (sub-para. 57; since 10.08.2026 the limit may be passed to a related company of the group); the Donation limit, transfers to the NBU special account for the Armed Forces since 07.08.2025 (62); the Charity limit, charitable donations since 10.08.2026 whose final recipients are military units of the Armed Forces and the National Guard, under Big Four-audited accounts (62-1); the Loan limit, proceeds of new loans from non-residents from 2026 (41-1). Special cases via the group’s Eurobond coupons (46-1 to 46-3). | para. 14(41-1), (46-1)–(46-3), (57), (62), (62-1) | Resolution No. 90 (of 10.08.2026) |
| Repatriation of an investment: sale of shares, exit, capital reduction | no | Not in the list of permitted transfers in para. 14. Only an individual NBU permission on the basis of a Cabinet of Ministers order is possible (sub-para. 6). | para. 14 (the list), sub-para. 6 | Resolution No. 46 (of 19.04.2024) |
| Coupon income on domestic government bonds to a foreign investor | yes | Coupon paid after 01.04.2023; the bonds were held for at least 90 consecutive days in the account of the investor, nominee holder or foreign depository bank. | para. 14(21) | Resolution No. 68 (of 19.05.2023) |
| Outbound investment, buying shares in non-residents | no | Not in the para. 14 list. Exception: Defence City residents under an individual NBU permission requested by the Ministry of Defence, where the operation relates to an international interdepartmental agreement or to acquiring a stake in a non-resident (sub-para. 6-1). | para. 14 (the list), sub-para. 6-1 | Resolution No. 166 (of 30.12.2025) |
Loans from non-residents
| Operation | Allowed | Conditions and limits | Basis in Resolution No. 18 | Last amended |
|---|---|---|---|---|
| New loans from non-residents (received after 20.06.2023) | with conditions | The funds must come from abroad into the borrower’s account in Ukraine. Interest, fees and other payments are allowed if, in total, they do not exceed payments at 12 % per annum (paras 19-6, 19-7). Principal: on a loan of up to one year, only from the borrower’s own currency; over one year, in the first year only from own currency. Not before the payment date in the agreement (para. 19-5). | para. 14(43); paras 19-5 to 19-7 | Resolution No. 2 (of 13.01.2026) |
| Loans received on or before 20.06.2023 | with conditions | Interest: the payment date falls after 24.02.2022 and there were no arrears as at 24.02.2022; interest overdue as at 01.05.2024, up to EUR 1,000,000 per quarter per agreement (sub-para. 28). Principal: only within the Investment, Donation, Charity or Loan limit (sub-paras 57, 62, 62-1, 41-1), on loans involving an international financial institution (IFI) or an export credit agency (42), or from a foreign bank rated at least “A” with IFI participation (42-3). | para. 14(28), (42), (42-3) | Resolution No. 95 (of 05.08.2025) |
| The “Loan limit”: a new loan as a key to legacy debts | with conditions | A loan from a non-resident (not an IFI), all tranches of which were granted after 01.01.2026 and came into Ukraine, allows payments within the amount received for the purposes of sub-para. 57: legacy loan debts, legacy imports and advances, maintenance of offices abroad, dividends. Repayment of principal within the remainder of the loan. Through one bank. | para. 14(41-1); para. 19-8 | Resolution No. 2 (of 13.01.2026) |
| Guarantees and sureties for non-resident loans | with conditions | A resident surety may pay for the borrower on loans for which transfers are permitted (sub-para. 42-2). A non-resident guarantor is reimbursed only on loans involving an IFI or an export credit agency (42-1) or an “A”-rated bank with IFI participation, from the resident’s own currency (42-4). | para. 14(42-1), (42-2), (42-4) | Resolution No. 95 (of 05.08.2025) |
| Early repayment of a loan to a non-resident | no | Not before the latest payment date in the agreement; shortening the terms is prohibited. Exception: set-off against the non-resident’s contribution to the borrower’s share capital. | para. 19-5 | Resolution No. 2 (of 13.01.2026) |
Branches, representative offices, staff
| Operation | Allowed | Conditions and limits | Basis in Resolution No. 18 | Last amended |
|---|---|---|---|---|
| Maintaining branches and representative offices abroad | with conditions | Up to EUR 1,000,000 per calendar year (plus the 2021 volume for units opened before 24.02.2022); up to a quarter of the annual amount per month; only own (not bought, not borrowed) currency; through one bank; the company has operated for at least 12 months; against a cost estimate. | para. 14(30) | Resolution No. 53 (of 09.05.2025) |
| Remuneration of non-resident board or executive members to accounts abroad | yes | Payments under civil-law contracts accrued since 01.05.2026. | para. 14(36-2) | Resolution No. 43 (of 23.04.2026) |
| Transfer abroad by a non-resident of salary received in Ukraine | yes | Salary and other payments under the Law on Remuneration of Labour received on an account in a Ukrainian bank since 01.05.2026; through the same bank. | para. 14(36-1) | Resolution No. 43 (of 23.04.2026) |
| Transfers by representative offices of non-residents to the head company | with conditions | Representative offices of foreign airlines and card payment systems, up to EUR 5,000,000 per month through one bank (sub-para. 48). Other representative offices, only proceeds of sales of goods paid for with IFI funds (sub-para. 41). | para. 14(41), (48) | Resolution No. 56 (of 03.05.2024) |
Other payments abroad
| Operation | Allowed | Conditions and limits | Basis in Resolution No. 18 | Last amended |
|---|---|---|---|---|
| Arbitration, court and registration fees abroad; advances on costs; enforcement proceedings | yes | For claims in international arbitration and foreign courts and for enforcement abroad (sub-para. 34); cases at the ICAC and the Maritime Arbitration Commission at the Ukrainian CCI (sub-para. 29). | para. 14(29), (34) | Resolution No. 53 (of 09.05.2025) |
| Membership fees to international organisations | yes | No cap on the amount since 03.05.2024. | para. 14(35) | Resolution No. 56 (of 03.05.2024) |
| Fees for protecting IP rights abroad, foreign patent attorneys | yes | Fees of foreign patent offices and services of patent attorneys abroad. | para. 14(53) | Resolution No. 83 (of 09.07.2024) |
| Registration fees for conferences and scientific events | with conditions | Up to EUR 1,000 per event. | para. 14(66) | Resolution No. 90 (of 10.08.2026) |
| EU VAT for Ukrainian e-commerce sellers | yes | For companies and sole traders registered for VAT in an EU country, to the budget of the country of registration. | para. 14(55) | Resolution No. 108 (of 06.09.2024) |
| Reinsurance with non-residents | with conditions | The reinsurer is rated at least A3 (Moody’s) or A- (S&P, Fitch, A.M. Best); the insurer is on the NBU list; some classes (credit insurance, legal expenses, motor third-party liability and others) are excluded. Green Card, aviation risks, the nuclear pool and telecoms are permitted separately. | para. 14(16)–(19-1); paras 14-8 to 14-18 | Resolution No. 43 (of 23.04.2026) |
Buying currency, cards, cash
| Operation | Allowed | Conditions and limits | Basis in Resolution No. 18 | Last amended |
|---|---|---|---|---|
| Buying foreign currency by a company | with conditions | Only for operations permitted by para. 14 (para. 12(4)), with a few exceptions. Bought currency must be used within two business days (para. 12-9). The bank will not buy currency if the client already holds the equivalent of UAH 400,000 or more in foreign currency (paras 12-12, 12-16). Business trips: per diems up to EUR 80 a day plus accommodation and transport per calculation per person; the currency is credited to the foreign-currency account used with the corporate card (para. 12(14)). | para. 12(4), (14); paras 12-9, 12-12, 12-16 | Resolution No. 105 (of 15.09.2026) |
| Corporate cards abroad | with conditions | Payments for goods, works and services: up to UAH 400,000 a month from hryvnia accounts; from foreign-currency accounts without limit. Cash withdrawals abroad from hryvnia accounts, up to UAH 140,000 a month (para. 5-2). International cargo carriers are exempt from the hryvnia limit. | para. 14(8); para. 5-2 | Resolution No. 105 (of 15.09.2026) |
| Cash from company accounts in Ukraine | with conditions | Hryvnia, up to UAH 200,000 a day (except salaries and social payments); foreign currency, up to the equivalent of UAH 200,000 a day. | paras 3, 5 | Resolution No. 90 (of 10.08.2026) |
| Settlement deadlines for exports and imports | with conditions | 180 calendar days for transactions since 05.04.2022 (the general 365-day rule of Regulation No. 5 is suspended for the duration of martial law). Not applied to transactions below the threshold of Article 20 of the Anti-Money Laundering Law. Export receipts must be credited to the resident’s account in a Ukrainian bank (para. 14-4). Set-off does not close currency supervision, except for telecoms and reinsurance (para. 14-6). Exceptions for particular goods and sectors are set by the NBU on a Cabinet submission (para. 14-3; Article 13(1) of the Currency Law); for individual transactions the Ministry of Economy may extend the deadline by an opinion (Article 13(4) of the Law). | paras 14-2 to 14-4, 14-6 | Resolution No. 22 (of 16.02.2024) |
Prohibitions and exceptions
| Operation | Allowed | Conditions and limits | Basis in Resolution No. 18 | Last amended |
|---|---|---|---|---|
| Operations with persons in Russia and Belarus, in roubles | no | All currency operations in Russian or Belarusian roubles, with persons registered or permanently resident in Russia or Belarus, and in performance of obligations to them are prohibited (para. 17). Debit operations on accounts of Russian and Belarusian residents and of companies with such beneficial owners are suspended, with exceptions (para. 15). | paras 15, 17, 17-2 | Resolution No. 43 (of 23.04.2026) |
| Individual NBU permission for a prohibited operation | with conditions | The NBU may permit a single operation on the basis of a Cabinet of Ministers order stating its importance for the state, the amount, the counterparty and the bank (sub-para. 6), and for Defence City residents on a request from the Ministry of Defence for operations under international interdepartmental agreements or acquiring a stake in a non-resident (sub-para. 6-1). The permission must not conflict with the strategy for easing currency restrictions. | para. 14(6), (6-1) | Resolution No. 166 (of 30.12.2025) |
The four “pocket” limits: how they work
Since 2025 the NBU has replaced direct permissions for legacy debts and dividends with a different mechanism: a company earns the right to closed operations within the amount that it or its group has brought into Ukraine. All four limits share the same rules: operations only for the purposes of para. 14(57) (imports delivered before 23.02.2021, refunds of advances received before 23.02.2022, loans received before 20.06.2023, maintenance of offices abroad, dividends), through one bank, on documents proving the inflow. “Loan limit” and “Charity limit” are our labels; the Resolution calls them the “Marginal Amount” (sub-para. 41-1) and the “Limit” (sub-para. 62-1).
- Investment limit (sub-para. 57, since 12.05.2025). The amount of foreign investment in the resident’s share capital received from abroad in foreign currency since 12.05.2025, with proof that the capital increase has been registered. Since 10.08.2026 the limit may be passed, wholly or partly, to a related company under Article 14 of the Tax Code by written consent through the same bank.
- Donation limit (sub-para. 62, since 07.08.2025). The amount of hryvnia (not borrowed) and own foreign currency (not bought, not borrowed) transferred by the company to the NBU special account for the support of the Armed Forces; operations only from own currency. Funds paid under court decisions replacing a preventive measure or under plea agreements do not count.
- Charity limit (sub-para. 62-1, since 10.08.2026). The amount of monetary charitable donations whose final recipients are military units of the Armed Forces and the National Guard, confirmed by financial statements audited by Deloitte, PwC, EY or KPMG; operations only from own currency; the limit may also be passed to a related company.
- Loan limit (sub-para. 41-1, since 13.01.2026). The proceeds of a new loan from a non-resident (not an IFI), all tranches of which were granted after 01.01.2026 to an account in Ukraine, less principal already repaid. Payments within the limit go to the same purposes of sub-para. 57; the loan itself is serviced under the rules for “new” loans (interest up to 12 % per annum, payment dates per the agreement).
Comparison of the limits
| Limit | Source of the amount | What it may be spent on | Transfer to a related company | Point |
|---|---|---|---|---|
| Investment | foreign investment in share capital received from abroad since 12.05.2025 | purposes of sub-para. 57: legacy imports, advances received before 23.02.2022, loans received before 20.06.2023, offices abroad, dividends | yes, since 10.08.2026 | para. 14(57) |
| Donation | hryvnia (not borrowed) and own foreign currency (not bought, not borrowed) transferred to the NBU special account for the Armed Forces since 07.08.2025 | the same purposes, from own currency only | not provided for | para. 14(62) |
| Charity | charitable donations since 10.08.2026 whose final recipients are units of the Armed Forces and National Guard, confirmed by a Big Four audit | the same purposes, from own currency only | yes | para. 14(62-1) |
| Loan | proceeds of a new loan from a non-resident (not an IFI), all tranches after 01.01.2026 | the same purposes; repayment of principal within the remainder of the loan | not provided for | para. 14(41-1) |
What the Resolution itself requires to be documented
The general document package for each operation is set by the bank under Regulation No. 8 (contract, invoice or act, proof of the basis of payment). Resolution No. 18 itself names the following confirmations:
- Investment limit — documents on the inflow of the investment from abroad and registration of the capital increase; for a transfer of the limit, the resident’s written consent (sub-para. 57).
- Charity limit — financial statements with an audit report by Deloitte, PwC, EY or KPMG and documents on the donations (sub-para. 62-1).
- Donation limit — documents on the transfer to the NBU special account (sub-para. 62).
- Loans from non-residents — the agreement’s record in the NBU register “Loan agreements with non-residents”; the bank may not record a shortening of the terms (para. 19-5).
- Dividends via Eurobond payments — documents on the non-resident’s Eurobond obligations and the coupons actually paid (sub-paras 46-1 to 46-3).
- Branches abroad — a cost estimate and proof of the 2021 transfer volumes (sub-para. 30).
- Business trips — a calculation of accommodation and transport costs per person (para. 12(14)).
- Reinsurance — the reinsurer’s rating and the insurer’s inclusion in the NBU list (paras 14-8 to 14-18).
What is not here
- Rules for individuals (transfer limits, purchase of currency by households, cards abroad): they are in the same Resolution, but this page is about business.
- The separate regime for the United States–Ukraine Reconstruction Investment Fund, its representative office and DFC Ukraine Subsoil, LLC: they may settle in hryvnia and foreign currency with residents and non-residents for operations implementing the Agreement establishing the Fund (para. 6-3). These are rules for the Fund, not for its portfolio companies.
- Rules for banks and insurers as regulated institutions (open currency position, government bonds, refinancing).
- Entry-into-force dates of individual amendments: the “Last amended” column gives the adoption date of the amending resolution; see its text via the link for the date it took effect.
- Official NBU explanations of each point: the regulator publishes explanations in its news, but they are not normative; we cite the text of the Resolution.
How we can help
We check whether your payment falls within the list, calculate the available “pocket” limits and prepare the document package for the bank’s currency supervision: for dividends, loans from non-residents, refunds of advances and payments under legacy contracts. See our Foreign Direct Investment Regulation practice.
If you know of a change that is not yet in this reference, let us know and we will update the page.
Related materials
This page is not legal advice. Information as of 7 November 2026; sources are Resolution No. 18 of the NBU Board of 24.02.2022 as amended on 17.09.2026 (Verkhovna Rada and NBU websites), the Law on Currency and Currency Operations, NBU Regulation No. 5 and the records of the amending resolutions on the Verkhovna Rada website.