Recent measures taken by the National Bank of Ukraine support long-term and export-related lending

Since the beginning of the full-scale war, the Ukrainian economy has faced a strong need for long-term financing, both for on-going business needs and for reconstruction projects. Banks remain the primary channel of financing the real sector. At the same time, the National Bank of Ukraine (the “NBU”) has focused on keeping the banking system stable and preserving confidence in the banking sector, which in 2022–2023 meant rather strict requirements and a number of temporary restrictions.

Over time, the NBU has started to gradually adjust these wartime restrictions and to introduce more targeted measures which, in addition to preserving stability, are also aimed at supporting lending.

 In 2024 this approach was reflected, in particular, in the NBU’s Lending Development Strategy, and recent regulatory changes are another step in this direction. In October and November 2025, the NBU adopted several amendments to its rules on mandatory reserves and credit risk calculation. These changes give banks, from a regulatory perspective, more flexibility to use certain types of long-term funding from qualifying foreign institutions and to provide loans backed by guarantees and insurance from the Export Credit Agency of Ukraine.

The key points of these changes and their possible impact on Ukrainian corporate borrowers and exporters are briefly outlined below.

Bank reserves relaxation for long-term funding

Mandatory reserves are a portion of the funds raised by a bank which must be kept on its accounts with the NBU in accordance with the regulator’s reserve requirements. For the period of reserve maintenance, the bank cannot use these funds for lending or other active operations, so for the bank they are effectively “frozen”.

The NBU’s rules also specify a list of liabilities that are excluded from the reserve base. Traditionally, such exclusions have applied to certain funds raised from, or held with, other banks and international financial institutions (“IFIs”). By Resolution no.125 dated 10 October 2025, the NBU extended this list to provide that banks are no longer required to maintain mandatory reserves against forcibly seized funds pursuant to the Law of Ukraine “On the Basic Principles of Forcible Seizure in Ukraine of Property Rights of the Russian Federation and its Residents” and against frozen funds pursuant to Ukrainian sanctions legislation.

An important exemption from mandatory reserves requirement introduced by the Resolution no.125 is long-term borrowings (with a tenor of over one year) from non-resident legal entities in which a foreign state and/or an IFI holds at least 10 per cent of the share capital. This category may include, for example, foreign state-owned or development banks and certain development finance institutions or funds in which IFIs hold at least a 10 per cent stake.

For banks this means that long-term loans from qualifying non-resident entities become a less expensive source of funding from a regulatory point of view, since they do not increase the amount of mandatory reserves. In effect, this should improve the terms on which banks can use such funding for lending to reconstruction and other investment projects, although commercial and credit factors will, of course, remain decisive.

Recognition of ECA guarantees and insurance for credit risk purposes

Private Joint Stock Company “Export Credit Agency” (“ECA”) is a state-owned company which supports Ukrainian exporters by providing insurance, re-insurance and guarantees for export-related loans and transactions, so that banks are more comfortable to finance such projects.

Pursuant to Resolution no.139 dated 15 November 2025 the NBU introduced amendments to its regulation governing the assessment by banks of credit risk under active banking operations and the amount of regulatory capital they must hold, insofar as it relates to guarantees and insurance policies issued by the ECA. 

Prior to these amendments, banks could recognise ECA guarantees and insurance as eligible collateral only if the total amount of ECA’s obligations under all its insurance and guarantee contracts did not exceed the amount of ECA’s own capital. This was a straightforward but quite strict test, which could limit the volume of transactions that ECA could support.

Resolution no.139 changed this approach. Now the key condition is that ECA must comply with the capital adequacy and solvency requirements set out in the separate NBU regulation governing ECA and that ECA does not have overdue obligations under its insurance and guarantee contracts for more than 90 days (except for cases set forth by the export support legislation). In other words, instead of using one rough limit, the NBU now relies on a full prudential supervision of ECA. This change does not remove capital constraints for ECA. The agency is still limited by its own capital and by the prudential ratios set by the NBU. The difference is that ECA cover now depends on a broader capital and solvency requirements, which also takes into account the overall risk level of ECA’s portfolio.

For banks this means that, as long as ECA meets its regulatory capital and solvency ratios and properly performs its obligations, ECA guarantee and insurance may be recognised as eligible collateral (subject to a 0.85 liquidity coefficient) when calculating credit risk on ECA-covered financing. It is expected to facilitate a wider use of ECA products in financing export, but the final decision on each transaction will still depend on the bank’s own risk appetite and credit analysis.

Implications for bank clients

For Ukrainian exporters, the above regulatory developments may make ECA-backed products more accessible in practice. If ECA guarantees and insurance are easier for banks to recognise as collateral for regulatory purposes, it can facilitate approval of such deals by bank credit committees. As a result, we may see more attention from banks to products such as export loans with ECA insurance, bank guarantees insured by ECA and investment projects where part of the political or commercial risk is covered by ECA.

For corporate clients this is a good moment to review available ECA instruments and to discuss with their relationship banks whether ECA cover could help in specific export or investment transactions. In many cases, ECA support can also reduce the amount of conventional collateral required by the bank. Banks may therefore be prepared to rely on a combination of ECA cover and “hard” security (such as cash, real estate or other assets), rather than requiring full coverage by traditional collateral, although this will always depend on the bank’s internal policy and the risk profile of a particular deal.

For borrowers involved in re-/construction projects (infrastructure, energy, logistics, etc.), long-term funding provided to their banks by foreign development and other qualified institutions may also become more relevant. As mentioned above, long-term borrowings of Ukrainian banks from certain non-resident lenders with foreign state or IFI participation do not create additional mandatory reserve requirements.

As a practical matter, this category would typically include institutions such as KfW and its subsidiary DEG (Germany), FMO (the Dutch development bank), Proparco (part of the French AFD Group), when they provide long-term facilities to Ukrainian banks. Many of these institutions already operate in Ukraine through SME credit lines, trade finance and other programmes with local banks, and the new reserve treatment improves the economics of such funding from the bank’s perspective. For clients, it is therefore advisable to ask their banks whether they have limits or special programmes with particular institutions, IFIs or development banks and to prepare projects in a way complying with the basic requirements of such programmes (for example, transparency, ESG aspects, procurement rules, reporting, etc.).