As Ukraine continues its economic stabilization and takes steps to encourage investment, the National Bank of Ukraine (NBU) has taken another significant step toward unwinding wartime currency controls. NBU Resolution No. 53, dated May 9, 2025, just came into effect launching what the NBU calls a “stimulating currency liberalization” mechanism, designed to attract foreign capital while maintaining macroeconomic stability.

This latest easing continues the phased rollback of emergency currency restrictions first introduced in February 2022, when martial law was declared in response to Russia’s full-scale invasion. Dentons has closely followed and reported on these changes, from the initial imposition of martial law currency measures (February 2022) to key liberalizations adopted over the past two years (June 2023, June 2023 – Cross-Border Loans, May 2024).

A new incentive for foreign investment: the “Investment Limit”

The central feature of this latest initiative is the introduction of an “investment limit,” a novel currency control concept introduced for the purpose of lifting certain cross-border payment restrictions within the amount of funds in foreign currency invested into a Ukrainian company’s authorized share (charter) capital after May 12, 2025.

Within such investment limits, a Ukrainian company with corresponding foreign investments is allowed to perform certain cross-border payments that, under the general rule in effect during martial law, are otherwise prohibited. In particular, such companies may now:

• Repay foreign loans received before June 20, 2023
• Pay for goods imported before February 23, 2021
• Refund prepayments to non-residents for goods that were never delivered, if the payment was made before February 23, 2022
• Finance its subsidiary, representative office abroad

This model encourages direct capital injections into Ukrainian enterprises while providing a path to service longstanding cross-border obligations. According to the NBU, Ukrainian companies are currently burdened with approximately US$21 billion in foreign debt (including interest) and US$3.2 billion in unpaid import obligations. The new mechanism enables an inflow of foreign investment that can support these outflows without increasing pressure on the foreign exchange market.

Additional measures to support business

Alongside the investment limit framework, the NBU has also implemented a series of targeted relaxations to support business activity and international operations:

• Expanded ability to finance foreign representative offices of Ukrainian companies
• Permission for FX payments related to legal disputes over non-performance of foreign trade contracts by non-residents
• Higher spending limits for corporate cards used abroad
• Authorization of certain forward FX transactions to help manage financial risk

These refinements reflect the regulator’s calibrated approach—balancing liberalization to support investment and growth, while maintaining protections against capital flight and speculation.

While full currency liberalization remains a longer-term goal, the NBU’s investment-linked approach marks a creative and practical interim solution.

The full NBU resolution (available in Ukrainian) can be found here.

Dentons will continue to monitor regulatory developments and stands ready to advise clients on how to structure and document qualifying foreign investments under the new investment limit regime.

If you’re looking to learn more about Ukraine and interested in our analysis and insights around the current business environment and the opportunities for international investors keen to be part of Ukraine’s transformation and rebuild, please visit our Ukraine transformation and rebuild hub where you can find more content such as this and other articles highlighted in this piece. Also please follow us on our Dentons Ukraine LinkedIn page for the most up-to-date legal developments.