December 2025 was one of the busiest months in terms of regulatory activity for the National Bank of Ukraine. The regulator adopted a number of important decisions on the functioning of the financial system under martial law, the activities of non-bank financial institutions, and the banking sector.
This is stated in the analytical review of the Center for Economic Research and Forecasting “Financial Pulse.”
As noted by Dilyara Mustafayeva, head of the analytical department of “Financial Pulse,” at the end of the year, the NBU traditionally “closes” several strategic areas at once.
“Usually, in December, the regulator sums up the year and, at the same time, lays the foundation for the next one. In 2025, we saw comprehensive changes: from targeted currency easing for defense needs to systemic steps to bring financial regulation closer to EU standards,” she explains.
Easing currency restrictions and focusing on defense
A separate set of decisions made by the NBU in December concerned the functioning of the financial system under martial law. The regulator eased currency restrictions for the Ministry of Defense of Ukraine and also allowed certain cross-border transfers for electricity transmission system operators. At the end of the month, additional currency easing measures were also introduced to enhance the country's defense capabilities.
"These decisions have a clear practical logic: the financial system must respond as flexibly as possible to the needs of the security sector and critical infrastructure. At the same time, the NBU is trying to maintain balance without destabilizing the currency market," the expert notes.
In addition, the regulator postponed the application of certain credit risk calculation requirements, giving banks additional time to adapt in conditions of uncertainty.
Active changes for the non-banking financial market
A significant number of December decisions concerned the non-banking financial sector. The NBU updated the licensing rules, reporting requirements, cyber security, and internal audit requirements for financial companies, insurers, credit unions, and pawnshops.
“The regulator is consistently establishing uniform ‘rules of the game’ for the non-banking market. The December decisions are not one-off amendments, but a systematic increase in transparency, risk management, and market participant accountability,” emphasizes the head of the analytical department at Financial Pulse.
An important feature of the changes was the alignment of the regulatory framework with the new Law of Ukraine “On Rating,” as well as the implementation of Global Standards for Internal Auditing.
Banking sector: stability, risks, and transparency
The banking system was also in the regulator's focus. In December, the NBU updated the requirements for internal auditing of banks and banking groups, approved technical specifications for assessing the stability of the banking system in 2026, and amended the rules for storing and disclosing banking secrets with an emphasis on electronic document management.
Particular attention was paid to the implementation of European approaches to assessing operational risk and significant exposures.
"In fact, the NBU is gradually ‘weaving’ European regulatory approaches into the Ukrainian banking system. This is important both for the process of European integration and for increasing the stability of banks in the medium term," notes Dilyara Mustafayeva.
At the end of the year, the regulator also approved new rules for the disclosure of prudential information, which expand the scope of data on risk management and problem assets of banks.
“For the market, this means greater transparency, and for customers and partners of banks, it means more information for making informed decisions,” the expert concludes.
Reference:
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 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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