The banking sector is sufficiently resilient and capitalized. The banks that account for the vast majority of the sector’s assets have sufficient capital to continue lending and remain solvent even in a deep and protracted crisis. However, a number of the banks need to take measures to improve their resilience against possible crisis episodes going forward. This is according to the 2025 resilience assessment of the banks and the banking system.
By tradition, this year’s resilience assessment of the banks consisted of:
- asset quality review and collateral eligibility assessment conducted by external auditors for all of the banks
- extrapolation of asset quality review results (where necessary)
- stress testing (under baseline and adverse macroeconomic scenarios) of the 21 largest banks jointly accounting for 90% of the sector’s assets.
The results of the asset quality review reaffirmed the correctness of the banks’ assessment of credit risk (prudential provisions). Overall, the auditors made minor adjustments to credit risk. These had no impact on the capital adequacy ratios of most banks that underwent only an asset quality review. Based on the results of the resilience assessment, just one such bank had a required capital ratio set for it above the minimum level.
Of the 21 stress-tested banks, 9 had higher required capital adequacy ratios set for them. These banks hold a combined 18% of the sector’s net assets. Three of these banks – two state-owned and one private with a combined 13% of sector assets – need capital only under the adverse scenario. Three of the banks facing higher required capital adequacy ratios under the baseline scenario are already holding sufficient levels of capital and must maintain them. Another three of the banks that must raise their capital adequacy ratios to the required levels under the baseline scenario jointly account for only 3% of the sector’s assets. The rest are sufficiently capitalized.
Taking into account the current year’s adverse scenario, the overall estimated need for capital based on stress-test results is about 5% of the banking system’s regulatory capital as of early 2025. This is almost one-third of the need revealed by the 2021 resilience assessment. Compared to the results of the resilience assessments conducted before the full-scale invasion, the number of banks that must meet increased capital adequacy requirements has declined. According to the 2025 stress-test results, the banks’ total capital was rising in every scenario, whereas in 2021, the system’s capital as a whole was shrinking in the adverse scenario.
To ensure their resilience, the banks must achieve and maintain the capital adequacy ratios set by the NBU or take steps to reduce risk by restructuring their balance sheets. These measures can include improving loan portfolio quality, optimizing the structure of assets and liabilities, or adjusting the business model. As usual, the banks more often choose the path of restructuring their balance sheets, an option that takes more time.
To give the banks time to implement their programs, the deadline for taking action to achieve the required capital adequacy ratios under the adverse scenario was pushed back to the end of September 2026. This extension was formalized by NBU Board Resolution No. 101 On Amendments to Certain Regulations of the National Bank of Ukraine on the Resilience Assessment of Banks and the Banking System of Ukraine in 2025 dated 27 August 2025.
The financial institutions will thus be able either to resolve their issues (that led to higher required capital ratios being set for these banks based on stress-test results) or to build up capital.
Further information on the resilience assessment findings, broken down by bank, will be published in late December 2025.