National bank of Ukraine Continues its Currency Liberalization
Resolution No. 90 of the Board of the National Bank of Ukraine dated 10 August 2026 introduces a number of changes to the functioning of the monetary and foreign exchange markets under martial law. The amendments are aimed at supporting economic activity and the country’s defence capabilities. In this Legal Alert, we focus on the changes relevant to businesses. At the same time, the document also eased certain restrictions applicable to individuals.
1. Increased limits on cash transactions and the use of corporate payment cards
Under the new rules, the daily limit for the withdrawal of cash in Ukrainian hryvnia has been increased from UAH 100,000 to UAH 200,000.
With regard to payments abroad, legal entities are now subject to a limit of up to UAH 400,000 per calendar month for payments for goods, works and services made using corporate payment instruments from all of the company’s accounts in the national currency.
2. More flexible management of foreign exchange limits within corporate groups through the “Investment Limit”
Resident legal entities may now conduct foreign exchange transactions within their own “Investment Limit” not only directly, but also through related parties.
A resident legal entity’s Investment Limit is determined within the total amount of foreign currency invested by foreign investors in its charter capital starting from 12 May 2025. These funds may be used through one servicing bank to make payments for imports (under contracts concluded before 23 February 2021), refund advance payments received, repay foreign loans (obtained before 20 June 2023), maintain branches abroad, or pay dividends.
An important innovation introduced by Resolution No. 90 is the possibility of transferring this limit, in whole or in part, to other related resident legal entities, provided that the bank is provided with written consent and both companies are serviced by the same bank.
To carry out such foreign exchange transactions, the bank must have documents confirming the actual transfer of the foreign investment for the increase of the resident legal entity’s charter capital, as well as the state registration of such increase.
3. Introduction of the “Donation Limit”
The Donation Limit is determined within the total amount of funds in Ukrainian or foreign currency that the company has transferred, starting from 7 August 2025, to the special account of the National Bank of Ukraine established to collect funds in support of the Armed Forces of Ukraine.
Such transfers must be made exclusively from the company’s own funds, which must not have been purchased (where foreign currency is used) or obtained in the form of loans or borrowings. The transfers must also comply with their designated purpose and be made through one bank.
4. NBU permitted transfers abroad to satisfy financial obligations
Businesses are also now permitted to make transfers abroad to pay fines, penalties, bonuses and compensation for losses under foreign economic contracts for the export of goods.
This right is subject to an annual limit, which may not exceed 10% of the total value of the goods supplied to the non-resident under the relevant contract after 23 February 2021.
Conclusion
The adopted amendments demonstrate the NBU’s continued policy of foreign exchange liberalisation while simultaneously supporting businesses’ foreign economic activities and encouraging assistance to the Armed Forces of Ukraine. The expansion of existing limits and the introduction of mechanisms for their transfer enable companies to manage their capital more efficiently under wartime conditions.