The National Association of Banks of Ukraine and the Association of Ukrainian Banks signed on May 14 an updated version of the memorandum on transparency of the payment services market. This is not a law or an NBU resolution — banks are taking on obligations voluntarily. The original document came into effect in February 2025 and has already limited transfers by individuals without confirmed income to 50–100 thousand UAH per month. Now the effect of the limits extends to sole proprietors (FOP).
Who will be affected and when
The new rules apply to two types of entrepreneurs: newly created FOPs (up to 6–12 months of existence depending on the internal rules of a particular bank) and "dormant" ones — those who resume activity after a long break. Changes are being introduced in two stages.
- August 2025 — first threshold: Group 1 FOPs — up to 600 thousand UAH per month, Groups 2 and 3 FOPs — up to 3 million UAH per month.
- November 2025 — second threshold: Group 1 FOPs — up to 400 thousand UAH, Groups 2 and 3 FOPs — up to 1 million UAH per month.
- For legal entities of an analogous category, the limit in November will be up to 2 million UAH per month.
These restrictions will apply only to those who do not provide the bank with documentary proof of income — for example, a single tax declaration. Documents can be submitted and the limit increased at any time.
Declaration ≠ obligation
The memorandum is an industry agreement, not a regulatory act. Participating banks commit to implementing automated transaction monitoring, enhanced customer verification, and information exchange about suspicious clients among themselves. However, the document does not provide for any external arbiter to record violations of the memorandum terms.
"If any bank fails to conduct proper financial monitoring, it may in the future face NBU penalty sanctions, or even license revocation"
lawyer Lankin, UNIAN
That is, the only real deterrent is the NBU, which has the right to inspect banks even without a memorandum. The document itself contains no sanctions for non-compliance.
Why exactly FOPs
According to representatives of the associations, the purpose of the changes is to counter tax minimization schemes and "dropping": one-day entrepreneurs or previously inactive FOPs are used to transit funds without a fiscal trail. As Interfax-Ukraine reports, the concept of a "new" entrepreneur in accordance with NBU Resolution No. 65 may cover 6 to 12 months of existence — meaning banks will have some freedom of interpretation.
An important nuance: the limits do not apply to FOPs with confirmed income. An entrepreneur with declared income corresponding to turnover will not automatically fall under the restrictions.
If banks do not form a unified technical standard for exchanging data about suspicious clients by August, the memorandum risks remaining a set of good intentions with different interpretations at each individual bank.
