EBA representatives met with the leadership of the National Bank of Ukraine

04/ 06/ 2026

Listen to online Stop   On 27 May, the leadership of the National Bank of Ukraine held a meeting with representatives of leading business associations. The European Business Association was represented by members of its Board and heads of sectoral committees. The Governor of the National Bank of Ukraine, Andriy Pyshnyy, shared updates on the regulator’s current priorities, including: ongoing negotiations within the IMF mission; inflation expectations and exchange rate policy; macro-financial stability; donor assistance and its impact on the financial sector; development of lending, factoring, and the insurance market. A separate part of the meeting was dedicated to the situation on the foreign exchange market and prospects for currency liberalisation. NBU representatives emphasised the importance of maintaining a productive dialogue between business and the regulator in order to assess and prioritise relevant needs. As part of the ongoing negotiations with the IMF, proposals regarding further currency liberalisation are currently being aligned. The NBU expressed hope that the inflow of announced donor support would create the preconditions for adopting relevant liberalisation measures in 2026. Business representatives, in turn, noted the positive effects of liberalisation measures implemented in 2025–2026. In particular, companies have already used the “loan limit” instrument under the incentive-based liberalisation mechanism in the amount of over USD 600 million. It was also noted that Ukraine’s banking sector remains attractive to foreign investors despite security risks. EBA representatives proposed that the NBU support an initiative to hold an inter-agency working meeting on access to finance for companies operating in frontline regions. It is proposed to involve representatives of business, the NBU, the Ministry of Economy, and the Ministry of Finance of Ukraine. The Association expects such a meeting to take place in the near future and looks forward to continued constructive dialogue between business and state authorities in support of enterprises under wartime conditions. European integration of the financial sector was also among the topics discussed. The Governor of the NBU confirmed the regulator’s ambitious goal of fully harmonising financial legislation with EU law by the end of 2027. At the same time, he noted that the NBU is carefully reviewing all substantiated business proposals regarding the need for transitional periods for the implementation of certain directives and regulations. The EBA submitted to the NBU the results of a study initiated in 2025 on the potential impact of legislative harmonisation on the electronic payments market and the development of a cashless economy. The key conclusion of the EBA study is that the optimal timeline for phased implementation of the EU regulation on interchange fee caps is a five-year transitional period. This approach would ensure gradual market adaptation and help avoid shock effects, including a slowdown in the development of the cashless economy and an increase in the shadow economy. The report also analyses other scenarios for the pace of interchange fee reduction within the EU integration process, including an iterative phased reduction of interchange fees to the level stipulated by EU Regulation No. 2015/751, starting from 1 January 2028. According to the report, both the gradual reduction scenario and the five-year deferred reduction scenario would have a moderate impact on payment market participants compared to other scenarios analysed. The report was submitted to the European Commission, the National Bank of Ukraine, the Government and Parliament of Ukraine, market participants, and other stakeholders involved in Ukraine’s EU accession negotiations. In addition, the Association recently held a meeting with representatives of DG ENEST of the European Commission, during which the EU side confirmed that Ukraine, as a candidate country, has the right to independently determine the sequencing and timeline for the implementation of EU regulatory acts. This applies to EU acts that are not part of the negotiation benchmarks and are therefore not mandatory prior to Ukraine’s accession to the EU. The European Commission confirmed that the five-year implementation timeline proposed in the Association’s report is justified and feasible. It was also noted that this timeline should be reflected in Ukraine’s negotiating position. Thus, the business community calls on the National Bank to initiate amendments to Ukraine’s negotiating position under Negotiation Chapter 4 “Free Movement of Capital”, approved by the Cabinet of Ministers of Ukraine Order No. 534-r dated 30 May 2025, within the negotiations with the European Union on the Association Agreement under Cluster 2 “Internal Market”. In particular, this concerns the implementation of EU Regulation No. 2015/751, establishing a five-year period for the phased reduction of interchange fees and ensuring a comprehensive approach to implementing the Regulation, covering not only the regulation of interchange fees but also other aspects of payment market regulation. The Association is grateful to the leadership of the National Bank of Ukraine for the regular dialogue and productive cooperation.

On 27 May, the leadership of the National Bank of Ukraine held a meeting with representatives of leading business associations. The European Business Association was represented by members of its Board and heads of sectoral committees.

The Governor of the National Bank of Ukraine, Andriy Pyshnyy, shared updates on the regulator’s current priorities, including:

• ongoing negotiations within the IMF mission;
• inflation expectations and exchange rate policy;
• macro-financial stability;
• donor assistance and its impact on the financial sector;
• development of lending, factoring, and the insurance market.

A separate part of the meeting was dedicated to the situation on the foreign exchange market and prospects for currency liberalisation. NBU representatives emphasised the importance of maintaining a productive dialogue between business and the regulator in order to assess and prioritise relevant needs.

As part of the ongoing negotiations with the IMF, proposals regarding further currency liberalisation are currently being aligned. The NBU expressed hope that the inflow of announced donor support would create the preconditions for adopting relevant liberalisation measures in 2026.

Business representatives, in turn, noted the positive effects of liberalisation measures implemented in 2025–2026. In particular, companies have already used the “loan limit” instrument under the incentive-based liberalisation mechanism in the amount of over USD 600 million. It was also noted that Ukraine’s banking sector remains attractive to foreign investors despite security risks.

EBA representatives proposed that the NBU support an initiative to hold an inter-agency working meeting on access to finance for companies operating in frontline regions. It is proposed to involve representatives of business, the NBU, the Ministry of Economy, and the Ministry of Finance of Ukraine. The Association expects such a meeting to take place in the near future and looks forward to continued constructive dialogue between business and state authorities in support of enterprises under wartime conditions.

European integration of the financial sector was also among the topics discussed. The Governor of the NBU confirmed the regulator’s ambitious goal of fully harmonising financial legislation with EU law by the end of 2027. At the same time, he noted that the NBU is carefully reviewing all substantiated business proposals regarding the need for transitional periods for the implementation of certain directives and regulations.

The EBA submitted to the NBU the results of a study initiated in 2025 on the potential impact of legislative harmonisation on the electronic payments market and the development of a cashless economy. The key conclusion of the EBA study is that the optimal timeline for phased implementation of the EU regulation on interchange fee caps is a five-year transitional period. This approach would ensure gradual market adaptation and help avoid shock effects, including a slowdown in the development of the cashless economy and an increase in the shadow economy. The report also analyses other scenarios for the pace of interchange fee reduction within the EU integration process, including an iterative phased reduction of interchange fees to the level stipulated by EU Regulation No. 2015/751, starting from 1 January 2028. According to the report, both the gradual reduction scenario and the five-year deferred reduction scenario would have a moderate impact on payment market participants compared to other scenarios analysed. The report was submitted to the European Commission, the National Bank of Ukraine, the Government and Parliament of Ukraine, market participants, and other stakeholders involved in Ukraine’s EU accession negotiations.

In addition, the Association recently held a meeting with representatives of DG ENEST of the European Commission, during which the EU side confirmed that Ukraine, as a candidate country, has the right to independently determine the sequencing and timeline for the implementation of EU regulatory acts. This applies to EU acts that are not part of the negotiation benchmarks and are therefore not mandatory prior to Ukraine’s accession to the EU. The European Commission confirmed that the five-year implementation timeline proposed in the Association’s report is justified and feasible. It was also noted that this timeline should be reflected in Ukraine’s negotiating position.

Thus, the business community calls on the National Bank to initiate amendments to Ukraine’s negotiating position under Negotiation Chapter 4 “Free Movement of Capital”, approved by the Cabinet of Ministers of Ukraine Order No. 534-r dated 30 May 2025, within the negotiations with the European Union on the Association Agreement under Cluster 2 “Internal Market”. In particular, this concerns the implementation of EU Regulation No. 2015/751, establishing a five-year period for the phased reduction of interchange fees and ensuring a comprehensive approach to implementing the Regulation, covering not only the regulation of interchange fees but also other aspects of payment market regulation.

The Association is grateful to the leadership of the National Bank of Ukraine for the regular dialogue and productive cooperation.