Expert opinion

Despite the full-scale war, Ukrainian banks are not only staying afloat, but are demonstrating greater resilience, increased capital reserves, and improved stability. This is stated in an analytical article by the Center for Economic Research and Forecasting, “Financial Pulse.” 

"The financial system not only withstood the initial blows of the war, but is also actively improving. We are already seeing significant results: banks' capital has grown and has a significant reserve, which allows them to cover the main risks even in conditions of military action," explains Dilara Mustafayeva, head of the analytical department at Financial Pulse.

According to her, more than 75% of the EU's requirements for banking supervision have already been met. And according to some criteria, for example, in the area of operational risk coverage, the Ukrainian approach is even stricter than that of the EU.

 Referring to data from the NBU, the expert pointed out that as of June 1, 2025:

• regulatory capital adequacy (Npk) — 15.49% with a minimum requirement of 9.25%;
• Tier 1 capital (Nok1) — 15.15% (norm — 5.625%);
• Tier 1 capital (Nk1) — also 15.15% (norm — 7.5%).

“These figures are an indicator not only of the conscientious work of banks, but also of the effectiveness of the banking reforms being implemented,” explains Mustafayeva.

Even after the state retroactively increased the income tax to 50%, banks retained significant capital and a margin of safety. “But even these burdens did not derail the banking system. We have a real safety cushion in case of a repeat of shocks similar to those at the beginning of 2022,” the expert emphasizes.

Dilyara Mustafayeva noted that since August 5, 2024, a new three-tier capital structure has been in effect in Ukraine: Tier 1 capital, Tier 2 capital, and Tier 3 capital.

“This is not just a structural change — it is a tool for rapid response to crises. Today, 97.75% of regulatory capital is the highest quality capital that can immediately absorb losses,” the analyst emphasized.

In addition, Ukrainian banks are already assessing risks using European approaches. For example, starting in 2024, they will submit reports under the ICAAP procedure, which is an internal assessment of the capital needed to cover all risks.

By the end of 2026, Ukraine plans to take several more steps toward harmonizing capital requirements with EU standards. The nearest innovations are:

• From September 2025, a new standard will be introduced — the leverage ratio (LR), which assesses capital in relation to all bank assets without risk weighting;

• From March 2026, standards will come into effect to cover risks associated with financial market transactions (securities, foreign currency, over-the-counter derivatives, etc.).

• From August 2026, the approach to credit risk assessment will be updated, based on international ratings.

  Capital buffers will be introduced so that banks have additional reserves in case of crises.

   “If the planned deadlines for the implementation of the above innovations are met, Ukraine will have a chance to come closer to passing the assessment of the equivalence of our regulatory standards for banks and EU standards as early as 2026. This is a prerequisite for Ukrainian banks to operate freely in the EU market,” Mustafaeva notes.

   The equivalence assessment, conducted by the European Banking Authority (EBA) and approved by the European Commission, will eventually open up access to the European market for Ukrainian banks. In addition, European banks will be able to invest in their subsidiaries in Ukraine without creating additional reserves, which will significantly simplify the inflow of foreign capital into Ukraine.

   “Bringing the Ukrainian banking sector closer to EU standards is not only a guarantee of trust in banks for our citizens and businesses, but also the first step towards increasing investment in the Ukrainian economy,” Dilyara Mustafayeva concluded.