Main
News
Analytics
The NBU has updated the rules on the authorisation of financial institutions: a lawyer explained what has changed in 2026

The NBU has updated the rules on the authorisation of financial institutions: a lawyer explained what has changed in 2026

21 July 2026, 12:15

The NBU has updated the rules on the authorisation of financial institutions: a lawyer explained what has changed in 2026 — Rules for the Authorisation of Financial Institutions 2026

The NBU continues to update regulatory requirements for the financial sector, tightening control over providers of financial and payment services. The latest changes relate to both authorisation procedures and requirements concerning business reputation, ownership structure and business planning for financial institutions. The new rules will also affect pawnbrokers and insurers, which must adapt their internal processes to the updated standards.

The adoption by the National Bank of Ukraine of Resolution No. 69 (dated 24 June 2026) has indeed brought about significant changes for the non-banking financial sector.

Dina Dryzhakova – a solicitor and head of the law firm ‘Prima Leader Group’ – spoke exclusively to ThePublic about the key changes that will affect financial institutions in 2026.

1. What exactly will change for pawnbrokers and fintech/financial companies? (Simply and briefly)

The main thrust of the reform is to simplify the red tape at the outset, but to significantly tighten capital and transparency requirements going forward.

For pawnbrokers:

‘Two in one’: Previously, to issue secured loans and exchange currency, it was necessary to go through two separate bureaucratic procedures. Now, a licence for pawnbroking activities and authorisation for over-the-counter currency trading can be obtained with a single set of documents.

Business planning: Pawnbrokers that already exchange currency (or plan to do so) are required to submit a clear business plan for 2027–2029 to the NBU by 31 December 2026.

Simpler small contributions: The source of funds for micro-contributions to authorised capital (up to 1 per cent) can now be verified using a simplified in-house procedure (though the results must be retained for five years).

For financial and fintech companies:

Debt restrictions: Payment service providers exhibiting signs of risk will no longer be able to raise funds through the issue of debt securities (bonds).

Stricter requirements for investors: Funds raised as capital (for example, subordinated debt for insurers or financial companies) must be exclusively the company’s own funds, free from encumbrances and without any obligation to repay.

Updated reporting rules (Resolution No. 49) — reports may now be signed not only with a qualified electronic signature (QES) but also with an advanced electronic signature (AES), which technically simplifies the process.

2. How will this affect their operations? Will there be fewer companies?

The number of pawnbrokers is unlikely to decrease, but the market will consolidate. Easier access to the foreign exchange market for pawnbrokers will encourage large chains to expand their range of services (by opening currency exchange counters in their branches). Small pawnbrokers lacking the resources to draw up long-term business plans and secure capital will have to either merge or exit the market.

Conditions are becoming tougher for fintech and payment companies. The ban on issuing debt securities for high-risk players and the tightening of regulations regarding the origin of capital will result in weak or ‘grey’ companies being forced out. The market will be cleansed of technology platforms that were used for dubious transactions or the fraudulent reallocation of capital. The number of players in the fintech sector may decrease slightly, but the quality and financial stability of those who remain will improve.

3. Is this a positive move for the market, or does it pose a risk?

Pros (why this is a good move):

Reduced bureaucracy: A ‘single window’ (a single set of documents) for pawnbrokers is a civilised European approach. Less paperwork means a faster business launch.

The requirement to submit three-year business plans forces businesses to think strategically, whilst enabling the NBU to better understand the risks within the system.

Protection of consumers and investors: Tighter capital requirements minimise the risk of bankruptcy for financial companies holding clients’ money.

Risks and dangers:

Pushing small players into the grey economy: Excessively high capital requirements and complex business planning could drive small regional pawnbrokers into the ‘grey zone’ (where loans are issued without licences under other agreements).

Restrictions on fintech development: Depriving financial companies of the ability to issue debt securities (even subject to the regulator’s subjective ‘risk criteria’) could hinder investment in Ukrainian start-ups. The NBU is being given a very powerful tool of influence, the subjective use of which could restrict healthy competition.

Finance

Analytics

Will there be enough gas and electricity this winter? What Ukrainians need to prepare for in the new heating season

Ukraine is approaching another heating season whilst its energy infrastructure comes under constant attack. Whilst the authorities report on gas reserves and the commissioning of new power generation capacity, experts point to disputed figures and problems with connecting new capacity, and in some places power cuts lasting between 10 and 20 days.