The Committee on Banking Risk Management and Creditor Protection of the Association of Ukrainian Banks (hereinafter referred to as the Association or AUB) is systematically working to remove legislative barriers that hinder the development of lending in Ukraine.
On November 6, 2025, the AUB sent an official letter to:
• the Verkhovna Rada Committee on Economic Development;
• the Verkhovna Rada Committee on Finance, Tax, and Customs Policy
(with copies to the Ministry of Economy of Ukraine, the Ministry of Justice of Ukraine, and the National Bank of Ukraine)
proposing the creation of a working group to develop amendments to the legislation in the field of lending.
It was proposed to establish a working group comprising:
• Members of the Verkhovna Rada of Ukraine;
• representatives of the Ministry of Economy of Ukraine;
• representatives of the Ministry of Justice of Ukraine;
• representatives of the National Bank of Ukraine;
• representatives of Ukrainian banks.
The main task of such a working group is defined as reviewing certain provisions of the legislation and preparing amendments aimed at restoring the balance between the rights of borrowers and lenders, as well as removing obstacles to the development of lending.
The appeal emphasizes that a number of provisions introduced at the start of the full-scale war as temporary measures have lost their relevance but remain in effect and:
• limit lenders’ ability to protect their rights;
• create an imbalance in the financial market;
• hinder the development of lending and the country’s economic recovery.
Following the initiative, a working group was established, marking an important step toward a systematic review of approaches to regulating the credit market.
The working group has already achieved its first results. In particular, a joint letter was drafted by five specialized financial market associations representing banks, financial companies, private enforcement agents, and participants in the debt collection business.
In the aforementioned letter, the associations:
• supported the working group’s activities;
• provided coordinated proposals for amendments to legislative and regulatory acts;
• identified priority issues requiring resolution, specifically:
o regulating the collection of interest and penalties on non-performing loans;
o reviewing the general moratorium on foreclosure on mortgaged property;
o simplifying procedures for collecting small amounts of debt, including by expanding out-of-court mechanisms.
To provide insight into the challenges facing the development of lending, the Association’s website features an analytical presentation
titled “The Development of Lending: Key Challenges,” which systematically outlines the market’s main issues, including:
• the inability to fully collect interest and penalties on non-performing loans;
• the effect of moratoriums on foreclosure on mortgaged property;
• the lack of effective and expedited debt collection procedures, leading to lengthy litigation even for minor amounts.
The associations emphasized that the effective functioning of the credit market is impossible without adequate protection of creditors’ rights and effective mechanisms for debt recovery.
The Association will continue to actively participate in the working group’s activities and contribute to the development of balanced legislative solutions necessary for the resumption of lending and Ukraine’s economic development.
