Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the NBU's register entry, including banking and payment rails.
Get a payment license in Ukraine.
Ukraine replaced its old payment rules with a PSD2-shaped statute in 2021: the Law on Payment Services, in force since 1 August 2022. The National Bank of Ukraine licenses payment institutions and e-money institutions by entry in its Register of Payment Infrastructure, decides within 60 working days of a complete file, and asks for UAH 1 million to 10 million of authorised capital depending on the services. The law also created small payment institutions, accreditation for foreign branches, a sandbox and open banking.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Ukraine in brief
A PSD2-shaped law, four capital tiers in hryvnia, and a 60-day clock.
Law No. 1591-IX of 30 June 2021 rebuilt Ukrainian payments law around the EU model and took effect on 1 August 2022. Article 10 lists who may provide payment services: banks, payment institutions including small ones, branches of foreign payment institutions, e-money institutions, financial institutions with payment rights, postal operators, and providers of non-financial services such as payment initiation and account information, which register rather than license. Article 16 sets the authorised capital, to be paid only in money: UAH 1 million for payment initiation or transfers without an account, UAH 3 million for both together or for one of the financial payment services in points 1 to 5 of Article 5, UAH 5 million for several of those services or for a postal operator, and UAH 10 million to issue electronic money. Article 11 gives the NBU 60 working days from receipt of the application and a complete set of documents to license or refuse; the procedure sits in NBU Regulation No. 217 of October 2022.
Two features are worth knowing before you plan. A small payment institution under Article 13 serves Ukraine alone within volume limits the NBU sets, on a simplified licence, and has 240 days to re-license if it outgrows them. And a foreign payment institution may operate through an accredited branch under Article 14 - unless it is controlled by residents of a state the law names as an aggressor. The statute carries a regulatory sandbox, and the NBU approved open-banking rules on 25 July 2025. Settlement runs on the NBU's System of Electronic Payments, SEP. Corporate tax is 18% at the base rate, 25% for financial institutions, with 20% VAT and 15% withholding on dividends to non-residents; which rate a payment institution falls under is checked for your structure. We run the file from Budapest, in Ukrainian and Russian, and plan on six to nine months.
Law No. 1591-IX (in force 1 August 2022) licenses payment institutions and e-money institutions by entry in the NBU's Register of Payment Infrastructure. Capital in money only: UAH 1M / 3M / 5M by service, UAH 10M for e-money (Article 16). Decision within 60 working days of a complete file (Article 11).
Small PI for Ukraine alone (Article 13); foreign branches by accreditation (Article 14). Sandbox and open banking (NBU rules of 25 July 2025). 18% tax, VAT 20%. Six to nine months realistic. We run it from Budapest.
The routes
Payment institution, e-money institution - or a small PI for the domestic market.
Three NBU routes at three depths: the full payment institution for any of the financial payment services, the e-money institution on UAH 10 million, and the small payment institution for Ukraine alone. We fix the route first, then build once.
Payment institution or e-money institution - small PI for the domestic market.
01 - PAYMENT INSTITUTION
Платіжна установа
A licence entered in the NBU's Register of Payment Infrastructure for the financial payment services of Article 5 - UAH 1, 3 or 5 million of authorised capital by service under Article 16, paid only in money, with a 60-working-day decision under Article 11 and the corporate-governance and risk-management duties of Article 15.
A licence entered in the NBU's Register of Payment Infrastructure for the financial payment services of Article 5 - UAH 1, 3 or 5 million of authorised capital by service under Article 16, paid only in money, with a 60-working-day decision under Article 11 and the corporate-governance and risk-management duties of Article 15.
- ✓Transfers, account services, acquiring, initiation
- ✓Capital UAH 1M / 3M / 5M (Article 16(3))
- ✓Capital paid in money only (Article 16(1)-(2))
- ✓Decision within 60 working days of a complete file
- ✓Small-PI variant for Ukraine alone (Article 13)
- ✓Commercial agents entered in the Register
02 - E-MONEY INSTITUTION
E-money - UAH 10MУстанова електронних грошей
The licence to issue electronic money and execute payment operations with it - UAH 10 million of authorised capital under Article 16, the NBU's prudential ratios under Regulation No. 190 of August 2022, and the same 60-working-day decision and Register entry.
E-money institution: UAH 10,000,000 capital; NBU prudential ratios (Reg. 190/2022); same 60-day decision and Register entry.
- ✓E-money issuance and payment operations with it
- ✓Capital UAH 10,000,000 (Article 16(3))
- ✓Prudential ratios per NBU Regulation No. 190/2022
- ✓Register of Payment Infrastructure entry
- ✓Agents and distributors registered with the NBU
- ✓Foreign branches by accreditation (Article 14)
Costs and timelines are confirmed for your case before any work begins. State charges follow the NBU's tariff schedule; they, the safeguarding set-up and substance are itemised in your quote.
Why Ukraine
The EU's payment model, written into a market of its own.
Ukraine took PSD2's architecture - service list, capital tiers, registers, open banking - and applied it to a country with a bank-run instant rail and a fintech habit. The licence is the way into that market on its own terms.
✓
A PSD2-shaped statute
Law 1591-IX copies the directive's service list and licence types, so a file built for an EU application translates into the NBU's format with the articles renumbered, not the logic.The EU model, renumbered.
✓
Capital in hryvnia
UAH 1, 3, 5 or 10 million under Article 16 - four tiers matched to the services, paid in money only, and an order of magnitude below the EU's euro floors at current rates.UAH 1M-10M by service.
✓
60 working days
Article 11 gives the NBU 60 working days from a complete file to decide - a clock in the statute rather than a service standard.A clock in the statute.
✓
A small-PI door
Article 13 lets a domestic business start on a simplified licence within NBU volume limits, with 240 days to upgrade when it outgrows them.Domestic start, 240 days to upgrade.
✓
Open banking and a sandbox
The law carries a regulatory sandbox, and the NBU approved its open-banking rules on 25 July 2025 - account access and initiation are in the statute, not in a roadmap.NBU rules since July 2025.
✓
SEP
The NBU's System of Electronic Payments settles in real time and in batches; a licensee's rails are planned against it from the first design.Real-time and batch settlement.
How it compares
How Ukraine differs from other routes.
Ukraine offers a PSD2 structure without a passport, at hryvnia capital and a statutory clock. The honest comparison is below.
Ukraine vs other jurisdictions
| Feature |  Ukraine | Other jurisdictions |
|---|---|---|
| Capital | UAH 1M / 3M / 5M · e-money 10M | EUR 20,000-350,000 in the EU |
| Decision clock | 60 working days from a complete file | 3 months, or none |
| Passport | None - domestic licence | EEA passport from EU states |
| Corporate tax | 18% · 25% financial institutions | 9-25% |
Capital
UkraineUAH 1M / 3M / 5M · e-money 10M
Other jurisdictionsEUR 20,000-350,000 in the EU
Decision clock
Ukraine60 working days from a complete file
Other jurisdictions3 months, or none
Passport
UkraineNone - domestic licence
Other jurisdictionsEEA passport from EU states
Corporate tax
Ukraine18% · 25% financial institutions
Other jurisdictions9-25%
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Ukraine | PI / EMI (NBU) | 18% | UAH 1M-10M · 60 working days |
 Moldova | PI / EMI (BNM) | 12% | MDL 350k-2.2M · 60 working days |
 Kazakhstan | NBK registration · AFSA PMS | 20% · AIFC 0% | USD 50k base (AIFC) |
 Poland | PI / EMI (KNF) | 19% | PSD2 floors · EEA passport |
UkraineLicense typePI / EMI (NBU)
Taxation18%
RequirementsUAH 1M-10M · 60 working days
MoldovaLicense typePI / EMI (BNM)
Taxation12%
RequirementsMDL 350k-2.2M · 60 working days
KazakhstanLicense typeNBK registration · AFSA PMS
Taxation20% · AIFC 0%
RequirementsUSD 50k base (AIFC)
PolandLicense typePI / EMI (KNF)
Taxation19%
RequirementsPSD2 floors · EEA passport
Before you apply
Requirements for the NBU licence.Requirements for the licence.
The law sets the capital, the clock and the categories; NBU Regulation No. 217 of 2022 sets the documents. The checklist below is what a passing file contains.
01
A legal entity under Ukrainian law - or a foreign payment institution applying for branch accreditation under Article 14, provided it is not controlled by residents of a state the law names as an aggressor.
02
Authorised capital at the Article 16 tier - UAH 1, 3, 5 or 10 million - formed and paid exclusively in money, with the source of funds documented.
03
A business plan with projections for the services applied for, matched to the categories of Article 5 and, for e-money, to the NBU's prudential ratios under Regulation No. 190.
04
Ownership structure disclosed to the ultimate beneficial owners, with the business reputation of owners and managers assessed under Regulation No. 217.
05
Corporate governance and risk management systems under Article 15 - functions, reporting lines and controls proportionate to the services.
06
Arrangements for protecting users' funds and for settlement through SEP or partner banks, described in the file.
07
Information-security and operational-resilience arrangements to the NBU's requirements for payment service providers.
08
AML/CFT policies under Ukraine's financial-monitoring law, with a responsible officer and reporting to the State Financial Monitoring Service.
09
For a small payment institution: services limited to Ukraine within the NBU's volume limits, and a plan to re-license within 240 days if they are exceeded.
10
Agents and distributors identified for entry in the Register of Payment Infrastructure, with the contracts the NBU expects.
01
Ukrainian entity, or foreign branch (Art. 14).
02
Capital UAH 1M / 3M / 5M / 10M in money.
03
Business plan per Article 5 services.
04
Owners to UBO; reputation assessed.
05
Governance and risk management (Art. 15).
06
Fund protection and settlement described.
07
Information security to NBU rules.
08
AML with responsible officer.
09
Small PI: domestic limits, 240-day upgrade.
10
Agents identified for the Register.
Reflects Law No. 1591-IX of 30 June 2021 (in force 1 August 2022), NBU Regulations No. 190 and No. 217 of 2022 and the NBU's open-banking rules of 25 July 2025, as of 2026.Law No. 1591-IX (2021); NBU Regulations No. 190 and No. 217 (2022); open-banking rules of 25 July 2025.
How it works
From first call to the NBU register.
01
Route and strategy
PI, e-money institution, small PI or foreign branch; service list and capital tier - the route and budget fixed in writing.PI, e-money, small PI or branch - in writing.
02
Company and capital
Ukrainian entity formed, capital paid in money to the Article 16 figure, owners and managers documented.Formed, paid in money, documented.
03
The application file
Business plan, governance, fund protection, security and AML documentation under Regulation No. 217 - complete before filing.Regulation No. 217 documents.
04
NBU review
The 60-working-day clock from a complete file, question rounds answered - plan on six to nine months end to end.60 working days; 6-9 months realistic.
05
Register entry and launch
Licence entered in the Register of Payment Infrastructure, agents registered, rails live - and the reporting calendar running.Agents registered, rails live.
Quick facts
RegulatorNational Bank of Ukraine
LawNo. 1591-IX (2021)
LicencePI · e-money institution · small PI
CapitalUAH 1M / 3M / 5M / 10M
Decision60 working days
PassportNone - domestic
Timeline6-9 months realistic
Corporate tax18% · VAT 20%
The clock runs from a complete file, which is where most applicants lose time. A file the NBU accepts at first reading is what keeps the review inside the statute, and our job.
Your Ukraine desk
Run from our Eastern Europe desk.
Prifinance - Eastern Europe desk
Budapest · coordinating Ukrainian mandates
Korányi Sándor u. 4, Budapest
01
Ukrainian company formation
A TOV or joint-stock company with the authorised capital paid in money to the Article 16 tier, and the ownership structure documented to the beneficial owner.TOV, capital in money, UBO documented.
02
The NBU file
Business plan, governance, fund protection, information security and AML documentation under Regulation No. 217 - drafted by us and defended through the 60-working-day review.Regulation No. 217 answered in order.
03
Rails and settlement
SEP access through partner banks and the e-money settlement model agreed before launch.SEP via partner banks.
04
Substance in Ukraine
Managers who pass the NBU's reputation test, a financial-monitoring officer and premises - the presence the Register entry is built on.Managers, monitoring officer, premises.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Ukraine.
An 18% base corporate rate with a 25% bracket for financial institutions, 20% VAT and 15% withholding on dividends to non-residents - checked line by line for the licence you hold.
Corporate tax 18%
The base rate under the Tax Code. Financial institutions other than insurers pay 25%; whether a payment institution is taxed as one is confirmed for your structure before launch.25% for financial institutions.
VAT 20%
The standard rate, with a UAH 1 million registration threshold. Payment and settlement services carry exemptions; technology fees may not - the product mix is mapped early.Threshold UAH 1M.
Dividends 15%
Withholding on dividends and other income paid to non-residents is 15%, reduced by Ukraine's treaty network where the parent qualifies.To non-residents; treaties cut it.
Financial institutions 25%
The higher bracket for financial institutions - a licensee combining payment services with other financial activity plans for it.Financial-institution status checked.
Payroll
Personal income tax, the military levy and the unified social contribution on Kyiv salaries - the operating budget prices them in.PIT, military levy, USC.
Treaties
A wide treaty network - outbound dividends and service fees are structured with the licence, not after it.Wide network.
Tax summary
Corporate tax18% · 25% financial institutions
VAT20% · threshold UAH 1M
Dividend withholding15% to non-residents
Other non-resident income15%
PayrollPIT + military levy + USC
Tax treatiesWide
*Figures as of 2026 per the State Tax Service. Treaty and regime positions are assessed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Ukrainian TOV, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed institution.
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Ukraine · NBU
Launch your payment project in Ukraine with expert support.
Full-service assistance - from company formation to the NBU licence, fund protection, rails and ongoing compliance.
Get a consultation →Free legal opinion
Is Ukraine the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which jurisdiction, licence scope, or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The Ukrainian payment licence, answered.
What licence does a payment business need in Ukraine?+
A licence from the National Bank of Ukraine, granted by entry in the Register of Payment Infrastructure under Law No. 1591-IX - as a payment institution for the financial payment services of Article 5, or as an e-money institution to issue electronic money. Payment initiation and account information are non-financial services and register rather than license.
How much capital is required?+
Article 16(3): UAH 1 million for payment initiation or transfers without an account; UAH 3 million for both, or for one of the financial payment services in points 1 to 5; UAH 5 million for several of them or for a postal operator; UAH 10 million to issue e-money. The capital is formed in money only.
How long does the NBU take?+
Article 11(6) gives the NBU 60 working days from receipt of the application and a complete set of documents to decide. With preparation and question rounds, plan on six to nine months from first call to register entry.
What is a small payment institution?+
A simplified licence under Article 13 for services provided in Ukraine only, within volume limits the NBU sets. A small PI that exceeds them must obtain the full licence within 240 days.
Can a foreign payment institution operate in Ukraine?+
Yes, through a branch accredited by the NBU under Article 14 - unless the institution is controlled by residents of a state the law names as an aggressor.
Does the licence passport?+
No - it is a domestic licence for the Ukrainian market. Groups that need the EU pair it with an EU home state; we sequence the two.
How are payment companies taxed?+
Corporate tax at the 18% base rate, or 25% if the licensee is taxed as a financial institution; VAT at 20%; 15% withholding on dividends and other income paid to non-residents.
What substance does the NBU expect?+
A Ukrainian entity with owners and managers of good business reputation, corporate governance and risk management under Article 15, information-security arrangements, a financial-monitoring officer and premises.
Is there open banking?+
Yes - the law provides for it and the NBU approved its open-banking rules on 25 July 2025. The statute also carries a regulatory sandbox for new products.
Why Ukraine rather than Moldova or Poland?+
Ukraine is the larger market with a PSD2-shaped law and hryvnia capital; Moldova is the smaller neighbour with a 12% tax rate; Poland is the EU home state with the passport. Groups serving Ukrainian clients license here and add an EU base when they need one.
Which licence?+
NBU PI or e-money institution; PISP/AISP register.
Capital?+
UAH 1M / 3M / 5M; e-money UAH 10M.
How long?+
60 working days; 6-9 months realistic.
Small PI?+
Domestic only; 240 days to upgrade.
Foreign branch?+
Yes - accreditation under Article 14.
Passport?+
No - domestic licence.
Taxes?+
18% (25% financial), VAT 20%, dividends 15%.
Substance?+
Governance, security, monitoring officer, premises.
Open banking?+
Yes - NBU rules of 25 July 2025.
vs Moldova / Poland?+
Larger market; no passport.
Client notes
Google4.7★★★★★
Founders who wanted it done right.
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the National Bank of Ukraine or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.