The National Bank of Ukraine (the NBU) has announced a further easing of certain foreign exchange (FX) restrictions, effective 14 January 2026. The key changes are summarised below.
New FX Mechanism Linked to Post-2026 Foreign Loans
The NBU has introduced a mechanism under which foreign currency funds received under a foreign loan on or after 1 January 2026 (other than loans financed or guaranteed by international financial institutions) may be used as a payment limit for certain previously restricted transactions.
Within this limit, Ukrainian companies are now allowed to:
Practical Limitations
Although this mechanism may initially appear to permit the refinancing of “old” loans and the settlement of other long-standing payment obligations that are currently restricted, its practical usefulness is significantly limited.
In particular, any use of the new loan proceeds for the purposes listed above proportionally reduces the borrower’s ability to repay the principal of the new cross-border loan. As a result, the borrower effectively loses the right to repay the new financing to the extent it is used to service old obligations as long as FX restrictions remain effective.
Conclusion
In practice, this mechanism is likely to be relevant only in very limited scenarios – for example, where a foreign parent company is willing to provide funds to settle “old” loans or other overdue obligations in order to stop the accrual of default interest and penalties, without any realistic prospect of recovering the new financing.
Legal Basis
The changes were adopted by:
For further details, please contact Olexiy Soshenko or Olesia Mykhailenko.