“The All-Ukrainian Association of Financial Companies, the Ukrainian Association of Fintech and Innovative Companies, the Association of Ukrainian Banks, the Ukrainian Interbank Association of EMA Payment Systems Members, and the International Payment Association GPA addressed a joint statement to the First Deputy Chairman of the National Bank of Ukraine, Serhii Nikolaychuk. Representatives of non-bank providers of payment services operating on the payment market of Ukraine requested to postpone the action”, — write on: ua.news
The All-Ukrainian Association of Financial Companies, the Ukrainian Association of Fintech and Innovative Companies, the Association of Ukrainian Banks, the Ukrainian Interbank Association of EMA Payment Systems Members, and the International Payment Association GPA addressed a joint statement to the First Deputy Chairman of the National Bank of Ukraine, Serhii Nikolaychuk. Representatives of non-bank payment service providers operating on the payment market of Ukraine requested to postpone the NBU Board Resolution No. 64 dated June 13, 2025 “On some issues of determining the regulatory capital of non-bank payment service providers”.
The statement says:
Clause 2 of the specified Resolution defines the obligation of payment institutions (except small payment institutions), financial institutions that have the right to provide financial payment services, and postal operators (hereinafter – the Institutions) to ensure that their regulatory capital meets the requirements of the Regulation on Regulatory Capital Requirements by December 31, 2025.
Since the adoption of the mentioned Resolution, the members of the Associations have carried out complex work aimed at analyzing its provisions, assessing the impact on the activities of the Institutions and determining possible ways of bringing the regulatory capital into compliance with the established requirements. Within the framework of this work, discussions were held at the level of market participants, specialized associations and management bodies of non-bank providers of financial payment services, preliminary financial calculations and analysis of the regulatory, economic and procedural consequences of the implementation of paragraph 2 of the Resolution were carried out within the prescribed period.
Based on the results of the said discussions and analysis, non-bank providers of financial payment services came to the conclusion that, despite understanding the regulatory goals of the Decree and readiness for its implementation, bringing the regulatory capital into compliance by December 31, 2025 is objectively difficult and in some cases impossible for reasons beyond the will of such market participants, in particular, considering the economic, competitive and procedural factors outlined below.
In addition, during the same period, the Institutions – members of the Associations simultaneously implement other regulatory requirements and recommendations of the NBU, in particular, related to the implementation of the provisions of the Resolution of the Board of the NBU dated August 28, 2025 No. 103 (obtaining licenses for acquiring) and the implementation of the recommendations of the National Bank of Ukraine regarding the acquisition of licenses (permits) for currency operations.
The specified regulatory changes require significant organizational, financial and personnel resources from non-bank providers of financial payment services, including adaptation of internal policies and procedures, improvement of IT infrastructure, bringing financial monitoring and risk management systems into compliance with the updated requirements.
Under such conditions, the simultaneous implementation of several large-scale regulatory blocks, each of which has a significant impact on the operating model and financial stability of non-bank providers of financial payment services, creates an excessive cumulative burden on non-bank participants of the payment market, which objectively complicates the fulfillment of the requirements for bringing regulatory capital into compliance by December 31, 2025.
In connection with this, the Association for the first time appealed to the National Bank of Ukraine with a request to consider the possibility of postponing the deadline for fulfilling the requirements of paragraph 2 of the Resolution until the end of martial law in Ukraine.
In the appeal, the following factors are asked to be taken into account in justifying such a need:
- 1. Disproportionality of requirements in comparison with EU regulation: The Regulation provides for the application of increased conversion factors when calculating capital: 1.25 or 1.5 – if the share of cash transactions or P2P transfers exceeds 25% or 50% of the total volume of services, respectively. At the same time, the EU methods allow the use of lower coefficients: for example, a coefficient of 0.5 is set for the money transfer service, 0.8 for certain other services, and 1.0 for the rest of the payment services. That is, the coefficients established by the Resolution (1.25–1.5) are in 1.5 –
2 times higher than in EU countries (0.5–1.0). As a result, non-bank providers of financial payment services in Ukraine must maintain a significantly larger amount of capital than similar institutions in the EU, with equal volumes of payment transactions. - 2. Low margin of payment services in Ukraine:
The profitability of non-bank payment service providers in the domestic market remains low. The average level of margin of Ukrainian payment providers is 2-3 times lower than that of their European counterparts. Because of this, the net profit, as a rule, does not allow
build or maintain a sufficient level of regulatory capital without constant additional external financing. In comparison, EU payment companies have higher profitability, which allows them to direct more of their own resources to cover regulatory requirements. In Ukraine, there are participants
market are forced to work with a minimum margin and maximum cost efficiency, therefore compliance with inflated capital requirements requires regular additional infusions of funds, which are economically difficult to provide. - 3. Competition with banks and limited opportunities to increase tariffs: Non-bank providers of financial payment services operate in a common market with banks, which have access to a much wider base of income and assets. Banks can cross-subsidize payment services with profits from other activities or sustain a lower margin on payments. On the other hand, non-bank providers do not have such reserves and cannot painlessly raise tariffs for their services to quickly increase capital – because any significant increase in commissions will lead to a loss of competitiveness and an outflow of customers in favor of banking services.
Therefore, non-bank providers of financial payment services cannot actually increase the margin to ensure compliance with regulatory capital requirements, which makes it difficult to meet increased capital requirements at the expense of internal resources. - 5. War realities: limited investment capital and additional burden: In the conditions of war and martial law, access to external investment and capital is extremely limited. Foreign investors are currently not ready for large-scale investments in the Ukrainian financial sector, and many domestic companies and private investors and current owners are forced to direct resources to maintaining erv activity and fulfillment of social obligations. According to experts, attracting new capital in significant amounts will be possible only after the end of the active phase of the war and the stabilization of the situation. At the same time, non-bank payment service providers bear an additional burden (operational risks, cyber security costs, etc.) in martial law. Thus, until the end of the war, non-bank providers of financial payment services are practically deprived of the opportunity to increase their capital by attracting investments, which makes
it is impractical to set strict deadlines specifically for the period of military uncertainty.
“Taking into account the common goals of the National Bank of Ukraine and participants of the payment market to increase the financial stability, stability and reliability of the state’s payment infrastructure, as well as the objective economic, competitive and procedural conditions of the activity of non-bank payment service providers during the period of martial law, the Associations are convinced that it is expedient to implement the step-by-step implementation of requirement 5, paragraph 2 of the Resolution. Such an approach will ensure the achievement of regulatory goals without creating an excessive systemic and cumulative burden on payment market participants and will contribute to the stable and responsible fulfillment of regulatory requirements,” representatives of non-bank payment service providers ask.
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