Lead Signal
Ukraine's National Bank has entered a markedly more assertive enforcement posture toward non-bank payment service providers, even as the same institution presses ahead with a multi-year liberalisation of the country's wartime foreign-exchange controls. In the clearest signal of this shift, the NBU fined EasyPay and City24 — two of Ukraine's largest independent payment-terminal networks — 135 million UAH each following inspections conducted in 2025 and 2026, the largest penalties ever levied in Ukraine's payments sector. The action signals a tightening supervisory posture toward non-bank PSPs specifically, distinguishing the regulator's treatment of independent terminal operators from its historically lighter touch on bank-affiliated payment infrastructure. Yet the enforcement wave arrives against a backdrop of judicial pushback that complicates its durability: Ukraine's Supreme Court has fully overturned an NBU fine against RVS Bank for alleged financial-monitoring violations, ruling that NBU officials had not acted according to constitutional procedure. That precedent — a judiciary willing to strike down NBU sanctions on procedural grounds — creates meaningful litigation risk for the current crop of enforcement actions, including the EasyPay/City24 fines, and suggests the NBU's expanding use of its enforcement toolkit against PSPs may face sustained legal contestation rather than settling into an uncontested new normal.
Other Developments
Ukraine's underlying licensing architecture for payment services has also been clarified this cycle. The Law of Ukraine On Payment Services (No. 1591-IX) was enacted 1 August 2022, but NBU enforcement and liability provisions took effect only from 1 December 2022 pending secondary legislation, correcting an earlier single-date assertion that had conflated enactment with enforcement. NBU Board Resolution No. 81 of 25 July 2025 established a three-tier authorisation regime for non-financial account-information and payment-initiation service providers, with a lighter-touch track available to banks and existing PSPs. Ukraine does not recognise EU passporting, so EU-licensed e-money institutions must obtain a separate Ukrainian NBU licence to operate domestically. The NBU's Office for Financial Services Consumer Rights Protection made Ukraine the 120th country worldwide to protect financial-services consumer rights under a 2019 law, with the NBU itself the 98th central bank to hold this function. A broader payment-accounts safeguarding regime remains at concept stage with no fixed implementation date.
Ukraine's virtual-asset framework continues its slow transition from adopted-but-dormant law toward an operative regime. The 2022 Law On Virtual Assets remains adopted but not in force, pending Tax Code amendments. Draft Bill No. 10225-d passed its first reading in the Verkhovna Rada on 3 September 2025, a material status advance toward a MiCA-aligned two-regulator regime that corrects an earlier baseline treating the bill as merely introduced. A transitional VASP registration deadline of 1 July 2026 applied to providers serving Ukrainian residents before 31 December 2025, and that deadline has now passed with no verified compliance outcome yet sourced. Separately, the NBU's e-hryvnia CBDC project remains in a research phase begun in September 2021, with no public pilot or issuance timeline.
On cross-border capital flows, NBU Resolution No. 95 of 5 August 2025 extended permitted dividend repatriation to dividends accrued from 1 January 2023, previously only from 1 January 2024, capped at EUR 1 million per month via the E-Limits mechanism, a further step in the NBU's progressive unwind of wartime capital controls.
Ukraine's commercial fintech landscape recorded its most significant milestone to date: Fintech-IT Group, developer of the monobank app, achieved unicorn status via a strategic investment from the Ukraine-Moldova American Enterprise Fund, becoming the country's first fintech unicorn. monobank itself serves 9.9 million clients as of September 2025 and ranks as Ukraine's second-largest retail banking platform. monobank has also moved to expand its commercial footprint into merchant acquiring, entering a market estimated at UAH 50-55 billion per month. On the innovation and market-development front, the NBU's open banking regulation became operational on 1 August 2025. That builds on the System of Electronic Payments' upgrade to a 24/7 ISO 20022 real-time gross settlement platform on 1 April 2023, which now services over 99% of Ukraine's interbank payments.
Cross-Monitor Connections
Ukraine's AML/CFT standing remains a Sentinel.gi-fed input to this brief rather than a WPM analytical conclusion. Ukraine is not on the FATF list of strategic AML deficiencies, and its fourth-round mutual evaluation and 2020 follow-up upgraded two FATF recommendations to Largely Compliant, though the country remains in enhanced follow-up. That clean standing sits uneasily alongside a persistent correspondent-banking access constraint, as Western banks continue to cite war-risk compliance costs, sanctions-screening complexity and reputational caution as drivers for reducing or terminating correspondent relationships with Ukrainian banks. That pressure persists independent of the NBU's own FX-liberalisation programme. This corridor-access dynamic has been flagged to the Financial Intelligence Monitor for AML and sanctions-screening analysis beyond WPM's payments-corridor framing.
Outlook
The coming cycles should clarify several open threads. Whether the July 2026 VASP registration deadline under Draft Bill No. 10225-d produced enforcement action, and whether the Cabinet appoints the bill's second virtual-asset regulator, will determine how quickly Ukraine's MiCA-aligned stablecoin regime becomes operative in practice rather than on paper. The durability of the NBU's enforcement wave against non-bank PSPs is also in question, since further judicial rulings following the model set by the RVS Bank reversal could either embolden challenges to the EasyPay/City24 fines or validate the NBU's expanded use of its sanctions toolkit. On FX policy, continued liberalisation via mechanisms like the January 2026 loan-limit facility would extend the corridor-opening trajectory already visible in the dividend-repatriation extension, though correspondent-banking de-risking pressure is likely to persist as a structural constraint on cross-border settlement regardless of domestic policy easing.