NBU changes the rules: lowering minimum ratios and mandatory buffers
The National Bank of Ukraine (NBU) has officially announced a set of changes to capital requirements for commercial banks, combining a reduction of minimum ratios with the introduction of mandatory buffers. The decision takes effect on January 1, 2027 — and aims to strengthen the resilience of the banking system and align regulatory standards more closely with EU practices.
What exactly the regulator decided
The NBU is lowering key capital adequacy ratios:
regulatory capital: from 10% to 8%;
Tier 1 capital: from 7.5% to 6%;
common equity Tier 1 (CET1) capital: from 5.625% to 4.5%.
At the same time, a mandatory capital conservation buffer of 2.5% is being introduced for all banks, and for systemically important banks an additional systemic importance buffer of 1% to 2% will apply.
"The purpose of building capital buffers is to create a reserve to increase banks' ability to withstand risks during periods of financial and economic instability. At the same time, the presence of capital buffers provides the necessary flexibility in regulatory requirements, as it allows the accumulated resilience to be used during crises to support lending activity..."
— Press Service of the National Bank of Ukraine
Why this is being done (rationale)
The strategy combines two approaches: lower formal minima and, instead, ensure a reserve of strength in the form of buffers. Previously, Ukrainian banks compensated for the absence of buffers with higher minimum requirements. Now the NBU proposes a different balance — lower "thresholds" but a clear reserve that can be mobilized in a crisis. This aligns with practices of European regulators and gives banks greater flexibility without reducing the overall resilience of the system.
Buffers had previously been planned to be introduced in phases by 2020–2023, but the requirements were postponed first due to the COVID-19 pandemic, and then because of the full-scale war. Now the NBU is bringing this instrument back in an updated form.
Who this applies to
The new rule applies to all commercial banks in Ukraine. The list of systemically important credit institutions subject to the additional buffer includes: А-Банк, Ідея Банк, Креді Агріколь Банк, Кредобанк, ОТП Банк, Ощадбанк, Південний, ПриватБанк, ПУМБ, Райффайзен Банк, Сенс Банк, ТАСкомбанк, Укргазбанк, Укрексімбанк, Укрсиббанк, Універсал Банк.
What this means for depositors and borrowers
In short: the goal is to strengthen depositor protection and preserve lending activity during shocks. For clients this does not mean immediate changes to rates or contract terms, but it increases the likelihood that banks will have resources to support lending in crisis conditions. For the market, it is a signal of aligning rules with European standards and of the regulator's intent to balance financial resilience and access to financing.
Conclusion
The NBU's decision is not about reducing protection, but about restructuring its mechanisms: instead of high permanent "minimums" — a combined approach with buffers that can be mobilized in a crisis. The next step is how banks will plan buffer accumulation by 2027 and how quickly this will turn into an additional safety cushion for the economy. Whether it will be possible to combine flexibility for banks with reliable protection for society depends on the implementation of the rules and the regulator's supervision.
