Changes in Financial Services Licensing in 2026

How Financial Services Licensing Works in 2026

In 2026, the basic principle remained unchanged: financial services can be provided by institutions and other persons who have the right to conduct the relevant activity as provided by law. The Law of Ukraine “On Financial Services and Financial Companies” allows combining the right to provide one or several financial services under a single license, if the law permits them for a specific type of institution.

The National Bank issues licenses, among others, for the activities of financial companies, insurers, credit unions, pawnshops, and for certain currency operations. The current types of permits issued by the NBU are published on the page about licensing of non-banking institutions.

For businesses, this means a simple thing: it’s not enough to register a legal entity and add the required classification code (KVED). The right to actually provide regulated financial services arises only after passing the relevant authorization procedure.

On Poshuk.info, there is a separate collection of companies offering support for obtaining licenses for financial services, and for new businesses, there is also a direction for registration of financial companies.

What Changed in 2026

Strengthened Control over Activities Without a License

From February 28, 2026, changes approved by NBU Resolution No. 21 dated February 26, 2026, came into effect. They concern the definition of whether a particular service is a financial or limited payment service, as well as procedures for identifying unlicensed activities.

The regulator detailed the criteria it takes into account when making such decisions and the procedure for conducting in-depth analysis. The NBU also received a clarified mechanism for involving third parties in such analysis.

The risk for a company arises not only when the website explicitly mentions “credit” or “factoring.” The NBU may analyze the actual economic substance of the transaction.

When checking the business model, it is worth separately evaluating:

• what exactly the client receives under the contract;
• whether funds are transferred to the client with an obligation to return;
• whether the company charges fees for the use of funds;
• whether there is an assignment of the monetary claim;
• whether the operation contains features of a payment, credit, factoring, or another financial service;

The actual model is key. The contract name does not change the legal nature of the transaction.

To understand the responsibility for conducting business without the necessary permission, the material on Poshuk.info about Art. 164 of the Code of Administrative Offenses is also relevant.

A Separate Regime for Significant Financial Companies Has Appeared

In January 2026, the NBU published the list of significant financial companies for the first time. It included 53 institutions. Enhanced requirements for corporate governance, activity planning, and information disclosure apply to them, which had to be fulfilled by July 1, 2026.

The status of a significant company affects not so much the fact of issuing a license, but more the subsequent compliance with activity conditions. The regulator reviews the management system much more deeply.

In particular, NBU Resolution No. 108 established the obligation of a significant financial company to prepare an activity plan for the second half of 2026 and for the 2027-2029 period. After increasing the authorized capital, such a company must notify the NBU and submit documents confirming the sources of funds within 15 working days.

New Authorization Changes from June 26, 2026

NBU Resolution No. 69 dated June 24, 2026, became another noticeable update to the system. The document came into force on June 26 and changed the rules of authorization for both financial service providers and payment market participants.

Among the practically important changes:

• clarified requirements for certain financial companies and payment service providers;
• key persons of the company were added to some evaluation procedures;
• restrictions on the issuance of debt securities for certain providers of financial payment services were established;
• additional requirements were provided for financial companies dealing with guarantees, currency operations, or certain payment services;
• the NBU’s control over compliance with established restrictions for financial companies was detailed;

A special rule concerns pawnshops that have the right to trade currency valuables in cash. They must develop an activity plan for 2027-2029 and submit it to the NBU by December 31, 2026.

A License No Longer Means the End of Regulatory Procedure

In 2026, the transition from formal document verification to continuous risk-oriented supervision became especially noticeable. A company must comply with regulatory requirements not only on the day it receives the license.

The NBU controls the financial condition, ownership structure, business reputation of managers and significant shareholders, capital, internal control, risk management, and compliance with prudential standards. For some financial companies, updated prudential rules took effect precisely on January 1, 2026.

Therefore, preparation for licensing is advisable to be carried out sequentially:

1. Determine the exact legal model of the future financial service.
2. Check which license or other type of authorization is required.
3. Form the ownership structure and confirm the sources of capital.
4. Verify the business reputation of owners, managers, and key persons.
5. Prepare a business plan, internal policies, and risk management system.
6. Match the actual IT, accounting, and organizational infrastructure with the NBU’s requirements.
7. Before submitting documents, check the current version of regulatory acts.

The last point is of practical importance. During 2026, the rules have already changed several times, so a document package prepared according to an old template may not meet current requirements.

Which Documents and Conditions Should Be Checked in 2026

The specific package depends on the type of institution and financial services. There is no universal set for lending, factoring, financial leasing, guarantees, insurance, and payment services.

Before applying to the NBU, at minimum check:

• the charter and declared scope of activity;
• ownership structure and ultimate beneficiaries;
• sufficiency and origin of capital;
• documents of managers and key persons;
• business plan or activity plan if required for the chosen model;
• internal rules for providing financial services;
• risk management and internal control system;
• financial monitoring, accounting, and information protection;

An error at this stage can affect not only the document review period. If a company starts providing financial services before obtaining the necessary right or goes beyond the scope of the license, the issue moves from business registration to regulatory liability.