The Verkhovna Rada adopted a financial inclusion law on June 3, 2025 — with 260 votes against a minimum of 226. It was published on December 25. Now the NBU is preparing the regulatory framework: a draft resolution with procedures and requirements for obtaining a limited banking license. It will take effect on June 26, 2026 — after public consultation.
Why a regular license doesn't work
The minimum charter capital for a regular bank is 200 million hryvnias (the Council lowered the bar from 500 million). For most postal operators, cooperatives, or regional financial institutions that could theoretically serve small communities, this is an unaffordable amount. This is why the NBU began developing the concept of a "financial inclusion operator" with relaxed requirements back in 2024.
NBU Governor Andriy Pyshnyi explained the logic to Forbes during the discussion phase: the focus is primarily on frontline and de-occupied territories where financial infrastructure is virtually non-existent. As one of the state managers involved in developing the concept noted,
"This is essentially about loans for farms, because other players don't want to enter this niche, even Oschadbank."
state manager involved in developing the BFI concept, Forbes
What a financial inclusion bank can — and cannot — do
Law No. 4465-IX defines BFI as a separate type of bank with a limited license. Key restrictions discussed during development:
- No foreign exchange operations — currency trading is prohibited to avoid speculation;
- Loans — only for SMEs: micro, small and medium businesses, farmers, and amalgamated territorial communities;
- Services for individuals, businesses, public organizations and local authorities — directly provided for by law.
At the same time, the NBU insists: investor requirements are the same as for regular banks. As the regulator emphasized, "the financial stability of an institution with such social status cannot be undermined." In other words, a "simplified" license is not synonymous with reduced oversight.
Where the delay is
More than six months passed between the law's adoption in June and its publication — the document was only signed on December 25, 2025. Interfax-Ukraine requested information from the NBU about the reasons for the presidential delay. The regulator responded that it is interested in the fastest possible entry into force, but does not know the reasons for the delay.
The first applications for a BFI license can be submitted in summer 2026. The NBU is simultaneously preparing separate measures to expand the physical presence of financial institutions — since, as the regulator itself acknowledges, financial inclusion is not limited to a new type of bank.
A practical question that remains unanswered: if even Oschadbank refused to operate in frontline areas due to risks, will private investors be found willing to meet the same capital requirements — but with a smaller market and greater danger?
