When a tenant pays for elite apartments exceeding 400,000 hryvnias per month, their real estate agent is no longer simply drawing up a contract — they become a subject of financial monitoring. The Ministry of Finance clarified this nuance in response to LIGA.net's inquiry: rules on rental have existed for a long time, but are only being practically enforced starting February 2026.
Two Thresholds, Two Regimes
For real estate sales and purchases, the financial monitoring threshold is 400,000 hryvnias from the transaction value. For rental — the same amount, but based on the monthly payment. This is a separate limit that in practice applies to a narrow market segment: premium rentals in major cities.
However, as the Ministry of Finance clarifies, real estate agents do not automatically report every transaction above the threshold — the obligation to submit data on "threshold financial transactions" does not apply to them. This is a requirement for banks and other financial institutions. Instead, a real estate agent is obligated to identify the client, assess risks according to the "know your customer" principle, and notify the State Financial Monitoring Service only about suspicious transactions — that is, those meeting the risk criteria approved by the Ministry of Finance.
An Old Law, A New Mechanism
The key paradox of the situation lies in its timeline. The Anti-Money Laundering Law No. 361-IX has been in effect for several years, but its provisions regarding real estate agents were essentially not enforced. Starting February 2026, the Ministry of Finance, together with the State Financial Monitoring Service, launched an updated digital tool — the ICE "E-Cabinet of the Financial Monitoring System," through which real estate agents must register and submit reports.
"This year's appeal to real estate agents is related not to the emergence of new requirements, but to the updating of information exchange mechanisms with the State Financial Monitoring Service and the need to verify proper registration."
Ministry of Finance of Ukraine
In simpler terms: the law existed in theory, but there was no tool to enforce it. Now the tool has appeared — and the Ministry of Finance held clarification meetings for over 800 representatives of the real estate community, accountants, and consultants.
"Triple Control" — Or Duplication?
The real estate market received the innovation skeptically. Some real estate agents point out: financial monitoring functions are already performed by banks and notaries, who verify transactions during settlements and contract authentication. Adding real estate agents to this chain creates, according to Andriy Romanov, head of the "KyivDimService" real estate agency, a de facto "triple control" — without clear distribution of responsibility among participants.
The Ministry of Finance promises a transitional approach: at the initial stage — training rather than immediate fines. Specific penalties for non-compliance with requirements have not yet been named in the ministry's public clarifications.
What This Means in Practice
- A real estate agent accompanying rental of housing costing more than 400,000 hryvnias/month is obligated to identify the tenant and landlord.
- Suspicious signs of a transaction — cash payment, discrepancy between the tenant's income and the price, unusual payment structure — become grounds for notifying the State Financial Monitoring Service.
- A real estate agent without registration in the e-cabinet is already formally violating the law.
- For the mass rental segment — apartments up to 50–100,000 hryvnias/month — the rules have not changed.
A practical question remains unanswered: if a real estate agent identifies a suspicious rental transaction and reports it, while a notary and bank do not, whose risk assessment version will have priority and who will be held accountable for inaction? The Ministry of Finance's clarifications do not yet provide an answer.
