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NBU Outlines Rules of Operation of Nonbank Services Market Participants Under Martial Law

NBU Outlines Rules of Operation of Nonbank Services Market Participants Under Martial Law

For the duration of martial law, the National Bank of Ukraine has made changes to the regulation of nonbank financial market participants, nonbank financial groups, payment market participants, debt collection agencies, and legal entities licensed to provide cash collection services to banks.

To bolster these NBFIs, the NBU will not subject them to corrective actions for violations of:

  • deadlines for the filing of reporting established by the Rules for the Compilation and Filing of Reports with the National Bank of Ukraine by Nonbank Financial Services Market Participants, approved by NBU Board Resolution No. 123 dated 25 November 2021
  • deadlines for submission of financial statements and consolidated financial statements for 2021 and interim financial statements and interim consolidated financial statements for 2022, compiled on the basis of financial reporting taxonomy in line with international standards in unified electronic format, to the center for collecting financial statements that is run by the National Commission on Securities and Stock Market
  • equity capital availability requirements
  • requirements for the filing of paperwork and provision of information to the regulator as per a number of NBU regulations, including the Regulation On Licensing and Registration.

The NBU has also eased other requirements for some market participants.


Insurers will not come under corrective actions for breaching the required criteria and ratios for capital adequacy, solvency, liquidity, profitability, asset quality, and insurer operations risk.

Credit Unions

Credit unions will not face corrective actions for being in violation of required financial ratios and requirements that limit the risks associated with transactions with financial assets of credit unions. Neither will the regulator apply corrective actions for breach of the terms of regular general meetings of credit union members in 2021.

Financial guarantor companies

Financial Guarantor companies will be exempt from corrective actions for failure to meet required financial ratios and the requirements limiting the risk of transactions involving financial assets.

Nonbank financial groups

Nonbank financial groups, responsible persons, and other members of nonbank financial groups will not come under corrective actions for breach of regulatory capital adequacy requirements and preparation and submission requirements for consolidated and sub-consolidated reports and information.

Note that market participants that are in violation of said requirements will not face corrective actions from the NBU if such violations arose after 23 February 2022 and were caused by the fallout from Russia’s military aggression against Ukraine.

Along with the resolution noted above, the NBU has adopted a number of restrictions for these market participants in order to minimize new risks that have emerged since the launch of the Russian military assault.

Despite martial law having been imposed, nonbank financial market participants must meet their commitments to customers.

In addition, the resolution identifies the specifics of the application of a number of NBU regulations regarding Russian aggression in order to ease the regulatory burden on market participants.  

The novelties outlined above are introduced by NBU Board Resolution No. 39 On Regulating the Activities of Nonbank Financial Market Participants, Nonbank Financial Groups, Payment Market Participants, Debt Collection Agencies, and Legal Entities Licensed to Provide Cash Collection Services to Banks dated 6 March 2022.

The resolution is effective from 6 March 2022.

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