Quick take
The National Bank of Ukraine in a new Financial Stability Report recommends that the Verkhovna Rada lift the blanket moratorium on resolving distressed mortgages introduced after the full-scale invasion. The NBU stresses: the moratorium currently covers about UAH 35 billion in gross loans, of which more than 80% have already been classified as NPLs — and this keeps the market in a state of uncertainty.
"Although the ban does not apply to new mortgages, it creates uncertainty about the ability to enforce collateral in case of loan non‑payment and pushes mortgage rates up. Therefore, such a blanket moratorium should be lifted, and the practice of applying moratoria should be reviewed."
— The National Bank of Ukraine, Financial Stability Report
Why this matters to you
Uncertainty about creditors' rights raises risks for banks and, as a result, is reflected in higher rates for borrowers. If the Rada supports lifting the blanket moratorium in favor of targeted restrictions, this could reduce the risk premium and make mortgages more affordable for those planning to buy homes during the country's reconstruction.
What the NBU proposes
The regulator is not calling for a complete removal of protections for those affected. The NBU proposes moving from general moratoria to targeted measures that take into account the actual condition of the property and the borrower's circumstances. One example is a ban on enforcing collateral if the property was destroyed as a result of hostilities.
"An example of measured restrictions could be a ban on seizing mortgaged property that has been destroyed. According to banks, collateral securing UAH 21 million in loans was destroyed as a result of hostilities."
— The National Bank of Ukraine, Financial Stability Report
Experience and risks
The NBU points to the positive effect seen in 2021 after the moratorium on resolving old foreign‑currency mortgages was lifted: the market began to clear and bank portfolios stabilized. At the same time, the decision requires precision: a hasty or inconsistent lifting could create social tensions or complicate matters for families who have truly been affected.
What this means for state programs
There are also moves in the other direction in the public sector: on December 12 the Cabinet of Ministers decided to recapitalize "Ukrfinzhytlo" by UAH 30 billion, which will allow about 18,000 families to take advantage of the affordable mortgage program. A combination of targeted market reforms and support for state programs could accelerate the recovery of housing finance.
Conclusion
The decision on the moratorium is not just a technical matter for banks. It concerns access to credit, the cost of loans, and the pace of housing reconstruction after destruction. The NBU offers a compromise: fewer blanket bans, more fine‑tuned regulation that protects those affected while restoring investor and bank confidence.
Now the question is for Parliament: will it find the balance between protecting citizens and restoring the functions of the credit market?
