Deposit as a shield against enforcement officer no longer works: what the law on digitization of collections changed

Law No. 4833-IX closes popular debt evasion schemes — from term deposits to electronic wallets. However, at the same time, it gives enforcement officers access to funds of individuals who are not even debtors.

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For years, one of the standard pieces of advice Ukrainian lawyers gave debtors was simple: transfer the money to a time deposit. The bank would refuse the bailiff — the deadline hasn't passed. Law No. 4833-IX, adopted on April 7, 2026, closes this loophole. But along with it — several dozen others.

What changes in the logic of debt collection

Until now, a bailiff could seize property, but couldn't always realize it — banks dragged their feet, registries were out of sync, seizures were lifted manually over weeks. The new law puts a significant portion of these processes into automatic mode.

Now, in the collection order, first place is taken by funds in accounts and electronic money in digital wallets. Only if these are insufficient — real estate, vehicles, equipment. This isn't just convenience: it's a change in priority that forces debtors to think twice before holding assets in easily accessible forms.

Closed deposit scheme

Previously, a popular evasion scheme was placing funds in time deposits: the bank refused the bailiff, citing the fact that the deposit term hadn't ended. The new version of Article 48 puts an end to this.

"After receiving a seizure order, the bank has no right to continue the deposit agreement"

Law No. 4833-IX, Art. 48, Part 4

That is, prolongation of a seized deposit is prohibited. The funds remain frozen until the judgment is satisfied.

The most controversial provision: seizure of third-party funds

The most ambiguous novelty is Part 3 of Article 56. A bailiff can now seize funds and electronic money not of the debtor themselves, but of a person who has a debt to them confirmed by court. That is, if your debtor is themselves a creditor — the bailiff can reach the funds in their debtor's account.

This expands the debt collection toolkit, but at the same time raises the question: what protection will be afforded to persons who receive a seizure order without being a party to the proceedings?

The debtors' register — now with teeth

An entry in the Unified Register of Debtors (URD) previously had mainly a reputational effect. Now it blocks transactions: a notary will not certify a contract for alienation or pledge of real estate, vehicles, or mortgages if the owner is in the register. Furthermore, depositary institutions are obligated to check the client in the URD even when opening or closing an account in securities — if a debtor attempts to "cash out" through the sale of shares, the bailiff will learn about it on the day of the transaction.

What is protected

The law preserves and clarifies protections for debtors with small debts:

  • A single dwelling and the land plot under it are not subject to seizure if the debt amount does not exceed 50 minimum salaries (as of 2026 — over 400,000 hryvnia).
  • During martial law, pensions and scholarships cannot be seized — except for debts related to alimony, compensation for harm from crimes, and debts of Russian citizens.
  • A debtor can spend funds from a seized account within two minimum salaries per month.
  • Client funds of investment firms are not subject to seizure — protection against a broker's debts to third parties.

Automation as a systemic change

The law amends more than ten regulatory acts — from the Civil Procedure Code to laws on notaries, the depositary system, real estate registration, and capital markets. As noted in the analysis on dtkt.ua, complete digitalization is taking place: less paperwork, faster data exchange, and seizure after debt satisfaction is lifted automatically — no later than the next day. This simplification corresponds to recommendations from Council of Europe experts on the effectiveness of enforcement of court decisions.

The real test for the law — not its text, but its application: if the mechanism of seizing third parties' funds operates without clear judicial control, it could become an instrument of pressure. Whether court practice will emerge that defines the boundaries of this provision will become clear in the first months after the law takes effect.

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