Expert opinion

In November 2025, the National Bank of Ukraine focused on improving the regulatory framework for non-bank financial institutions.

The regulator adopted a number of important decisions affecting ownership structure requirements, licensing conditions, and the operating procedures of certain companies.

This is stated in the analytical review of the Center for Economic Research and Forecasting, Financial Pulse.

By Resolution No. 135 of November 7, the NBU approved a new version of the Regulation on the requirements for the ownership structure of financial service providers. And by Resolution No. 138 of November 14, amendments were made to several regulations regarding the submission of documents on the ownership structure of non-bank market participants.
In addition, by Decision No. 441-rk of November 25, the NBU prohibited the trading of foreign exchange and the provision of financial payment services by FC OBMIN24 LLC and FC IKS CHENGE LLC, as well as other related entities. The reason for this was the lack of the necessary licenses and other significant violations.

The National Bank also amended Resolution No. 351 regarding the requirements for ECA operations, compliance with which gives banks the right to take into account ECA guarantees and insurance contracts as collateral when calculating credit risk.
Additional adjustments were made to the Regulations on Depository and Clearing Activities, as well as to the rules for organizing cash circulation in the banking system during a special period.
According to Dilyara Mustafayeva, head of the analytical department at Financial Pulse, these changes create a more controlled and transparent environment for non-banking institutions.

“The NBU's November decisions demonstrate the regulator's desire to strengthen market discipline and ensure that participants comply with clear requirements regarding ownership structure and the provision of financial services. This is an important step towards reducing risks and increasing confidence in the financial sector,” she concluded.

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The public organization “Center for Economic Research and Forecasting ”Financial Pulse" was established on March 2, 2015, with the aim of uniting the efforts of participants and experts in the Ukrainian financial market for its development and improvement.

The Center's activities will contribute to the achievement of the following goals:

• Improving the quality of the regulatory framework governing the financial market, eliminating regulatory problems that hinder its full development
  
  
• Increasing the transparency of financial institutions
  
  
• Developing new market instruments and mechanisms, including through the introduction of best international practices
  
  
• Improving the financial literacy of the population
  
  
• Promoting economic reforms, including through financial decentralization
  
  
• Promoting the development of entrepreneurship, etc.

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