The National Bank of Ukraine on June 16 published its annual list of systemically important banks for 2026. It remained unchanged: the same 16 institutions as last year. But "nothing has changed" is not quite an accurate description of the situation.
Who made the list
The list of systemically important banks includes: A-Bank, Ideya Bank, Crédit Agricole Bank, Kredobank, OTP Bank, Oschadbank, Pivdennyi, PrivatBank, PUMB, Raiffeisen Bank, Sens Bank, TAScombank, Ukrgasbank, Ukreximbank, Ukrsibbank, and Universal Bank. The NBU determines the list annually as of January 1 based on the share of assets, deposits, and loans in the total banking system.
What this status really means
Making the list is not a reward. A systemically important bank is subject to enhanced supervision and must comply with stricter capital standards. The logic is simple: if such a bank fails, it brings down not only its customers but also related sectors of the economy. This is why the regulator is willing to limit their freedom of action in advance in exchange for a guarantee of stability.
"Capital buffers should create a reserve to increase banks' ability to withstand risks during periods of financial and economic instability."
NBU, March 2026
What changes from 2027
The list is the same, but the rules of the game for its participants are not. From January 1, 2027, the NBU is reinstating the capital buffer requirement that was in effect before the full-scale invasion and was then suspended. The specific figures:
- Capital conservation buffer — 2.5% for all banks without exception.
- Systemic importance buffer — from 1% to 2% depending on the bank's category. These 16 institutions will be affected first and foremost.
To make the transition less abrupt, in 2026 banks are already applying new requirements at 50% of the full amount of additional capital. From 2027 onward — all 100%. In parallel, the NBU plans to reduce basic capital adequacy standards to European standards levels — compensation for previously artificially inflating them due to the absence of buffers.
Stress tests as the next step
Separately from the list of systemically important banks, the NBU is preparing in 2026 an assessment of the resilience of 26 largest institutions — AQR and stress tests under baseline and adverse macroeconomic scenarios. The sample will include banks with the largest assets, deposits, and household credit portfolios, as well as those that already needed recapitalization based on the results of previous checks.
So the real burden on the banking system is not that the list remained unchanged, but that the requirements for its participants are continuously increasing. A stable list and an unstable environment — a combination that will test whether enough capital has been accumulated before a crisis raises this question itself.
If the results of 2026 stress tests reveal a capital deficit in at least a few systemic banks — will there be enough time until 2027 to close it without state injections?
