The NBU is making changes to its reserve requirements for the banks in order to increase the efficiency of money market regulation while under martial law and stimulate inflows of external financing.
Starting 10 November 2025, forcibly seized and sanctioned funds are no longer included in the calculation of reserve requirements. Such funds are:
- money seized under the Law of Ukraine On Basic Principles of Forced Seizure in Ukraine of Property Assets of russia and its residents, and money taken possession of upon seizure as per this law
- funds frozen due to the application of special economic and other restrictive measures under the Law of Ukraine On Sanctions.
The primary purpose of these changes is to optimize existing approaches to reserve requirements calculation, as such funds are essentially immobilized and have no effect on monetary processes. These changes will not have a significant impact on the banking system’s total required reserves.
Furthermore, effective 10 December 2025, calculation of reserve requirements will not include loans taken out by the banks for longer than one year from non-resident legal persons that have a foreign state as a shareholder and/or have at least 10% of their authorized capital funded by international financial institutions (IFIs).
The algorithm to calculate reserve requirements does not currently include all of the loans raised from IFIs. These novelties will better incentivize the banks to mobilize long-term funds to finance reconstruction projects.
Said changes were made by:
- NBU Board Resolution No. 125 On Amendments to the Regulation on the Procedure for Creating and Maintaining the Required Reserves by Ukrainian Banks and Branches of Foreign Banks in Ukraine dated 10 October 2025
- NBU Board Decision No. 373 On Amendments to NBU Board Decision No. 752 dated 23 November 2017 dated 10 October 2025.
Considering said changes to how the reserve requirement ratio is calculated for seized and sanctioned funds, corresponding amendments have been made to NBU Board Resolution No. 23 On Certain Issues of Activities of Banks and Banking Groups in Ukraine (as amended) dated 25 February 2022. These amendments will take effect on 10 December 2025.