Currency trap for Ukrainians abroad: why the NBU limits of 2022 became a problem in 2026

For over four years, the Ukrainian financial system has been operating under a special period regime regulated by the National Bank of Ukraine (NBU) Board Resolution No. 18 dated February 24, 2022. Despite gradual liberalization for businesses and the defense sector, restrictions for individuals residing abroad remain among the strictest.

Millions of Ukrainians abroad continue to work for the Ukrainian economy, paying taxes to the budget. However, they remain hostages to currency restrictions introduced in the early days of the full-scale invasion. But do the four-year-old limits correspond to the realities of housing and food prices in Europe in 2026?

Card payments

For most Ukrainians who have been living or working abroad since the start of the full-scale war, the main payment instrument remains hryvnia bank cards, to which they receive salaries or other income from Ukraine. At the same time, the current currency restrictions of the National Bank of Ukraine set limits on cashless payments outside Ukraine.

In particular, for personal hryvnia payment cards, the maximum volume of cashless transactions (P2B — payment to business) is 100,000 UAH per calendar month from all client accounts opened in one bank. For corporate (business) cards, this limit is set at 150,000 UAH per month. At the same time, these restrictions do not apply to cards opened directly in foreign currency — transactions from foreign currency accounts can be made without such limits.

In practice, this creates difficulties for Ukrainians who have been living abroad for a long time but continue to receive salaries or other payments in hryvnia. This primarily concerns employees who work remotely for Ukrainian employers, individual entrepreneurs, and other categories of citizens whose income is credited to hryvnia accounts in Ukrainian banks.

At current price levels in most European Union countries, a significant part of the monthly limit may already be taken up by rent payments. In many cities, the average cost of renting an apartment exceeds 800–1,500 EUR per month, which at the current exchange rate often approaches or even exceeds the limit set by the National Bank. As a result, a person is forced to spend their entire cashless limit only on rent, remaining unable to pay for groceries, medicine, children's education, or utilities cashlessly.

That is why the currency restrictions introduced by the National Bank in the first months of the full-scale war as a temporary measure to stabilize the currency market and protect Ukraine's international reserves are increasingly becoming a subject of discussion in 2026 regarding their compliance with current economic conditions and the needs of Ukrainians who have been abroad for a long time but continue to maintain economic ties with Ukraine.

Cash withdrawal deficit: the 12,500 rule

The situation with cash withdrawals from foreign ATMs is even more complicated. According to paragraph 5-2 of Resolution No. 18:

• Cash withdrawals from all hryvnia accounts are allowed in an amount not exceeding the equivalent of 12,500 UAH every seven calendar days.
• For business cards, this limit is 17,500 UAH per seven days.

In fact, this means that during a month, the owner of a personal hryvnia card can withdraw approximately up to 50,000 UAH in cash, depending on the number of seven-day periods in the calendar month and the official exchange rate. Converted to euros, this is about 1,100–1,200 EUR.

For Ukrainians who have been living abroad for a long time and mainly use hryvnia accounts, such restrictions may have practical significance. In some countries, certain payments — including rent, medical services, small purchases, or household expenses — are still made in cash or require its use. In addition, the need for a significant amount of cash may arise during relocation, signing a lease agreement, making a deposit payment, or other unforeseen expenses.

Under such circumstances, the weekly limit set by the National Bank may restrict the ability to promptly obtain the necessary amount of funds. This especially applies to citizens who receive income exclusively to hryvnia accounts in Ukrainian banks and have no alternative sources of funding or foreign currency accounts.

Currency purchase: limited access to own funds

Separate restrictions are also set for purchasing foreign currency with hryvnia. Although Ukrainians who have been living abroad for a long time often seek to convert their income into the currency of the country of residence, the current rules of the National Bank significantly limit this possibility.

In particular, without providing additional supporting documents, an individual can purchase non-cash foreign currency credited to their own current foreign currency account only within 50,000 UAH per month in one bank. Thus, even if there are sufficient funds in the hryvnia account, a citizen cannot freely convert them into foreign currency for use abroad beyond the established limit.

The National Bank also allows currency purchases for a larger amount — up to 200,000 UAH per month — but only through a special mechanism with subsequent placement of funds on a term deposit. Such funds must be obligatorily placed in a bank for a specified period — depending on the program conditions, this is at least three or six months. Until the end of this period, the depositor cannot freely dispose of the purchased currency.

In practice, this mechanism may be effective for long-term savings or protecting funds from currency fluctuations, but it does not solve the needs of Ukrainians living abroad who require regular access to their funds for daily expenses.

This aspect is increasingly becoming a subject of discussion regarding the advisability of maintaining the currency restrictions introduced in 2022, given that a significant number of Ukrainians have been permanently residing outside Ukraine for the fourth consecutive year.

“Quasi-cash” and specific MCC codes

The National Bank introduced a separate group of restrictions for operations that may be used to circumvent currency limits. Starting from September 2024, the NBU tightened control over a number of transactions classified by international payment systems as high currency risk operations or potentially used for capital outflow abroad.

This primarily concerns so-called quasi-cash operations. According to NBU regulations, quasi-cash operations include transactions with assets that are directly converted (exchanged) into cash according to the rules of international payment systems.

This includes: purchasing cryptocurrencies, topping up electronic wallets, buying gift certificates, lottery payments, transfers to bookmakers, and payment of traveler's checks.

Individuals can perform such operations up to 100,000 UAH (equivalent) per calendar month cumulatively from all client accounts opened in foreign currency.

In addition to general restrictions on payments abroad, the NBU singled out groups of goods and services for which special "ceilings" are set when paying with foreign currency cards.

Category “Luxury items”: limit 100,000 UAH

For operations using the following codes, a limit of 100,000 UAH per month from all foreign currency accounts of the client is set:

MCC 5094 — Precious stones and metals, jewelry.

MCC 5944 — Watches, jewelry, and silverware.

MCC 5972 — Coin and stamp shops.

Category “Real estate and professional services”: limit 500,000 UAH

A cumulative limit of 500,000 UAH per calendar month from all foreign currency accounts is set for payment of services under the following codes:

MCC 6513 — Real estate agents and managers.

MCC 7299, 8999 — Other professional and personal services.

MCC 7311, 7392, 7399 — Advertising, consulting, and business services.

MCC 8111 — Legal services.

MCC 8931 — Accounting, auditing, and bookkeeping.

MCC 9399 — Government services.

Direct prohibitions for MCC codes

It is important to note that for certain categories of operations, there is a complete ban on making payments abroad using electronic payment means. In particular, payments using MCC code 6211 (Brokers/dealers in securities) are prohibited.

Banks are also prohibited from making foreign currency transfers received by the client as a loan or credit for the purpose of purchasing securities denominated in foreign currency.

If you are abroad and planning a large payment (for example, legal services or rent through an agency), you need to consider that even if there is currency in the account, the banking system will block the transaction if it exceeds the established limits for the respective MCC code.

Currency restrictions introduced as a temporary measure to save gold and foreign exchange reserves, in the long term, begin to work against the economy. Restricting consumption by Ukrainians abroad leads to people seeking ways to receive income on foreign cards, bypassing Ukrainian jurisdiction. This is a direct threat to future tax revenues.

Editor's Note: Considering numerous appeals from readers and the objective mismatch of limits with the cost of living abroad, “Judicial and Legal Newspaper” sent an official request to the National Bank of Ukraine.

In the request, we emphasized the need to revise the limits on cashless payments for individuals abroad and to differentiate limits depending on the intended purpose.

We continue to monitor the situation and will inform our readers as soon as an official response from the NBU is received. For now, we recommend Ukrainians abroad to diversify accounts across different banks as limits often apply within a single institution.

Subscribe to our Telegram channel t.me/sudua and to Google News SUD.UA, as well as to our VIBER and WhatsApp, Facebook page and Instagram to stay updated on the most important events.