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Contents
1. License for financial services
2. Licensing of factoring companies
3. License for leasing companies
4. Licensing of pawnshops
5. Licensing of credit unions
6. Licensing of lending and microcredit
7. License for foreign exchange transactions
8. Procedure for obtaining a license
Financial services in Ukraine may only be provided after completing the authorisation procedure established by law. The specific requirements depend on the type of institution, the range of services, the ownership structure, the amount of capital and the selected business model.
The National Bank of Ukraine is the primary regulator of the banking and non-banking financial markets. The NBU licenses financial companies, pawnshops, credit unions, insurance companies, banks and non-banking institutions that conduct foreign exchange transactions. Capital market activities, including asset management, brokerage services and public offerings of securities, fall within the competence of the National Securities and Stock Market Commission.
Since 1 January 2024, the principal rules governing financial companies have been established by the Law of Ukraine «On Financial Services and Financial Companies». The authorisation procedure is regulated by Resolution No. 199 of the Board of the National Bank of Ukraine dated 29 December 2023. When preparing documents, applicants must also consider subsequent amendments to regulatory requirements, including updates that entered into force on 26 June 2026.
A financial company does not obtain a separate permit for every transaction. Instead, it receives one licence to operate as a financial company. The NBU specifies the particular financial services that the institution is authorised to provide within the scope of this licence.
The licence may cover:
A company may not provide a service that is not included within the scope of its licence. To expand its activities, the company must apply to the NBU and complete the procedure for amending the scope of the licence.
Applicants must meet a comprehensive set of requirements. The NBU assesses:
The outdated rule requiring a mandatory five-year work history for a director or chief accountant does not apply as a universal requirement to all financial companies. The regulator assesses the education, experience, professional competence, business reputation and ability of each person to perform the relevant duties.
The company submits an application in the prescribed form and a package of documents to the NBU. Depending on the selected services, the package may include the charter, a description of the business model, financial statements, documents confirming the formation of capital, information about owners, questionnaires completed by executives, internal policies, audit documents and information about the management system.
The NBU considers a complete application package submitted by a financial company within a period of up to two months. The licence is issued for an indefinite period. However, the regulator may restrict, suspend or revoke it in the event of a breach of law, failure to comply with prudential requirements or submission of inaccurate information.
The minimum authorised capital depends on the range of financial services to be provided.
The following basic thresholds apply to most financial companies:
The registration of authorised capital alone does not guarantee that a licence will be granted. The funds must have a documented lawful origin and must actually be contributed. The company’s regulatory capital must also comply with the requirements established by the NBU.
There is no separate «factoring licence» under the current authorisation system. To provide factoring services, a legal entity must obtain a licence to operate as a financial company, with factoring included within the scope of that licence.
If factoring is the company’s only financial service, the minimum authorised capital is generally UAH 3 million. If the company combines factoring with lending, financial leasing or other permitted services, the minimum capital may be UAH 5 million or more, depending on the scope of the licence.
A factoring company must have internal service rules, a system for recording agreements, proper procedures for assessing clients and debtors, a risk management system and financial monitoring mechanisms.
A separate «monitoring department» is not a universal requirement for every company. Nevertheless, a financial institution must organise a system for preventing money laundering, terrorist financing and the financing of the proliferation of weapons of mass destruction, taking into account its status, scale of operations and risk profile.
Where a company manages overdue consumer credit debts, it must also comply with legal requirements concerning ethical conduct, interaction with consumers and the activities of debt collection companies.
To provide financial leasing services, a new company must obtain a licence to operate as a financial company, with financial leasing included within the scope of that licence.
Legal entities that previously operated as lessors under the former rules acquired the status of financial institutions under transitional procedures, and their permits were reissued as licences for the activities of a financial company. Therefore, the previous distinction between financial institutions and ordinary legal entity lessors no longer applies in its former form.
To obtain the right to provide financial leasing services, a company must:
If financial leasing is the company’s only service, the basic minimum authorised capital is UAH 3 million. Where several financial services are combined, a higher capital requirement applies.
A loss recorded during a particular reporting period does not automatically prohibit the company from obtaining a licence. The NBU assesses the financial condition comprehensively, including capital adequacy, sources of financing, asset quality, the feasibility of the business plan and the company’s ability to meet its obligations.
A pawnshop operates on the basis of a separate pawnshop activity licence. Its principal financial service is the provision of loans to individuals secured by movable property.
A pawnshop must be a legal entity and must comply with requirements concerning its ownership structure, capital, executives, financial condition, internal control and financial monitoring. The institution must also have appropriately equipped premises and ensure the safe storage of pledged property.
The minimum authorised capital is:
A pawnshop licence is issued for an indefinite period. The previous rule providing for a three-year licence, a subsequent five-year extension and a state fee of UAH 400 no longer applies.
Subject to obtaining the relevant authorisation, a pawnshop may provide certain payment services or conduct transactions involving currency valuables. These rights do not arise automatically upon obtaining a pawnshop licence. Additional NBU requirements must be satisfied.
The activities of credit unions are regulated by the new Law of Ukraine «On Credit Unions» and NBU regulations. A credit union has a special legal status, a membership-based governance structure and operates primarily to meet the financial needs of its members.
A credit union may obtain one of two types of licence:
The scope of the licence may also include guarantees and certain financial payment services, provided that the credit union meets the applicable additional requirements.
The outdated statement that a credit union must necessarily consist of at least 50 people living in the same city or belonging to the same trade union should not be treated as a current universal rule. The procedure for establishment, membership criteria, composition of founders and governance bodies are determined by current legislation and the credit union’s charter.
For licensing purposes, the NBU assesses:
The NBU makes a decision on granting a credit union licence within a period of up to 60 calendar days after receiving a complete package of documents. The licence is issued for an indefinite period.
To provide loans, a non-banking company must obtain a licence to operate as a financial company, with the provision of funds and bank metals on credit included within its scope.
Ukrainian legislation does not provide for a separate universal «microfinance institution licence». The term «microfinance organisation» is frequently used in commercial practice, but legally such an organisation usually has the status of a financial company authorised to provide credit.
Before commencing operations, the lender must develop lending rules, agreement templates, creditworthiness assessment procedures, overdue debt settlement procedures and rules governing interaction with consumers.
The company must also comply with legislation on consumer lending, advertising of financial services, personal data protection and financial monitoring, as well as NBU requirements regarding disclosure of the total cost of credit.
Ukraine does not have a universal «investment raising licence» that may be obtained by any company or individual. Whether authorisation is required depends on the method used to raise funds.
A company may receive contributions from shareholders, loans, repayable financial assistance or other financing under civil, corporate and tax legislation. The receipt of an investment in itself does not require a separate «investment licence».
Different rules apply when raising funds involves:
Such activities may require registration of a securities issue, approval of a prospectus, establishment of a specialised legal entity or a licence from the National Securities and Stock Market Commission to conduct professional activities in the capital markets. An asset management company, investment firm or other professional market participant may not operate solely on the basis of ordinary state registration.
Individuals are not issued a universal licence to invest their own funds. However, the systematic raising of funds from other persons, management of third-party assets or offering of financial instruments without proper authorisation may breach legislation governing financial services and capital markets.
Non-banking financial institutions and postal operators may conduct foreign exchange transactions after obtaining an NBU licence for foreign exchange operations.
The previous model under which a non-banking company could operate only as a bank agent is not a universal rule. A non-banking financial institution may conduct authorised operations in its own name on the basis of its own NBU licence. Information about the licence is entered in the relevant electronic register.
To trade in currency valuables in cash, a company must:
The minimum authorised capital of a non-banking institution intending to trade in currency valuables in cash is UAH 3 million.
The licence is issued for an indefinite period. The previous conditions providing for a three-year licence and a monthly payment of UAH 360 no longer apply. Currency exchange offices must be entered in the Register of Foreign Currency Exchange Offices, and the NBU must be notified of changes in their operations in accordance with the prescribed procedure.
A tariff established by the National Bank of Ukraine is payable for reviewing the application and supporting documents. There is no single state fee of UAH 400 or another nominal fixed amount.
The applicable tariff depends on the type of institution and the relevant procedure, including:
Tariffs, application forms and documentary requirements are amended periodically. They should therefore be checked on the official NBU website immediately before the application package is submitted.
The licensing process should begin not with collecting documents, but with defining the correct operating model.
The principal stages are:
The NBU may refuse to grant a licence where the ownership structure is not transparent, capital has been formed from unverified sources, executives do not meet the qualification requirements, documents contain inaccurate information or the business model creates risks for clients and the financial market.
After obtaining a licence, the company must continuously comply with NBU regulations, submit reports, notify the regulator of changes in its ownership structure and management, comply with financial monitoring rules and protect consumer rights. Although the licence is issued for an indefinite period, the right to operate is maintained only while the company continues to comply with the applicable legislation.
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