The NBU launched the "loan limit": how currency operations for business are changing under the new rules

Starting from January, currency regulation in Ukraine has entered a new stage within the Strategy for easing currency restrictions. The National Bank of Ukraine has introduced a number of changes, the central element of which is the so-called "loan limit". This decision is part of the transition to stages I and II of the Liberalization Roadmap, whose goal is not just to lift prohibitions but to stimulate the inflow of new capital into the country.

How the "loan" limit works

The new limit is formed from foreign currency that actually entered Ukraine as a loan or credit after January 1, 2026. Its size is dynamic: after each principal repayment, the available limit volume decreases by the corresponding amount.

At the same time, interest payments on such loans are allowed even after the limit is fully used. All operations within this mechanism must be carried out through the Ukrainian bank to whose account the funds from the respective loan were credited.

Current practice

According to the official position of the NBU, currency operations within the "loan" limit must be conducted through the servicing bank, to whose account the funds from the new loan or credit were actually received. It is the bank that, within currency supervision, verifies the client's documents, the connection of the payment with the corresponding receipt, and compliance with the limit application conditions.

In fact, this means that the new mechanism does not work as an automatic right to payment but as a compliance model where traceability of funds, contract correctness, and the ability to prove the origin of currency become critical. Additionally, the NBU has embedded a dynamic structure of the limit itself: each repayment of the principal of a new loan reduces the available amount for other operations.

What businesses can use the "loan" limit for

The introduction of the new mechanism will allow companies to carry out a number of cross-border payments that were previously restricted by currency rules.

In particular, businesses will be able to:

• repay loans and credits received before June 20, 2023;
• pay dividends to foreign investors exceeding the current limit of 1 million euros per month;
• pay for imported goods delivered before February 23, 2021;
• return advance payments to non-residents received before February 23, 2022, for goods that were not delivered or were only partially delivered;
• finance foreign branches and representative offices exceeding the established annual limit of 1 million euros.

The NBU notes that the mechanism is intended to help businesses fulfill accumulated obligations to foreign creditors and investors without additional pressure on the currency market.

Requirements for new loans

For a loan or credit to form the basis for the loan limit, they must meet the National Bank's requirements applicable to borrowings attracted after June 20, 2023.

In particular, the maximum interest rate on such loans cannot exceed 12% per annum. In addition, early repayment of the principal before the date specified in the contract is prohibited.

The NBU also set restrictions on the sources of loan repayment. During the first year of using the loan, repayment of the principal is allowed only from the company's own foreign currency. Businesses will be able to purchase currency for such payments only starting from the second year of using the loan.

At the same time, loans provided by international financial organizations or secured by their guarantees or sureties will not form the loan limit.

Benefits for the defense industry and exporters

The National Bank has also introduced separate currency relaxations for enterprises in the defense-industrial complex and exporters.

In particular, for residents of the "Defense City" legal regime, balances of targeted financing received from foreign states and international organizations will not be taken into account when purchasing foreign currency. In addition, such enterprises will be able to obtain individual NBU permits for certain cross-border transfers.

At the same time, the export of insurance services is exempted from the limits on currency settlement deadlines. The same rule will apply to export operations for which the Export Credit Agency has already made insurance compensation.

Simplified currency operations for non-resident military personnel and foreign top managers

The National Bank has also expanded opportunities for currency operations by non-resident individuals.

In particular, non-resident military personnel will be able to purchase foreign currency and transfer it abroad without restrictions within the limits of monetary allowance credited to their accounts after May 1, 2026. For funds received before this date, the monthly limit of 400,000 UAH continues to apply.

Additionally, Ukrainian companies are allowed to purchase foreign currency and transfer it to accounts abroad of non-resident members of supervisory boards and executive bodies within the remuneration accrued from May 1, 2026, under civil law contracts.

This means that for businesses, not only the fact of currency receipt but also proper documentary traceability of funds will be key. In the first months of applying the mechanism, different approaches by banks to confirming the grounds for payments can be expected, so companies should prepare their document packages in advance.

What changes for business

The introduction of the "loan" limit effectively creates a new channel for settlements with non-residents without additional pressure on the currency market. For companies, this means the ability to repay certain old obligations, pay dividends, and carry out other permitted operations using new external loans.

At the same time, this tool does not cancel currency supervision and does not remove the need to confirm each operation. On the contrary, the new model increases the importance of internal control, as the bank will check whether the payment complies with the conditions for using the limit.

The mechanism implies the need to review loan agreements, payment routes, and internal currency control policies. This especially concerns companies that have debt to non-residents or regularly make cross-border payments.

Under such conditions, compliance becomes not a formality but a practical condition for access to currency operations. The clearer the financing structure and the better documented the chain of funds movement, the lower the risks of bank refusal or further claims from regulatory authorities.

Judicial practice and dispute prospects

So far, the new "loan" limit is too fresh a mechanism to talk about established judicial practice specifically regarding its application. However, there is already a significant body of disputes in the field of currency supervision, including penalties for violations of foreign economic settlement deadlines.

The Supreme Court has repeatedly emphasized that liability in currency relations is applied according to the special rules of the Law of Ukraine "On Currency and Currency Operations," and certain grounds for exemption from liability do not work automatically. Therefore, even with new relaxations, businesses should act considering that banks will continue to apply a strengthened compliance approach.

In 2026, currency supervision in Ukraine is increasingly moving to a digital format. For businesses, this means enhanced automated document verification and more careful assessment of operations by banks. A formal approach to confirming cross-border payments is gradually losing significance, while the real economic substance of the operation and the quality of documentary support are gaining importance.

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