Ukraine’s FX liberalisation is moving into a more practical phase — and this time the most interesting changes are for business.
From 11 August 2026, NBU Resolution No. 90 introduces a new framework that gives Ukrainian companies supporting the Armed Forces of Ukraine and the National Guard additional flexibility for certain foreign-exchange operations.
The key point is not simply “higher limits”.
The NBU is gradually moving away from the 2022 emergency model, where the starting point was effectively prohibition, towards a more structured system based on economic purpose, documented transactions, banking control and defined limits.
For business, several changes are particularly important.
Companies making qualifying charitable donations from their own funds to military units of the Armed Forces of Ukraine or the National Guard may create a special “Donation Limit” for certain FX operations. The mechanism is not a simple one-to-one right to move money abroad: the company must use its own foreign currency, the transactions remain purpose-limited, and the donations must be properly documented.
There is also a significant compliance threshold. The relevant amounts must be supported by financial statements audited by Deloitte, PwC, EY or KPMG. This means the mechanism is likely to be most relevant to medium-sized and large Ukrainian businesses with material international operations and significant defence-support programmes.
For corporate groups, the changes may be even more interesting.
The Donation Limit can, subject to conditions, be used by a related Ukrainian company. The same approach is now applied to the Investment Limit: a related resident company may use it with the written consent of the original holder, provided the relevant operations are carried out through the same bank.
This introduces greater flexibility for holding structures, joint ventures and groups where operating cash flows, investment functions and international activity sit in different legal entities.
Other practical changes include a UAH 400,000 monthly limit for overseas business-card payments for goods, works and services, as well as the ability to pay certain contractual penalties, damages, bonuses and reimbursements under export contracts, subject to a 10% annual cap linked to the value of goods supplied.
For investors, the broader signal is important.
Ukraine is not yet returning to full freedom of capital movement. FX controls, banking supervision, AML/KYC requirements and transaction-purpose restrictions remain in place.
But the regulatory architecture is changing.
The question is gradually becoming less “how do we prevent currency from leaving Ukraine?” and more “what is the economic purpose of the transaction, what are the sources of funds, who is the recipient, and how can the transaction be properly controlled?”
That is an important shift for any investor assessing Ukraine’s medium-term business environment.
Economic recovery requires capital, cross-border investment and functioning international corporate structures. Gradual FX liberalisation is therefore not merely a banking issue — it is part of rebuilding the infrastructure for investment.
And one of the clearest policy signals in this package is that businesses which use their own resources to support Ukraine’s defence are being given additional room for international economic activity.
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