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Ukrainian firms abroad: first weeks of the register, month one

NBU Board Resolution No. 2 entered into force on 14 January 2026. It added a loan limit that lets a resident company pay for the financing of its own foreign standalone units.

Current as of 15 October 2026.

The dates that frame the month

  • The NBU release of January 2026 states that both resolutions were approved on 13 January 2026 and entered into force on 14 January 2026.
  • An earlier NBU release of August 2025 says that Resolution No. 95 is effective 6 August 2025. It is the first act in this sequence that names foreign standalone units.

The loan limit

  • The January release links the limit to a foreign-currency loan credited to a company’s account with a Ukrainian bank after 1 January 2026.
  • The release says that if the principal amount of the loan is repaid, the maximum amount under the loan limit shall be reduced equivalently.
  • The NBU lists the maximum interest rate on the loan shall be 12% per annum and that early repayment of the loan is prohibited.

Investment and donation limits

  • The January release defines it as the amount of funds attracted from abroad in foreign currency into the authorized capital of enterprises from 10 May 2025. The August 2025 release gives a different start date: a company’s investment limit is equal to the amount of FX funds the company has attracted since 12 May 2025. The two NBU texts differ by two days.
  • The January release ties the donation limit to funds transferred by the company from 7 August 2025 into the special account opened by the NBU.

What the releases do not say

  • Neither release says how a newly incorporated foreign company is financed.
  • NBU Resolution No. 90 of 10 August 2026, in force from 11 August 2026, amended Resolution No. 18 again. It names the existing limit on foreign investors’ funds brought into Ukraine the “Investment Limit” and lets a related legal entity use it with the resident’s written consent through one bank; it sets cash limits for business and private accounts. It contains no provision on investments by residents abroad (text of Resolution No. 90; checked 2026-10-19).

Scope of the January rule

Resolution No. 2 of 13 January 2026 covers financing of own foreign standalone units, described in the August 2025 release as units without a legal person abroad.

  • The January rule fits a branch or representative office more clearly than a new foreign company. The releases say nothing on the second case.
IndicatorValueSource
ActNBU Board Resolution No. 2, approved 13 January 2026, in force from 14 January 2026NBU release, January 2026
Basis of the loan limitForeign-currency loan credited to a company’s account with a Ukrainian bank after 1 January 2026NBU release, January 2026
Purpose of the loan limitFinancing of the company’s own foreign standalone unitsNBU release, January 2026
Maximum interest rate on the loan12% per annumNBU release, January 2026
Early repayment of the loanProhibitedNBU release, January 2026
Start date of the investment limit10 May 2025 (January 2026 release); 12 May 2025 (August 2025 release)NBU releases, January 2026 and August 2025
Donation limitFunds transferred by the company from 7 August 2025 into the special account opened by the NBUNBU release, January 2026
Foreign standalone unitsUnits without a legal person abroadNBU release, August 2025
Resolution No. 90, August 2026Verified against the text of the resolution; no outbound-investment provisionChecked 2026-10-19

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