Business expects further liberalisation in 2026: focus on dividends, “legacy” debts and capital market conditions

23/ 01/ 2026

These are the key findings of the third stage of the European Business Association’s survey on current needs for easing currency restrictions. The most pressing needs identified by businesses include: dividend payments (including dividends accrued before 2023), repayment of external loans, and an increase in limits on corporate card transactions. “Incentive-based liberalisation” mechanism The majority of surveyed companies (83%) are not currently using the “incentive-based liberalisation” mechanism and do not plan to do so; 10% are only considering its use, while just 7% already apply it. Regarding the volume of funds attracted or planned by the end of 2025, 86% of respondents have not carried out such transactions. Among those using the mechanism, 7% of companies operate within the range of EUR 500,000–1 million, and another 7% exceed EUR 2 million. Plans for 2026 show a similar trend: 83% do not plan to use the mechanism; 7% are considering amounts of up to EUR 100,000; another 7% are targeting amounts above EUR 2 million; and 3% plan transactions within the range of EUR 500,000–1 million. Dividend payments to non-residents 47% of companies consider dividend payments for the period prior to 2023 to be a relevant need (33% describe it as extremely relevant). In 2024, 69% of companies reported a need for dividend payments for the period prior to 2024. Acceptable payment schedules include: more than EUR 2 million per quarter (20%) and EUR 100,000–2 million per quarter (30%). Dividend payments to non-residents for the period since 2023 in the amount of EUR 2–9 million per quarter are relevant for 30% of companies. Repayment of loans to non-residents (“legacy” debts) Compared to 2024 (51%), the share of companies for which loan repayments to non-residents are relevant increased to 60% in 2025 (43% consider this need extremely relevant). The most demanded range is EUR 100,000–2 million per quarter (53%), while 10% of respondents require the ability to repay more than EUR 2 million per quarter. * Currently, such repayments are allowed within the “incentive” limits (in particular, the “loan limit” introduced as part of the NBU’s currency easing measures of 14 January 2026). Increasing limits for transactions using UAH-denominated corporate payment cards abroad 70% of companies need higher limits for transactions using UAH-denominated corporate cards abroad (60% consider it relevant but not critical; 10% extremely relevant). In 2024, 79% of companies declared a need to increase such limits. Optimal limits are assessed at UAH 150,000–500,000 per month (50%) and UAH 500,000–1 million per month (17%). Given the increase in business travel and related expenses, companies also propose raising limits on FX P2P transfers and lifting restrictions on cash purchases (currently equivalent to USD 80 per day), as these no longer cover employees’ actual needs abroad. Payments for imported goods delivered before 23 February 2021 In 2025, the issue of payments for imported goods and services delivered before 23 February 2021 became more acute: the share of companies for which it is relevant increased from 25% in 2024 to 40% in 2025 (17% extremely relevant; 23% relevant but not critical). The most demanded limits are EUR 100,000–500,000 (23%) and EUR 500,000–2 million (13%). This issue covers both goods and services delivered before 23 February 2021, and for settlements — including import arrears from 2022 — businesses are willing to use their own foreign currency reserves. * Currently, such payments are allowed within the “incentive” limits (including the “loan limit” introduced under the NBU’s currency easing measures of 14 January 2026). Refund of container deposits The issue of refunding container deposits remains niche: it is not relevant for 93% of respondents. The 7% that do have such a need (though not critical) indicate that a limit of EUR 100,000–500,000 would be sufficient. Cross-border payments related to export operations (penalties, fines, etc.) The ability to pay penalties related to export operations is relevant for 43% of companies (10% consider it extremely relevant). For most respondents, a limit of 2–5% of the contract value would be sufficient to mitigate these risks. Completion of currency supervision through set-off The need to complete currency supervision through set-off remains high at 63% (20% extremely relevant; 43% relevant but not critical), compared to 73% in 2024. Sufficient limits include: up to EUR 100,000 per month (23%), EUR 100,000–1 million per month (20%), and over EUR 1 million per month (13%). Companies point to the risk of penalties due to a lack of guarantees from tax authorities and propose simplification mechanisms to reduce administrative pressure. Settlement deadlines for export/import operations Given disrupted supply chains and border blockages, almost half of respondents (47%) consider it necessary to extend settlement deadlines to 360 days, while 180- and 270-day options are supported by 23% and 17% of companies respectively. In this context, businesses propose not only extending revenue repatriation deadlines (particularly for grain), but also exempting exporters from penalties for violations caused by logistical disruptions in 2023. Purchase of foreign currency to meet obligations regardless of available funds The ability to purchase foreign currency regardless of available funds remains consistently important for business: 80% of respondents declare this need (37% consider it extremely relevant), confirming the stable trend observed in 2024 (79%). In terms of desired limits, 50% of companies target UAH 100,000–2 million per month; 27% require UAH 2–5 million; and 7% need amounts exceeding UAH 45 million. Additional measures proposed by businesses in the context of currency liberalisation Businesses also emphasise the need to: Clarify the provisions of NBU Resolution No. 18 to avoid discrimination in dividend payments for companies that have undergone reorganisation (conversion from JSC to LLC). Allow transfers for goods and services without documentary confirmation up to UAH 400,000, significantly reducing the administrative burden on businesses and banks. Enable representative offices to transfer funds to parent companies (up to EUR 1 million per month) and to pay taxes to foreign jurisdictions (up to EUR 30,000 per year). Lift the ban on settlements under provided guarantees and foreign exchange risk hedging operations. Allow fulfilment of obligations under guarantee agreements (leases), repayment of import debts from 2022, and payments for services/guarantees provided before 23 February 2021, as well as payment of overdue interest on loans to parent companies. For reference: The survey was conducted from November 2025 to January 2026 among member companies of the European Business Association. A total of 30 companies participated.

These are the key findings of the third stage of the European Business Association’s survey on current needs for easing currency restrictions.

The most pressing needs identified by businesses include: dividend payments (including dividends accrued before 2023), repayment of external loans, and an increase in limits on corporate card transactions.

“Incentive-based liberalisation” mechanism

The majority of surveyed companies (83%) are not currently using the “incentive-based liberalisation” mechanism and do not plan to do so; 10% are only considering its use, while just 7% already apply it. Regarding the volume of funds attracted or planned by the end of 2025, 86% of respondents have not carried out such transactions. Among those using the mechanism, 7% of companies operate within the range of EUR 500,000–1 million, and another 7% exceed EUR 2 million. Plans for 2026 show a similar trend: 83% do not plan to use the mechanism; 7% are considering amounts of up to EUR 100,000; another 7% are targeting amounts above EUR 2 million; and 3% plan transactions within the range of EUR 500,000–1 million.

Dividend payments to non-residents

47% of companies consider dividend payments for the period prior to 2023 to be a relevant need (33% describe it as extremely relevant). In 2024, 69% of companies reported a need for dividend payments for the period prior to 2024. Acceptable payment schedules include: more than EUR 2 million per quarter (20%) and EUR 100,000–2 million per quarter (30%). Dividend payments to non-residents for the period since 2023 in the amount of EUR 2–9 million per quarter are relevant for 30% of companies.

Repayment of loans to non-residents (“legacy” debts)

Compared to 2024 (51%), the share of companies for which loan repayments to non-residents are relevant increased to 60% in 2025 (43% consider this need extremely relevant). The most demanded range is EUR 100,000–2 million per quarter (53%), while 10% of respondents require the ability to repay more than EUR 2 million per quarter.

* Currently, such repayments are allowed within the “incentive” limits (in particular, the “loan limit” introduced as part of the NBU’s currency easing measures of 14 January 2026).

Increasing limits for transactions using UAH-denominated corporate payment cards abroad

70% of companies need higher limits for transactions using UAH-denominated corporate cards abroad (60% consider it relevant but not critical; 10% extremely relevant). In 2024, 79% of companies declared a need to increase such limits. Optimal limits are assessed at UAH 150,000–500,000 per month (50%) and UAH 500,000–1 million per month (17%). Given the increase in business travel and related expenses, companies also propose raising limits on FX P2P transfers and lifting restrictions on cash purchases (currently equivalent to USD 80 per day), as these no longer cover employees’ actual needs abroad.

Payments for imported goods delivered before 23 February 2021

In 2025, the issue of payments for imported goods and services delivered before 23 February 2021 became more acute: the share of companies for which it is relevant increased from 25% in 2024 to 40% in 2025 (17% extremely relevant; 23% relevant but not critical). The most demanded limits are EUR 100,000–500,000 (23%) and EUR 500,000–2 million (13%). This issue covers both goods and services delivered before 23 February 2021, and for settlements — including import arrears from 2022 — businesses are willing to use their own foreign currency reserves.

* Currently, such payments are allowed within the “incentive” limits (including the “loan limit” introduced under the NBU’s currency easing measures of 14 January 2026).

Refund of container deposits

The issue of refunding container deposits remains niche: it is not relevant for 93% of respondents. The 7% that do have such a need (though not critical) indicate that a limit of EUR 100,000–500,000 would be sufficient.

Cross-border payments related to export operations (penalties, fines, etc.)

The ability to pay penalties related to export operations is relevant for 43% of companies (10% consider it extremely relevant). For most respondents, a limit of 2–5% of the contract value would be sufficient to mitigate these risks.

Completion of currency supervision through set-off

The need to complete currency supervision through set-off remains high at 63% (20% extremely relevant; 43% relevant but not critical), compared to 73% in 2024. Sufficient limits include: up to EUR 100,000 per month (23%), EUR 100,000–1 million per month (20%), and over EUR 1 million per month (13%). Companies point to the risk of penalties due to a lack of guarantees from tax authorities and propose simplification mechanisms to reduce administrative pressure.

Settlement deadlines for export/import operations

Given disrupted supply chains and border blockages, almost half of respondents (47%) consider it necessary to extend settlement deadlines to 360 days, while 180- and 270-day options are supported by 23% and 17% of companies respectively. In this context, businesses propose not only extending revenue repatriation deadlines (particularly for grain), but also exempting exporters from penalties for violations caused by logistical disruptions in 2023.

Purchase of foreign currency to meet obligations regardless of available funds

The ability to purchase foreign currency regardless of available funds remains consistently important for business: 80% of respondents declare this need (37% consider it extremely relevant), confirming the stable trend observed in 2024 (79%).

In terms of desired limits, 50% of companies target UAH 100,000–2 million per month; 27% require UAH 2–5 million; and 7% need amounts exceeding UAH 45 million.

Additional measures proposed by businesses in the context of currency liberalisation

Businesses also emphasise the need to:

Clarify the provisions of NBU Resolution No. 18 to avoid discrimination in dividend payments for companies that have undergone reorganisation (conversion from JSC to LLC).
Allow transfers for goods and services without documentary confirmation up to UAH 400,000, significantly reducing the administrative burden on businesses and banks.
Enable representative offices to transfer funds to parent companies (up to EUR 1 million per month) and to pay taxes to foreign jurisdictions (up to EUR 30,000 per year).
Lift the ban on settlements under provided guarantees and foreign exchange risk hedging operations.
Allow fulfilment of obligations under guarantee agreements (leases), repayment of import debts from 2022, and payments for services/guarantees provided before 23 February 2021, as well as payment of overdue interest on loans to parent companies.

For reference:

The survey was conducted from November 2025 to January 2026 among member companies of the European Business Association. A total of 30 companies participated.